With “dueling” safety auditing standards in play today, what's a charter operator to do?
Referring to “shelfware,” or manuals kept on prominent display solely for the benefit of the safety auditors that list procedures the operation actually isn't using, Lawton stressed the importance of following through and then documenting the actions. “‘Walk me through how you put together an international trip,’ is an example [of how an ACSF auditor would approach an inspection],” Lawton said. “You may be able to tell me, but if it's not documented, it's worth nothing. If the key person who knows the process disappears tomorrow, you are the source of ‘tribal knowledge’ in the company for this process. It all goes to accountability - if we don't agree on a procedure, there is no standard.”
The ACSF began conducting audits in June 2009. Keith's Jet Solutions was the first Part 135 operator to complete the audit and achieve registration; second was's Flexjet fractional operation (for which Jet Solutions provides the majority of charter backup.)
Another early adopter is Executive Fliteways, a charter operator based in Ronkonkoma, N.Y. Noting that his company was one of the first to undergo an ACSF audit, Ken Gray, the director of operations, said, “The ACSF standards are more comprehensive and thorough than those of the major auditing companies.” When Jet Solutions underwent its audit, Keith reported, thesent a team from the Washington headquarters to observe the process and, in turn, audit the ACSF standard and the auditors performing the inspection.
As of mid-November, 27 charter operators had gone through the process, with only two posted in the registry at that time, as the bulk of the audits were still in review and some operators were correcting shortcomings revealed by the inspections.
“After the audit is completed and reviewed, any findings not conforming to the standard are presented to the operator, whose personnel must then develop a corrective action plan as to how they intend to meet the standard in order to resolve the finding,” Lawton explained. “Then the next step in the process is to implement the corrective action plan and document it.”
If revisions are necessary for the operations manual, the ACSF requires proof that the revision has been accepted by the FAA, since a commercial operator's manual is an approved document. Other findings might apply to revising training, SOPs, etc. “It is an accepted conclusion that there are three basic fixes in this business,” Lawton said: “technology, training and regulations.”
Operators can be audited by request of outside entities, such as potential customers desiring to ensure particular charter providers meet their preferred safety level, or can request the audits themselves either as an internal checkup or simply to get themselves into the ACSF registry. Before an auditor is retained (which is the responsibility of the operator), the ACSF provides the operator with a pre-audit checklist to aid preparation for the on-site inspection. “The whole idea to avoid having someone going through the process who really isn't prepared to do it,” Lawton said. “Once it's established they're in good shape for the audit, then they [the operator] can approach one of the accredited auditors and set up the appointment schedule.” A completed audit is good for two years.
The ACSF accredits existing third-party audit companies authorized to conduct the audits, eight having been approved thus far. “The auditors are trained individually and must be affiliated with the auditing companies,” Lawton said. “The ACSF does the training, ensuring consistency and quality and that everyone is on the same page.”
Once an audit is arranged, the operator pays the ACSF for the audit fees, and the Foundation reimburses the audit company when the audit is completed. “We use a sliding pricing scale based on the number of aircraft in the operator's fleet,” Lawton said. “The basic audit is three days and two auditors for one to 15 aircraft, priced at $13,650.” For a fleet between 16 and 30 aircraft, four days is required, and the fee is set at $17,280. “When it goes beyond four days,” Lawton said, “we base it on a per-day fee.”
(A price schedule can be viewed on the ACSF Web site at www.acsf.aero. For information on the audit standard, add “/audit.” The operator standards manual, guidance material and a regulatory reference index can be downloaded without charge.)
Lawton acknowledged, “Some operators want to be audited by ARGUS, Wyvern, and do IS-BAO as well because they want to put those stamps of approval on their ads,” a pursuit he described as “a marketing tool. If you can demonstrate you are operating to a higher standard it is a win-win for the industry.”