The Canadian USOAP Experience RDIMSSGDDI The Canadian USOAP

The Canadian USOAP Experience RDIMS/SGDDI

The Canadian USOAP Experience Aim: to share Canadian experience gained from the ICAO audit process to provide other states with an insight that may be helpful in preparing for upcoming audits Outline • Overview of the ICAO audit process • Canadian preparation • Canada’s Audit experience • Lessons Learned • Pitfalls to avoid 2 RDIMS/SGDDI

Overview of the ICAO audit process Program Objective (Assembly Resolution A 35 -6) Assess State’s implementation of: - Safety oversight, and - Standards and Recommended Practices, associated procedures and guidance material 3 RDIMS/SGDDI

ICAO auditing Philosophy cont’d ICAO’s Comprehensive Systems approach: Phase 1. Review of State Aviation Activity Question and Compliance Checklists to confirm Annex implementation and capability for Safety Oversight Phase 2. On-site audit to confirm information and assessment of State’s overall capability for Safety Oversight 4 RDIMS/SGDDI

Foundation Documents • Rules of Conduct -Memorandum of Understanding o • Audit documentation • Pre-audit tools - State Aviation Activity Questionnaire - Compliance Checklist • Protocol Checklists - On site interview questions 5 RDIMS/SGDDI

Foundation Documents cont’d Memorandum of Understanding • Defines obligations for the audit • Sent to State with notification of ICAO’s scheduled intention - 9 months in advance of audit date • States are expected to sign and return 90 days before the audit 6 RDIMS/SGDDI

Foundation Documents cont’d MOU Highlights • Scope to address all annexes except 9 and 17 • ICAO team members will have command of English and at least one member will have command of the language chosen by the State • Audit will be conducted in accordance with “Safety Oversight Audit Manual Doc 9735) • ICAO to conduct the audit in accordance within a specified timeline 7 RDIMS/SGDDI

Foundation Documents cont’d State agrees: - to provide necessary access to staff, documents, state facilities; - to provide transportation within the state; - to provide required translation services and office facilities; - to submit updated version of SAAQ and CC at least 90 days before the audit - to establish a national coordinator; and - to assist with accommodation arrangements. 8 RDIMS/SGDDI

Foundation Documents cont’d Documentation tools Preaudit • State Aviation Activity Questionnaire • Compliance Checklists - Forms are available on ICAO web site 9 RDIMS/SGDDI

Foundation Documents cont’d State Aviation Activity Questionnaire Advance information required by ICAO for scheduling and workload planning Provides overview information on State Activity organized into seven parts: • General Administrative • Legislative • Organization • Operational Activities • Air Navigation Activities • Aerodromes • Accident and Incident Investigation 10 RDIMS/SGDDI

Compliance Checklists • Advance information required by ICAO for assessing compliance with SARPs • Presents State with tool to identify differences to SARPs • Update required 90 days in advance of an audit 11 RDIMS/SGDDI

Foundation Documents cont’d Protocol Checklists A tool for conducting the on site audit or internal self assessment used to ensure: • Transparency • Consistency • Standardization Organized to conduct critical element assessment in eight modules: • Legislation • State Organization • Personnel Licensing • Operation of Aircraft • Airworthiness • Accident Investigation • Air Navigation • Aerodromes 12 RDIMS/SGDDI

Guidance Sources ICAO intranet website provides access to: • State Aviation Activity Questionnaire • Compliance Checklists • Protocol Checklists • ICAO Annexes and Documents • Completed audits on member states ICAO Coordinators course • Also listed on the web ICAO Team leader for the State audit • Makes a State/ICAO team for meeting both goals 13 RDIMS/SGDDI

Audit timeline - On site activity Entry meeting • Opportunity for introductions; • ICAO provides explanation of process; and • The State to provide a description of their organization. Conduct of interviews • Start with group interviews for Legislation and Organization; • Importance of time management - Audit plans are on strict schedule - State coordinators to ensure Protocol questions are organized, assigned and prepared for the interviews - ICAO team continues their work after State hours - A complex audit will take up to two weeks - Industry visits require State observer 14 RDIMS/SGDDI

Audit timeline - On site activity Closing meeting • meeting is for ICAO team to present their preliminary findings • no discussion of these findings is intended • beginning of timeline for acceptance of findings and the final report. 15 RDIMS/SGDDI

60 days 30 days RDIMS/SGDDI ICAO clarifies state response State clarifications to ICAO provides interim report to State Closing meeting 90 days 30 days ICAO translates and posts on Web Audit Timeline - Post Audit 16

Canadian Preparation for the Audit -Coordination -Communications -Arrangements for daily debriefs -Training for State interviewees 17 RDIMS/SGDDI

Application of ICAO process in The Pre-Audit phase Cont’d Coordination • three areas to be involved in coordination – Civil Aviation, Transportation Safety Board and Department of National Defense • Started work on advance arrangements for: » Accommodations and office facilities » Security clearances » Transportation arrangements for industry and regional visits 18 RDIMS/SGDDI

Scope for Canadian auditing initiatives contin’d Need for Internal Coordination System - State organizational structure does not parallel audit protocol organization or ICAO annexes - need to arrange and schedule appropriate interview candidates - need to support ICAO auditor during the audit 19 RDIMS/SGDDI

Application of ICAO process in The Pre-Audit phase Cont’d Communications - Need for close coordination between State Coordinator and ICAO Team - Resulted in effective coordination for planning and resolution of Protocol question issues - Introduction of Daily Audit debrief requirement - Daily feedback for Management and Interviewees - Triggers for providing follow-up clarification - ICAO tool for managing “areas of concern” 20 RDIMS/SGDDI

Scope for Canadian auditing initiatives contin’d Training for the State’s interviewees - Improved understanding of their role and the audit process; - Guidance on role reversal from auditor to interviewee; and - Guidance on what are suitable questions. 21 RDIMS/SGDDI

Preparation by the Interviewee • Protocol questions for specialty areas are available on ICAO’s web site; • Critical elements numbers on the protocol questions confused the interviewees during their preparation for the audit 22 RDIMS/SGDDI

Observations on the Canadian Audit Experience - description of ICAO’s Audit Plan; - observations on the interviews; - observations on the audit process; and - a description of the Findings 23 RDIMS/SGDDI

Page from ICAO Work Plan for OPS Specialist 24 RDIMS/SGDDI

A Description of ICAO’s Audit Plan 25 RDIMS/SGDDI

The Interview Process Contin’d Observations on the Interviews – ICAO’s lack of organizational understanding lead to misdirection of questions and inappropriate responses – Interviewees were frustrated by auditors changing the order of the Protocol questions as well as by questioning from shaded areas - T. C. frustration over amount of inputs that were not addressed – No use of non-international inventories – Did not address Annex 10 26 RDIMS/SGDDI

Daily Debriefs – Began on the end of second full day of interviews • Attended by State coordinator and ICAO Team Lead – Records provided to coordinators and ICAO • Interviewees verified proper understanding and necessity to provide additional information • ICAO used to manage their follow-up issues and confirm accuracy of record – During the Daily Debriefs, ICAO used the terminology “Area of concern” and at the closing meeting the term was changed to “Preliminary Draft Finding” 27 RDIMS/SGDDI

The closing meeting - Canada had all audit participants attend to ensure full understanding of results and to undertake immediate attention to corrective action. - Each ICAO specialist summarized the preliminary findings for their area - Canada responded with commitment to follow through on Findings. - ICAO ended the meeting with the request to complete a State Assessment form and the commitment to continue using the “Daily Debrief” as part of their audit process 28 RDIMS/SGDDI

Closing meeting Contin’d Was the audit a success? • From the state perspective; – Were the logistics met? • From the State and ICAO perspective; – Was a proper understanding of the state program developed to permit a satisfactory “systems” assessment? 29 RDIMS/SGDDI

Findings • ICAO auditors admitted that they had to dig deep to find non-compliance • There were “areas of concern” we disagreed with and upon clarification were able to resolve • Others included: – – international conditions on licenses Cabin crew flight and duty times PPCs every two years Notify ICAO of exemptions 30 RDIMS/SGDDI

Lessons Learned 1. Being a “Beta” audit did not impact the final results 1. A shortage of time did not prevent preparation for the audit 2. Staff wanted more information on ICAO and its requirements. Feedback was for more information on ICAO role, terminology and a simplified version of the audit process 3. Need for state to adopt more proactive role in managing interviews 1. Ensure assignment of Interviewers to appropriate expertise in the organization 2. Promote requirement for advance preparation of questions 31 RDIMS/SGDDI

Lessons Learned Contin’d Lessons Learned (continued) 4. State response to “areas of concern” required specific focus – Too much material prevented clear understanding of the state position 5. Communication plan was essential – Resulted in team building and knowledgeable inputs – Daily debrief supported clear understanding by all participants – Prevented development of inappropriate “areas of concern” 32 RDIMS/SGDDI

Pitfalls in Advance of an Audit 1. 2. Not using all the resources available to understand prepare for an audit. - ICAO web, ICAO team leader, State auditing expertise Allowing communication barriers - Ensure staff have clear roles that are understood in the program - Test the process for understanding and effectiveness 33 RDIMS/SGDDI

Pitfalls in Advance of an Audit Contin’d 3. Unprepared interviewees • Provide training on process and expected attitude – Interviewees to understand the limit of their responsibility to answer questions – Don’t assume interviewees have knowledge of the process • Prepare in advance, formal responses to the protocol questions and be prepared with supporting reference documentation • Address apparent regulatory or organizational protocol issues with the time remaining before the actual audit 34 RDIMS/SGDDI

Potential Pitfalls During an Audit 1. Misunderstandings – ICAO understanding of state organization impacts their protocol management and accuracy of concerns – State members must understand the limits of their interview responsibilities – Purpose of industry visits 35 RDIMS/SGDDI

Potential Pitfalls During an Audit Contin’d 2. Giving too much information. 2. 3. Not using the “Daily Debrief” system, 2. 4. Know when to stop and how to focus the material to the key point that will be understood the feedback pulse for the audit Accepting General Findings based on limited interviews 36 RDIMS/SGDDI

Summary 1. 2. 3. 4. 5. Strong coordinator essential Send coordinator on ICAO training Select knowledgeable Branch coordinators Short and direct answers to questions Establish good communications with ICAO team leader 6. Prepare interviewees including industry 37 RDIMS/SGDDI

Summary (continued) 7. Insist on daily debriefs 8. Escort auditors everywhere 9. Plan to have staff available at all times during the audit including weekends and late at night 10. Work with Auditors to ensure “Areas of Concern” accurately reflect program 38 RDIMS/SGDDI

Questions? 39 RDIMS/SGDDI