Safety management is a prerequisite for any sustainable aviation business and few organisations can survive the economic consequences of a major accident
The business case for safety management systems (SMS) is clear. Accidents make bad business sense, as insurance does not cover risks and economic viability requires public confidence. In the case of Indian non-scheduled operator companies, the repeated downgrade by the Directorate General of Civil Aviation (DGCA) on safety concerns has, not surprisingly, adversely impacted the charter business. Safety management is a prerequisite for any sustainable aviation business and few organisations can survive the economic consequences of a major accident. The direct cost of accidents entails repairing physical damage to equipment and property and cost of hospitalisation of people injured. The indirect costs of accidents are many including:
Here is a sample of accident costs relating to small aircraft operators:
Benefits of SMS: A sampling of the savings of effective SMS implementation by aircraft operators are:
SMS is the cornerstone of the IS-BAO. Its implementation by Indian GA/BA operators makes for eminent business sense! Experience also demonstrates that safety is a good business practice!
Safety Oversight, SSP & safety downgrade
The International Civil Aviation Organisation (ICAO) document 9734 defines ‘safety oversight’ as a “function of states which ensure effective implementation of safety-related standards and recommended practices (SARPS) of ICAO. There are critical elements to safety oversight that requires development, relating to the following:
• Primary Aviation Legislation, • Specific Operating Regulations, • Empowered Regulatory Authority, • Technical Guidance, • Licensing and Certification, • Continued Surveillance, • Resolution of Safety Issues
The legislation for setting up of a CAA for India is long overdue and not likely to be an immediate priority. The lack of resources in the hands of the regulator can be expected to adversely impact the ability of the regulator to effect timely changes to meet the expectations of the GA/BA sector.
State Safety Programme (SSP): The SSP is an integrated set of regulations and activities aimed at improving safety. States are responsible for establishing a safety programme based on the following elements:
• Safety Regulations, • Safety Oversight, • Accident/Incident Investigation, • Mandatory/Voluntary Reporting Systems, • Safety Data Analysis & Exchange, • Safety Assurance, and • Safety Promotion.
Safety Downgrade: It would appear that the safety downgrade by the FAA points to deficiencies in the twin areas of oversight as well as the SSP.
Effective Implementation of SMS: The DGCA had issued a CAR on SMS in July 2010. NSOP operators were to implement their SMS over a three-year period. However, it would appear that operators have not had much success in effectively implementing the SMS. Part of the problem appears to be a deficiency on the part of the regulator to provide suitable guidance to GA/BA operators.
The inability to effectively implement SMS has adverse business implications for GA/BA operators, especially those flying to international destinations. EASA’s new approach to the authorisation of third country operators will focus not only on validation of the air operator certificate (AOC) but would be subject to its confidence in the foreign (Indian) AOC. An increased activity/intervention by international regulatory authorities can be expected in future; this trend is driven by a multitude of factors with globalisation and third party liability issues playing a key part.
Since the IS-BAO is well recognised internationally, the IS-BAO provides a good option for Indian GA/BA operators to adopt, from the point of view of protecting business interests, as well as reassurance to passengers and international regulatory authorities concerning the safety quality of the operator!
The Conundrum Faced by GA Operators
Failure to harmonise standards with internationally accepted best practices could be construed as contributing to safety deficiencies. GA/BA operators are therefore concerned that this gap should be bridged at the earliest, lest their operations are adversely affected, especially when traversing international air space. Post the safety downgrade, entry into certain air spaces may be denied to GA operators, unless proof of SMS implementation to an acceptable standard is endorsed by our regulator.
Benefits of IS-BAO
The ICAO standard states that GA operators of large aircraft (gross weight >12,500 lb/5,700 kg) and turbojet aircraft must establish and maintain an SMS appropriate to the size and complexity of the operation. ICAO recommends that GA SMS include:
The IS-BAO standard meets the requirements specified by ICAO. The IS-BAO provides the operator with a process to conduct internal evaluations and audits. These processes provide the means for continuous improvement. The IS-BAO programme is overseen by the IBAC (a not-for-profit organisation collocated with ICAO). The IBAC updates best practices on an annual basis and provides this info to operators implementing the IS-BAO. IS-BAO operators are thus assured of the validity of their practices year after year.
Mapping of a Safety Strategy: The IS-BAO contains inputs from an industry analysis, wherein, safety strategy is constructed around the following major safety themes:
• Safety culture, • Codes of practice (including SMS, training and human factors), • Adherence to industry standards, • Regulatory framework (rules and oversight), • Data collection and analysis, • Safety equipment and tools, • Air navigation and airport services, • Industry support services
Operators embracing the IS-BAO would have a solid professional foundation based on the Business Aviation Safety Strategy conducted by IBAC and member associations with support from the FSF (Flight Safety Foundation). As mentioned earlier, SMS is the cornerstone for the IS-BAO, which provides a mechanism for companies to continuously improve safety, which is a requirement of ICAO SARPS.
As can be seen, many of the issues already raised by the BAOA with regulatory authorities deals with the need to address the concerns / interests of the GA/BA industry, which for long has been ignored by the regulator. Some of the changes would require changes to existing aviation legislation, which means further delay and attendant frustration for the GA/BA fraternity. Adoption of the IS-BAO would automatically provide solutions to both stakeholders, namely, the GA/BA fraternity as well as the regulator (DGCA).
Standardisation of Multiple Types
The IS-BAO is applicable to both fixed-wing as well as rotary wing aircraft. A standard that is common to both aeroplanes and helicopters makes for ease of oversight by the regulator. Since the IBAC oversees the certification process, there is much advantage to the regulator in terms of savings in scarce resources (in trained personnel and finance).
Procedure for IS-BAO Implementation & Certification
NSOP and private operators interested in implementing the IS-BAO may contact the BAOA for purchase of the IS-BAO manual and tool kits that assist in the implementation process.
The author is an SMS instructor and IS-BAO auditor based in Bengaluru. He is a Managing Partner of CBAS Pvt Ltd that conducts aviation safety audits and MITRE-based SMS training. The views expressed are those of the author.