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Paper in support of presentation at 2004 Aviation Litigation Committee CLE Seminar, June 3rd 2004.

IOSA the IATA Operational Safety Audit Programme


Mike OBrien Director, Programme Implementation/Auditing IATA

In late September 2003, the first IOSA audit was carried out. The recipient airline was Qatar Airways, based in Doha, UAE. Since then, twelve more IOSA airline audits have been completed, representing a good start for IATAs ambitious programme to audit all of its 275 Members in the coming years. Even as recently as 2000, the concept of a global, harmonised, consistent programme for the operational safety auditing of airlines seemed like an unattainable goal. It had never before been attempted on such a scale. But, taking a leaf from the ICAO book with respect to Universal Safety Oversight, IATA launched the investigative and development phase of IOSA in 2001. The aims were simple to standardize, harmonise and rationalise the growing number of often redundant airline audits and thereby to improve operational safety and to save airlines money. As more and more airlines are undertaking audits of other airlines, either to meet State regulatory requirements or for their own commercial interests, the attractiveness of a common audit standard becomes very great indeed. Some airlines today undertake a dozen audits annually, and are themselves audited many times. There are no common audit standards; there is no consistent auditor training; audit results are not shared. Just imagine if every airline carried an audit registration, such that, once audited to a common agreed standard, it did not need to be audited again during the validity period of that audit. Once a good number of airlines were so audited, the numbers of audits being undertaken would be vastly reduced. Therein lies the heart of IOSA. IOSA is an internationally accepted and recognized evaluation system designed to assess the operational management and control systems of an airline. IOSA uses internationally recognized quality audit principles, and is designed so that audits are conducted in a standardized and consistent manner. At the outset of the project in 2001, some fundamental decisions were taken by IATA, which have guided the project to its successful implementation. These were: Development of a common set of IOSA standards, covering all aspects of an airlines operations that contribute to operational safety.

Involvement of ICAO, and key Regulatory Authorities, in the standards development and in the programme generally. That IATA itself would not carry out the audits; instead, it would appoint Audit Organisations (AOs) that would meet closely defined criteria. That any auditor conducting IOSA audits meets strict training criteria. That the full support of the IATA Membership be gained prior to official Programme launch. IOSA Standards Manual The manual is the source document for the IOSA Standards and Recommended Practices, and associated guidance material, on which each IOSA audit is based. The audit checklists used by the auditors on-site are drawn directly from these standards. More particularly, the ISM provides all information necessary for an airline to structure its operations in preparation for its audit. Over 100 industry specialists, drawn from airlines, ICAO, Regulatory and other Government Authorities, assisted IATA in the development of the IOSA Standards. The manual provides operational standards for an airline in these areas: Corporate Organisation and Management Flight Operations Operational Control/Flight Dispatch Aircraft Engineering & Maintenance Cabin Operations Aircraft Ground Handling Cargo Operations Operational Security The first edition of the ISM was published by IATA in April 2003, and has proven very popular. The document is subject to revision, in a structured way. For example, the first audits have shown that some of the audit standards need further clarification; these improvements will be made. Also, existing IATA Committees and Working Groups, with specific responsibilities in the areas of the IOSA standards, now have oversight of these standards and may themselves identify areas that need to change, either as a result of their own expert perspective, or because of external changes (e.g. regulatory revisions) of which they may become aware.

Audit Organisations The appointment of any organisation to undertake IOSA audits is not taken lightly. A comprehensive and consistent examination of the capabilities of each candidate company is undertaken. Technical, legal, financial and other

issues are examined, with the aim being to ensure that all AOs meet the very high standards established. As part of its ongoing management role of the Programme, IATA retains the right to observe any IOSA audit being conducted by any AO. In particular, it is mandatory for the first audit of any AO to be so observed. A typical IOSA audit would see six auditors on-site for a period of five days. Audit Organisations must employ only auditors that have met stringent IOSA qualification and training standards. Training of IOSA auditors is conducted by IOSA Endorsed Training Organisations. At this time, only one ETO has been appointed (AQS GmbH) to train the number of IOSA auditors required, but other ETOs may be appointed should the need arise. The 5-day training course for IOSA auditors is basically differences training. That is, the training course takes experienced aviation auditors and brings them up to the level of the IOSA audit standards. Audits carried out under IOSA are not free. Each airline must contract with an Audit Organisation, in a free market environment. IATAs commitment to its Member Airlines is that it will provide a range of Audit Organisations, with both regional and global coverage. Each airline is then free to choose the AO it wants, based on whatever financial and other criteria the airline establishes. As of May 2004, IATA had appointed six Audit Organisations Aviation Quality Services GmbH in Germany, United PROS in the United States, Aviation Compliance Solutions Pty Ltd in Australia, Wake Ltd in the UK, Morton Beyer and Agnew, and SH&E, both in the US. Despite their geographic home, each AO has indicated an ability to work worldwide. Any airline anywhere in the world can contact any of these AOs to get a quotation for their IOSA audit. The decision for an audit company on whether or not to become an IOSA AO is based on many factors, including an assessment of market share, and the cost of establishing an organizational structure, and insurance coverage, that will meet the IOSA requirements. IATA anticipates that up to ten AOs may be required to service the needs of auditing its full membership of 275 airlines, every two years.

Who will be audited under IOSA? Throughout the development phase of IOSA, consistent and positive guidance and support was provided by the IATA Board of Governors. That support was translated, at the IATA AGM in June 2003, into a Resolution on IOSA. That Resolution committed the existing IATA Membership 275 airlines - to seek an IOSA audit by the beginning of 2006. Whilst that timetable is subject to annual review by the Board, fundamentally it means that the existing Membership must have had its first IOSA audit, or be well on the way to achieving that audit, by the beginning of 2006. Its a substantial goal indeed, given the disparate size and nature of the Member Airlines.

But confidence in achieving that goal is high, because of the depth of support for the Programme. This was well-illustrated by the passage of the Resolution at the IATA AGM. It was proposed by Lufthansa a large European carrier, seconded by COPA of Panama a smaller Latin American carrier, and supported by Gulf Air a medium-sized Middle East carrier. And interest beyond the IATA Membership is growing. Charter airlines, corporate General Aviation, aircraft leasing companies, are all showing interest in IOSA.

Do Airlines pass the IOSA audit? At the completion of the on-site portion of the IOSA audit, the Audit Organisation issues to the airline an initial Audit Report. This document contains all the audit findings, as well as listing the corrective actions that the airline needs to take. The airline has up to twelve months in which to complete these actions (all of which will be verified by the AO), but clearly it is in the airlines best interests to clear all actions as soon as possible. It is only after all actions are cleared that the airline can be entered on the IOSA Registry. The IOSA Registry is a list of all current airlines that have successfully completed an audit under IOSA. Entry to the Registry is based on closure of all audit findings, and registration has a defined validity period 24 months before another IOSA audit is required. Any airline that would normally audit another airline for, e.g., code-sharing purposes, can check the publicly-accessible IOSA Registry listing to determine if that other airline has been audited under IOSA. If so, they may make an application to view the full audit report, and thereby save themselves the need to undertake their own audit. Although the audit report is held by IATA, the audited airline remains at all times the owner of the report, the contents of which will be released only on the specific agreement of the audited airline.

Role of State Regulatory Authorities As noted at the start of this paper, both ICAO and some key Regulatory Authorities have been involved in IOSA development since the outset. The US FAA, Transport Canada and the Australian Civil Aviation Safety Authority have been prime contributors and supporters. The US Department of Defense has also been involved; as the US Government body charged with the responsibility of ensuring that all airlines carrying US Government personnel meet certain standards, they too are keen to see an acceptable form of common airline auditing.

For the IOSA Programme to truly succeed, Regulatory Authorities worldwide must, at the very least, accept the concept of IOSA. But that is just the start. It is highly likely that States could see in IOSA an opportunity to enhance and extend their oversight capability, as well as to better target their limited resources. The US FAA for example, recognizes and values IOSA as a unique program that has the real potential to advance worldwide airline safety. As such, it is fully in keeping with both our broad and specific aims at the FAA. Transport Canada believes that it is not inconceivable that the maintenance of IATA/IOSA Registration could become the main benchmark of Transport Canadas foreign air operator risk assessment process. And of course ICAO sees that our (i.e. ICAO and IATA) collaborative efforts . will enhance safety of aircraft operations around the world. The EC finds IATAs initiative to be very helpful indeed. Presentations have been made also in 2003 and 2004 to the Austrian Mot, the Scandinavian CAA, CAAC China, Japan JCAB, CAAs in Saudi Arabia, Lebanon, Egypt and Bahrain, the Southern African Development Community and the French DGAC. The programme of Regulatory Authority awareness sessions will continue.

Programme Management and Oversight After having fostered its development and launch, IATAs role is now to ensure the successful implementation, ongoing programme management, and Quality Assurance. IATA will continue to oversee the accreditation of further Audit Organisations and Training Organisations, ensure continuous development of the IOSA Standards and Recommended Practices, and manage the central database of IOSA audit reports. In addition, IATA will implement effective quality assurance to ensure overall programme standardisation, as well as continually work with airlines and regulators to ensure that IOSA meets their needs. The audits themselves will provide extensive information that can be used firstly to improve the audit process, and the standards. More particularly, the audit results can show trends and/or areas that need specific attention in order to improve safety. The IOSA Oversight Committee has been formed. In a first for IATA, IOC membership consists not only of airline representatives, but also of regulators, in recognition of the vital role that such organisations play in the success of IOSA. To further ensure that the IOSA programme is managed and organized in a consistent and regular fashion, all aspects of the Programme, from auditor selection, to training, to audit report access, are embodied in the IOSA Programme Manual. This Manual also guides all day-to-day operations of the Programme and its small support team, based in IATA Headquarters in Montreal.

The Existing IATA Membership Entry Audit Since 1999, any airline wishing to become a Member of IATA must pass an Operational Quality Standards (OQS) audit. These audits are conducted, by IATA, largely against the airlines own published standards. The IATA 2003 AGM Resolution provided, in addition to requiring IOSA audits for existing Members, that the OQS Programme be folded into IOSA during 2004. The various Divisions of IATA dealing with new Members are now working with the IOSA Programme Team to devise the most practicable and equitable way to meld the two Programmes.

The Future In the short term, IATA will be focussed on IOSA implementation across its Membership, and in raising awareness of the benefits of the programme amongst both the airline and regulator communities. But already, the right questions are being asked could an IOSA-style approach yield similar benefits (reduced costs, improved operations) in other areas of airline operations? This prospect was first raised by the IATA Board of Governors in May 2003 and since then, preliminary investigations have shown that indeed there are many such areas that could be explored. For example, Maintenance, Repair and Overhaul (MRO) organisations, Catering companies, Fuel suppliers/distributors, could all be candidates for such a similar concept. For IOSA itself, the future looks very promising. The benefits are clear, and the Programme is now well set up to deliver those benefits. Challenges still remain in getting the message out on IOSA, and IATA looks forward to further cooperation with ICAO in this regard to ensure that both airlines and States start to see IOSA as the new standard in airline operational safety auditing.

Contact the IOSA Programme Team at iosa@iata.org, or visit the website www.iata.org/iosa

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