Focused IEP for Small Operators

Internal control dates back to when operational complexity required one person to have custody of assets belonging to others (Wilson, Wells, Little, & Ross, 2014, p. 85). So when the owner of an aircraft asks the aviation manager, “How are things going?”, it’s reasonable for the owner to expect the manager to validate the answer, “Just fine!”, with some sort of systematic approach.

An internal evaluation (IE) is a quality review undertaken within an organization for its own benefit with or without the involvement of an external subject matter expert. From an external agency perspective, the internal review is perceived as the part of the process that an organization undergoes to prepare for an external audit (Harvey, 2016).

An IE is typically carried out by someone from within the organization. Such an evaluator has the advantage of fully understanding the logic behind the processes and also appreciates any problems that may have developed. Furthermore, it is important that others in the organization trust and cooperate with the person designated as the internal evaluator. However, an internal evaluator may find it challenging to criticize the work of others, and, because of their close involvement with other team members, may be hesitant to suggest innovative solutions to findings. Such an internal evaluator may know very well how their colleagues have toiled to develop their current programs, and therefore, may shy away from the idea of suggesting even more work (Robert Gordon University, 2016).

IEPs and Safety Risk Management
Safety Assurance, a key component within the SMS framework, can be supported with an internal evaluation program (IEP). The Safety Management International Collaboration Group (SMICG), made up of representatives from national authorities around the world, posit, “No matter how small your organization, an internal audit will assess your processes and procedures and give you a level of confidence that everything is being done properly and your staff members are following your policy and procedures” (SMICG, 2015, p.11).

So why are we quoting information from a document written by the SMICG? First, ICAO requires states to ensure operators implement an SMS via Annex 19. Specifically, ICAO requires all commercial operators and international GA operators of large or turbojet aircraft implement an SMS. Yet, the FAA requires only Part 121 operators to have an SMS and offers AC 120-92B for guidance in implementing FAR Part 5 (SMS) requirements. Because the FAA’s SMS guidance for business aviation, especially for small operators, is very limited, international sources for SMS implementation guidance, such as SMICG and IS-BAO, are excellent sources.

Managing an IEP
The SMICG offers the following guidance for the small operators for managing an IEP:

• The internal auditor should be independent of the process being audited.
• The internal auditor should record the findings and agreed corrective actions.
• Management should capture hazards and risks in the Hazard Log.
• The best results can be realized with cross functional teams performing the audit on a progressive basis, completing a partial internal audit each quarter.
• If the manager determines it is too challenging to ensure an independent internal audit, an external auditor should be utilized.

Focused IEP for Small Operators
While ensuring compliance with regulatory requirements is important, internal audits should focus on the effectiveness of safety risk controls and related processes. For the small operator, the concept of an IEP can seem overwhelming. So what can a small operator do to ensure their limited resources are used wisely? Consider how some pilot checklists are designed to focus attention on more critical items. Under this method, each pilot completes their “flow” independently then they meet together to ensure the “killer items” are verified. This has proven to be a very efficient way to manage human resources on the flight deck, especially during critical phases of flight when time is limited, e.g. during final approach.

If operators were to apply a similar approach to conducting the internal evaluation, they could focus their efforts on working together to analyze the potential “killer items” threatening their operations. But what are they? Each operator has its own unique threats. For example, an operator may sometimes fly circling approaches at night in mountainous terrain at an uncontrolled airport with no radar. This is not recommended, by the way; it is simply offered as an example of a unique risk.

Also, both the NTSB and the NBAA provide a good starting point for “killer items” in the absence of specific organizational safety risks. For instance, in 2016 the NTSB highlighted procedural non-compliance, distraction, fatigue, substance impairment, and personnel not fit for duty as basic hazards plaguing the transportation system. Any aviation manager should evaluate, on an ongoing basis, how effective the organizational controls are at mitigating the safety risks related to these threats, which are all related to human factors.

As a technique, the “daily debrief” is an excellent, low cost way to capture valuable information related to the effectiveness of mitigation strategies. If aviation professionals would take 5-to-10 minutes at the end of each duty day and truthfully answer the following three basic questions in a software system, the aviation manager could monitor for trends:

1. Were there any deviations from policies, processes or procedures (PPP) today?
2. If yes, which one(s)?
3. If yes, why?

As long as the organization’s PPPs are aligned with best practices, capturing deviations is one of the best starting points for an IEP. Furthermore, internal surveys related to the aforementioned NTSB “killer items” can provide additional insight for management.

References
Harvey, L. (2016, February 3). Analytic Quality Glossary. Retrieved August 21, 2016, from Quality Research International: http://www.qualityresearchinternational.com/glossary/internalevaluation.htm

Robert Gordon University. (2016, August 21). External and internal evaluation. Retrieved from Robert Gordon University: http://www2.rgu.ac.uk/celt/pgcerttlt/evaluating/eval4.htm

SMICG. (2015, March 1). SMS for Small Organizations. Retrieved August 20, 2016, from Skybrary: http://www.skybrary.aero/bookshelf/books/3055.pdf

Wilson, T., Wells, S., Little, H., & Ross, M. (2014). A history of internal control: From then to now. Academy Of Business Journal, 1, 73-189.