The Canadian USOAP Experience. RDIMS/SGDDI 2 The Canadian USOAP Experience Aim: to share Canadian...

The Canadian USOAP Experience

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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

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Overview of the ICAO audit process

Program Objective (Assembly Resolution A35-6)

Assess State’s implementation of:- Safety oversight, and- Standards and Recommended Practices, associated

procedures and guidance material

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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

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Foundation Documents

o      

• Rules of Conduct-Memorandum of Understanding

• Audit documentation•Pre-audit tools

- State Aviation Activity Questionnaire- Compliance Checklist

•Protocol Checklists - On site interview questions

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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

Foundation Documents cont’d

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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

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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.

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Documentation toolsPreaudit

•State Aviation Activity Questionnaire

•Compliance Checklists

- Forms are available on ICAO web site

Foundation Documents cont’d

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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

Foundation Documents cont’d

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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

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Protocol ChecklistsFoundation Documents cont’d

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

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Guidance SourcesICAO 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

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Audit timeline - On site activityEntry 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

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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.

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Audit Timeline - Post AuditC

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Canadian Preparation for the Audit

-Coordination-Communications

-Arrangements for daily debriefs-Training for State interviewees

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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

Application of ICAO process in The Pre-Audit phase Cont’d

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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

Scope for Canadian auditing initiatives contin’d

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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”

Application of ICAO process in

The Pre-Audit phase Cont’d

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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.

Scope for Canadian auditing initiatives contin’d

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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

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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

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Page from ICAO Work Planfor OPS Specialist

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A Description of ICAO’s Audit Plan

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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

The Interview Process Contin’d

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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”

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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

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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?

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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

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Lessons Learned1. 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

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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”

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Pitfalls in Advance of an Audit

1. Not using all the resources available to understand and prepare for an audit.

- ICAO web, ICAO team leader, State auditing expertise

2. Allowing communication barriers

- Ensure staff have clear roles that are understood in the program

- Test the process for understanding and effectiveness

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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

Pitfalls in Advance of an Audit Contin’d

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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

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Potential Pitfalls During an Audit Contin’d

2. Giving too much information. 2. Know when to stop and how to focus the material to the key

point that will be understood

3. Not using the “Daily Debrief” system, 2. the feedback pulse for the audit

4. Accepting General Findings based on limited interviews

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Summary

1. Strong coordinator essential

2. Send coordinator on ICAO training

3. Select knowledgeable Branch coordinators

4. Short and direct answers to questions

5. Establish good communications with ICAO team leader

6. Prepare interviewees including industry

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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

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Questions?