Originally appeared in the 2013 1st quarter edition of Aviation Business Journal
By Lindsey C. McFarren
In November 2012, the first audit was conducted in accordance with the NATA Safety 1st Ground Audit Standard. I was lucky enough to observe the audit and will share my experiences with you below. The Aviation Business Journal published an article introducing the audit in the first quarter of 2012, but here’s a quick refresher on the program.
NATA Safety 1st established the NATA Safety 1st Ground Audit Standard to promote industry best practices and Safety Management Systems (SMS) development among ground handling providers. This audit standard is the first published audit for FBOs and other ground handling service providers. The NATA Safety and Security Committee, which includes representatives from large and small FBOs, on-demand charter operators, fractional program managers, insurance brokers, fuel companies, and more, assisted in drafting this important new audit standard.
The NATA Safety 1st Ground Audit Standard’s two primary objectives are: to create a consistent operational safety standard for FBOs, airports, and other facilities, while increasing the overall safety level of these operations, and to provide FBO or other ground handling facilities customers with an alternative to costly proprietary audits of these operations.
How It Works
NATA Safety 1st manages the audit standard but does not actually conduct audits. This audit allows for two levels of certification: self-certification, whereby the FBO has a qualified employee, trained by NATA Safety 1st, to conduct internal audits, and third-party certification, in which the FBO contracts with an NATA Safety 1st-trained auditor to conduct the audit. A self-certification audit must be completed within a specified time period. NATA Safety 1st must be advised of the start and end dates of the self-certification audit. The audit I observed was a third-party audit.
After either type of audit has been completed, the facility has 120 days to review the findings and implement any corrective actions. If the facility successfully closes all findings, it will be listed on the NATA Safety 1st registry of audited facilities. This registry will be available online at no charge to aircraft operators and other consumers to verify the successful completion of the audit.
NATA Safety 1st maintains oversight of the audit by reviewing each audit report, including corrective actions, upon completion.
What Does the Audit Cover?
The audit covers seven separate operating areas within an FBO, ranging from the company’s management system to environmental policies and procedures.
- Management System – Section 1 evaluates the management policies and procedures of the organization.
- Safety Management System and Quality Assurance – Section 2 evaluates the facility’s safety program, emergency response procedures, and quality assurance procedures.
- Training – Section 3 evaluates the training programs (i.e. general training, hazardous materials training, vehicle and equipment training, security training, and more) of the facility.
- Standard Operating Procedures – Section 4 reviews the standard operating procedures of the facility to ensure they are properly document and executed. This includes aircraft marshaling, taxiing, fueling/defueling, deicing, and more.
- Security – Section 5 reviews the security policies and procedures of the facility.
- Occupational Safety and Health – Section 6 reviews the facility’s occupational safety and health policies and procedures to ensure the facility is in compliance with state requirements. (Note: This is not a full OSHA audit.)
- Environmental – Section 7 reviews the facility’s environmental policies and procedures, including storm water pollution prevention, hazardous materials handling, and underground storage tank requirements.
First Audit: Lessons Learned
The on-site portion of the audit was conducted at one base of an FBO with a few locations. The FBO is not notably different in size, shape, or make up from any other FBO in the country. It is not a part of one of the large chains nor is it a “mom-and-pop” organization. It is a happy medium in terms of fuel sales, daily operations, and so on. Because this audit was the first “real” one of its type, the auditor was conservative in timing and allotted two and a half days to conduct the on-site portion of the audit. The company is currently in their 120-day window to review and correct findings so I will not disclose the company’s name or location at this time.
However, a number of lessons can be gleaned from the initial audit.
Lesson 1: Document everything! The NATA Safety 1st Ground Audit Standard requires an FBO to say what they do and do what they say; in other words, every standard must be met with written, implemented policies, processes and procedures. In this particular facility, high turnover is an unfortunate, but not uncommon, concern. Written policies and procedures can help ensure that new personnel perform to your standards and existing personnel continue to perform in a consistent manner. Be sure your company’s policies and procedures are well-documented.
Lesson 2: The goal is to exceed requirements. For this audit, line operations and safety training are particularly important. Many of the ground handling training programs – including the NATA Safety 1st program – available to FBOs only require training every 24 months. This facility has fully implemented the NATA Safety 1st program and meets the 24 month requirement. However, the Ground Audit Standard requires training every 12 months in most cases. There is no need to make this requirement too difficult though. Continue to use the training program you currently use. Just write a policy in your manuals that every applicable employee will complete recurrent training every year and set a schedule to be sure that training is in fact completed. This could be the entire PLST program or an overview of selected modules. (Note: The NATA Safety 1st PLST is not the only formal training acceptable for this audit – it is just one method of meeting the training standards and happened to be the program used at this location.)
Lesson 3: Be prepared. Electing to complete this audit is a commitment. Certain resources are necessary to perform the audit. If you intend to commit employees to the process only for the few days an auditor is onsite, frankly, do not waste your time. You will need to spend some time getting prepared for the audit. It might be in your best interest to review the checklist several weeks or months prior to the audit to gauge how you think your facility will perform and to close some gaps in your operation prior to securing an auditor and setting a date for the audit. Once you have chosen an audit date, complete the pre-audit checklist thoroughly. List the manual in which each standard is addressed along with the appropriate page number or other identifying details. Not only might this lessen the auditor’s time at your facility, but also it provides the auditor with more opportunity to observe your operations instead of being buried in manuals for days.
Lesson 4: Be realistic. This goes back to lesson 3. If you have prepared appropriately, you will not be especially surprised by most of the findings the auditor discovers. Similarly, do not set unrealistic expectations for yourself (or your staff!) in closing audit findings. This audit is a totally new ballgame for many FBOs, and you might be surprised by the overall number of findings. This is not an assessment of you or your team’s abilities or dedication to your work. It is a process intended to make your operations safer and more efficient.
Lesson 5: Address safety issues quickly. If an auditor points out an unmarked cabinet containing flammables or a lineman smoking within 50 feet of an airplane being refueled, do not wait until you receive the audit findings before you address those issues. There is no time like the present to address a safety concern.
Bragging Rights: A.K.A. Why Perform an Audit?
I could say the benefit of doing an audit like this one is to evaluate your facility objectively to become a safer operation ultimately. Certainly that is one great reason to consider doing any audit. But there is also a business case for conducting an audit such as this. An audit that focuses on safety and quality can help identify a safety risk before an accident or incident occurs. It can also help reveal inefficiencies in your operations, allowing you to tighten your procedures and become more efficient and effective.
Another reason to undergo an audit such as this is to lower insurance premiums or at least slow the rate of increase in premiums. Contact your insurance broker. Would the broker help subsidize the audit or provide resources to help you prepare? Could a third-party safety and operations audit lower your insurance premiums?
Pursuing this type of audit could keep your customers (and airport) happy. Part 135 air carriers eventually will be required by the FAA to implement a Safety Management System (SMS) within their operation. Some airports will be required to implement an SMS soon. There will be a trickle-down effect when SMS is required of air charter operators and these airports. Part of a complete SMS is the oversight of service providers, and FBOs should expect oversight from air charter operators to increase as SMS implementation progresses. FBOs, based at designated airports, will be required to comply with SMS regulations because they operate on the airport’s ramp.
However, FBOs are not in business for the express reasons of being safe, efficient, or making customers happy. Cleary if you accomplish none of these goals, you probably will not be in a business long. But one other, more important thing keeps your doors open and your staff employed: revenue. With any luck, PROFIT! You could be the safest, most efficient, most customer-centric company on the planet but if you do it without making money you will not be around long. Completing an audit like the NATA Safety 1st Ground Audit Standard, especially while it is in its infancy, can set you apart from your competitors. If you have only one other competitor on the field and you have completed this audit but they are known for both cheap fuel and hangar rash, where do you think most customers will go? There will always be aircraft operators who would sell their first born to save two cents a gallon, but as SMS and risk management concepts become more prolific with corporate and charter operators, expect more customers to choose the lower risk – if slightly higher cost – FBO.
Stay tuned for more information on the NATA Safety 1st Ground Audit Standard. Several auditors have been trained and are available to conduct the audit. Visit http://www.nata.aero/Safety-1st/Ground-Audit.aspx for more information.