The document explains the changes required by the CAA as part of the resolution (A35-6) adopted by the International Civil Aviation Organisation (ICAO). The Universal Safety Oversight Audit Programme (USOAP) will be conducted by ICAO using a system based approach moving away from the annex-by-annex approach. The document recommends the strategies that have to be followed to develop a system based regulatory successfully thus complying with the resolution.
International civil aviation remains the safest mode of mass transportation, and one of the safest production systems in the history of industrial systems. Levels of safety have been achieved that bring increased pressure on aviation and its organizations to sustain and improve such levels. This dictates the imperative for new approaches to the management of safety, as well as for a review of the processes aviation organizations must develop to implement such new approaches to improve the high levels of safety achieved by international civil aviation. Under the systems approach, the ICAO USOAP employs essentially compliance-based audits and tools that assess the health of contracting states systems and assures that they effectively control and manage risk.
The systems approach to ICAO USOAP refers to the implementation of a structured process and methodology for the planning, preparation, conduct, reporting, follow-up and evaluation of ICAO safety oversight audits. The basic tenet of a systems approach is the recognition that the parts of a system are subject to containing or contributing to error. A system audit, in examining and obtaining a picture of the system as a whole rather than auditing specific part is more likely to detect any deficiencies and provide guidance in reducing or eliminating them. (ICAO Presentation, n.d., p. 16).
The entire process, from initial planning and scheduling of an audit to the publication of a final safety oversight report takes approximately two years to complete.
Project Summary and Scope
The objective of USOAP is to promote global aviation safety through auditing Contracting States, on a regular basis, to determine States' capability for safety oversight by assessing the effective implementation of the critical elements of a safety oversight system and the status of States' implementation of safety-related ICAO Standards and Recommended Practices (SARPs), associated procedures, guidance material and safety-related practices. (Rallo, 2008, p. 9)
USOAP's initial method was an annex by annex approach of auditing of compliance against a limited set of criteria, which may sometimes result in a less than comprehensive view of a State's level of overall safety. ICAO's has now adopted a resolution (A35-6) stating that they would move towards a system based approach for conducting the audits.
Hence, it is necessary that the Civil Aviation Authority (CAA) of India develop a systems based regulatory framework to comply with ICAO's resolution.
Benefits of the systems approach
Enables the assessment of the effective implementation of the critical elements of a safety oversight system.
Evaluates the overall aviation safety system established by the State. Aviation activities are interrelated. A problem in one area affects the whole system.
Overall, it will significantly contribute to the safety and efficiency of the international air transport system.
ICAO has designed audit tools to collect useful information on the organisation and system established by the State. These are used throughout the three phases of the audit process for conducting a comprehensive systems approach-based safety oversight audit, from the initial planning stage to the publication of the final audit report. The main audit tools include:
State Aviation Activities Questionnaire (SAAQ).
Compliance Checklists (CCs)
Safety Oversight Audit Manual - Audit Protocols, and
SOA Quality Manual.
All Contracting States are required to complete the SAAQ and submit it to ICAO for proper evaluation and recording. The submitted information enables ICAO to maintain an up-to-date database on the State's activities. As a result, the State will have a clear picture of the implementation status of the relevant SARPs.
The comprehensive systems approach for the conduct of safety oversight audits consists of three phases. (ICAO, n.d., para. 9)
In the first phase, the level of implementation of Annex provisions is assessed and differences from ICAO SARPs are identified for the State through a review of a duly completed State Aviation Activity Questionnaire (SAAQ) and Compliance Checklists (CCs) for all safety-related Annexes, as well as through a review of documents developed by the State to assist it in implementing SARPs and in maintaining an effective safety oversight system.
In the second phase, the State will be visited by an ICAO audit team to validate the information provided by the State and to conduct an on-site audit of the State's overall capability for safety oversight.
The third phase of the audit process consists of the activities following the completion of the on-site audit. It will include closing the findings and recommendations contained in the final report.
Appointment of a National Safety Oversight Coordinator
The scope of safety oversight audits during the initial audit cycle was limited to Annexes 1, 6 and 8. This meant that ICAO, for the most part, only had to deal with one State entity, namely the Civil Aviation Authority. The scope of safety oversight audits under the comprehensive systems approach has expanded to 16 of the 18 Annexes to the Convention. As a result, ICAO has to deal with several entities responsible for safety oversight tasks, besides the CAA. (ICAO Audit Process, n.d., para.1)
To facilitate the audit process, and to ensure proper communication and coordination with Contracting States, the Safety Oversight Audit Section (SOA) has requested all States to appoint a National Safety Oversight Coordinator (NOSC). The NSOC serves as focal point between the Safety Oversight Audit Section (SOA) and the State concerning safety oversight matters. The NSOC has to play an active role during the three phases of the audit process.
Indeed, from CAA's perspective, a smooth transition is the most important aspect of this project for maintaining stability and integrity to comply with ICAO's mandate. A key component of the overall transition project is to effectively manage these changes and ensure their efficient incorporation into the daily CAA work environment.
In accordance with Assembly Resolution A35-6, safety oversight audit reports have to be restructured to reflect the critical elements of a safety oversight system. This is presented in ICAO Doc 9734, Safety Oversight Manual, Part A - The Establishment and Management of a State's Safety Oversight System. Please refer Appendices for more detail..
The CAA has to progressively implement system based safety auditing across all sectors of the aviation industry of the State. Our approach to safety surveillance should combine the use of systemically based regular scheduled audits that incorporate adequate processes, management, quality assurance systems, and risk based audits that are conducted on an ad hoc basis.
These changes include improving the effectiveness of certification and surveillance processes, and implementing enhancements to various technology support infrastructure. Successful adoption and institutionalization of the program depends on total workforce involvement. To reach the stakeholders, the Project Office should create an Outreach Team. This should have personnel representing all regions, a multitude of disciplines, and a range of positions and offices. The provision of procedures and guidelines, adequate facilities and equipment, and safety critical information to the technical personnel will enable them to perform their safety oversight functions; this includes the provision of technical guidance to the aviation industry on the implementation of regulations and instructions.
The main aim is to comply with the regulations set by ICAO. The main factors can be summarised:
Implementation of the new systems based regulatory framework
Maintaining safety regulations
Providing strategic alignment
Maintaining a corporate reputation
Maintaining ICAO Regulatory agency relations
Appointing a National Safety Oversight Coordinator, and
Training the large and geographically dispersed sectors on the new processes and tools.
The strategies and processes mentioned below will ensure successful project implementation. The project goals should be aligned with the organisational goals, the goals of other sub-units of the organisation and with individual goals. This will lay the foundation for a successful transition.
Project Management Office Involvement
The implementation will require different levels of cooperation with the other aviation-related organizations. Therefore all communications should be through the Project Management Office (PMO). An effective communications plan is critical to the overall success of the project, when many of the stakeholders will experience a change to their environments. Communication should focus on educating the stakeholders on what has been mandated by the ICAO.
The PMO should also support the project manager in creation of plans, schedules, budgets and staffing. Kerzner (2009, p.169) mentions the responsibilities of the PMO, which are to:
Act as the focal point of information for both in-house control and ICAO reporting.
Ensures that all the work required is documented and distributed to all key stakeholders.
Ensures that all the work performed is both authorized and funded by contractual documentation.
Mentor the project manager.
The PMO should appoint the National Safety Oversight Coordinator (NSOC) in consultation with the senior management. The PMO should identify all the stakeholders involved. This will include Air operators, aircraft maintenance organizations, the flight standards training division, and other aviation-related organisations of the State. An Outreach Team made of personnel representing the different regions and sectors will help facilitate the communication.
Selection of the Project Manager
The strategy should start off with the selection of a project manager capable to handle the transition. The manager should be well versed with the functions of project management and have sound experience in managing large projects. The manager must display "a balance of technical, interpersonal, and conceptual skills that help him analyze situations, evaluate the risk and work with other experts in designing a strategy to reduce or eliminate the risk". (Cleland and Ireland, 2006, p 395)
The project manager will be responsible for:
Developing and maintaining the transition project plan as well as managing the overall execution of the project in a timely manner.
Identifying the requirements and overlap in the project and planning for the implementation of the project using the project management strategies detailed in this report.
Reconciling all stages throughout the transition.
Implementing a clear communications strategy.
Providing comprehensive status and evaluation of the project on a timely basis to the senior management and the Project Office.
Monitoring the project expenditure as the project passes through the various phases.
The project manager should work closely with the NSOC (National Safety Oversight Coordinator). They should play an active role during the three phases of the audit process: pre-audit, on-site and post-audit phase.
Systems Approach to Project Management
The systems based approach to project planning, scheduling and controlling will ensure that implementation is on-time, on budget, and well-communicated. "The systems approach is a logical and disciplined process that systematically assembles and integrates all activities into a meaningful total system" (Kerzner, 2009, p. 83)
The systems approach (Kerzner, 2009, p. 83):
Forces review of the relationship of the various subsystems
Is a dynamic process that integrates all activities into a meaningful total system
Seeks an optimal solution or strategy in solving a problem
The transitional project should move through a set of project life cycle phases. This will define the beginning and end of the project. Kerzner (2009, p. 68) says that "A clear understanding of the life-cycle phases permits managers and executives to better control resources to achieve goals".
All major events and dates must be clearly identified. The exact sequence of work should be defined through a network in which interrelationships between events can be identified.
The project life cycle should consist of four major phases: Project Definition, Project Planning, Project Execution & Control, and Project Closeout. The in-house developed industry recognized documents, checklists and templates needed to support the project management process are available with the Project Management Office. These can be tailored to meet the needs of the transition project if necessary.
Before effectively managing a project, there needs to be a shared understanding of the project - its purpose, scope, sponsors, stakeholders etc. Verzuh (2003, p.10) states that project definition is "a very important phase of project management and is the foundation for success as it establishes a common understanding of the goals and constraints of the project." Therefore, all the stakeholders on the project have to be identified and their goals and involvement are to be properly documented in the Project Charter.
Planning is fundamental to the success of the project. Kerzner (2009, p. 449) says "Executives should interface with project and line personnel during the planning stage in order to define the requirements and establish reasonable deadlines".
Project Planning should involve a sequence of steps and should have the following (Kerzner, 2009, p. 464):
Project Plan and Schedule development
The information obtained and created during the project definition phase should be recorded using a Statement of Work (SOW) by the PMO and project manager. Kerzner (2009, p. 425) defines SOW as "a narrative description of the work to be accomplished". It should record the goals and constraints of the transition project including scope, budget and key milestones.
A detailed work breakdown structure (WBS) should be developed that will break the overall work into manageable sub-divisions. Schedules should directly relate to the work breakdown structure and must identify time constraints. This will help in better estimation of resources and an accurate cost estimate. Detailed schedules are to be prepared for each sub process of the project. Kerzner (2009, p. 464) emphasises that "The PMO should combine all the detailed schedules into one master schedule to verify that all activities can be completed as planned". This has to be done in consultation with the functional program team members who are more technically sound on the subject matter.
A detailed and thorough Project Plan highlighting the transition should be developed. This should serve as a guideline for the lifetime of the project and may be revisited as often as possible. The development of the Project Plan can be time-consuming and all levels of the organisation should participate. It should elaborate the management section as well as have a detailed technical section. This should act as the standard communication tool through all life cycles of the project and should be linked with the WBS. The plan can help in identifying any inconsistencies in the planning phase.
"The agreement on this information by the key stakeholders is an important 'gate' through which the project should pass" accentuates Gardiner (2006, p. 29). This will avoid any conflict with functional managers as everyone knows about their clear-cut role.
The budgeting approach to be followed will be a bottom-up approach. This will ensure the accurate preparation of the budget as this will be prepared in consultation with the experts who have the necessary data and knowledge. The project manager is to prepare a budget proposal that supports efficient and on-schedule project execution with the support of the PMO and functional managers.
It is important that the resource requirements and skill set required are determined here so that conflicts do not arise later. Sufficient resources, in the form of people, skills and equipment are to be provided for the development and implementation of all aspects of the project.
Planning must include agreement on purpose acceptance of individual responsibilities. Responsibility Assignment Matrix (RAM) should contain the participants and to what degree an activity will be performed or a decision will be made. Kerzner (2009, p. 200) says that "The RAM attempts to clarify the authority relationships that can exist when functional units share common work".
Project Execution and Control
The project manager should constantly track the plan throughout the execution phase. The project monitoring and control processes should be established to ensure that high performance standards are maintained. Schedule slippages and cost overrun can be controlled through strong performance monitoring.
At project close-out, the lessons learned from the project should be captured and documented so that they can be passed on to the organisation. (Verzuh, 2003, p. 12)
Integration of Processes
Kerzner (2009, p. 74) believes that good methodologies integrate other processes into the project management methodology. The project management methodology to be used should be an integrated system made of the processes mentioned below.
When quality management is considered as a part of the other management approaches, it assists the project manager in measuring the standard of activities, processes, and final output. Gardiner (2006, p. 197) verbalises this saying "Quality management is about managing the quality of the products, services and processes associated with the project".
The quality policy of the organisation should be adopted for use by the project. A detailed quality management plan should be prepared in parallel with other planning processes that describes how the project management team will implement its quality policy. It should also address quality control, quality assurance and quality improvement for the project. The Quality Assurance Department of the organisation should assign personnel to be actively engaged in this project. They should plan monthly quality audits and report any non-compliance.
Effective quality management will ensure an improvement in quality, avoid rework and provide ample documentation for project records. Moreover it allows immediate corrective or preventive action as a result of quality control measurements. (PMBOKÂ®)
Risk pervades all aspects of a transition project. Risk Management is the systematic process of identifying and responding to the risk of the project without any impact on the project's objectives.
Risk analyses and contingent plans help to address all aspects of the project viz. financial, schedule and quality. Therefore, Risk Management should be established early in the project and should be alive during all phases of the project. Communication and consultation with the internal and external stakeholders is necessary for the effective Risk management process. A risk management plan should be established to address areas of identified risk with the goal of achieving agreed safety objectives and targets.Â
A certain amount of change is a normal part of project management, but it should be carefully managed. Changes can be from within the project team or the client or even from an external third-party source. Gardiner (2006, p. 286) says that "Projects do not fail because of change but because of lack of clear, consistent direction and leadership when confronted with challenges of change".
Hence, during the project planning phase a change management plan should be developed. Early identification of change and its effect on the project plan will help to minimise risk and maximise value. The changes should be documented and communicated to all stakeholders.
Safety Management Systems (SMS)
The systems approach to auditing should be complemented by the implementation of Safety Management System (SMS). The industry faces unique safety challenges that are unlike those faced by any other facet of transportation and must therefore put appropriate systems in place to address this. The term "safety management" itself conveys the notion that managing safety is a managerial process that must be considered at the same level and along the same lines as any other managerial processes systems such as the quality management system and risk management system.
The International Civil Aviation Organization (ICAO) defines Safety Management Systems (SMS) as: "a systemic approach to managing safety, including the necessary organizational structures, accountabilities, policies, and procedures (ICAO doc. 9859, Safety Management Manual)." This is a relatively new requirement for airline operators to have a Safety Management System which has a systems approach to safety. The CAA should mandate the establishment of Aviation Safety Departments in their respective organisations by the aviation stakeholders of the State to oversee the implementation of a SMS.
A Safety Management System must:
Identify safety hazards.
Ensure that remedial action necessary to maintain an acceptable level of safety is implemented.
Provide for continuous monitoring and regular assessment of the safety level achieved.
Aim to be a continuous improvement process.
Note. - Guidance on safety management systems is contained in the ICAO Safety Management Manual (Doc 9859).
This is to ensure that business process changes are facilitated by the transfer of knowledge, skills, tools, processes, systems, and methods for all stakeholders involved in the changes. The strategies should include the initial evaluation of the updated USOAP procedures and transition processes to be conducted at all key sites. This evaluation will allow the assessment of training, communications outreach, and management support required to enable the incorporation of necessary enhancements or improvements prior to the roll-out of the full systems based regulatory framework. This will ensure the smoothest transition during this critical period for all the stakeholders.
Training Policy and Programme
The objective is the institution of a regional training policy, together with the development and establishment of a regional training programme, in order to provide the technical personnel of the Aviation Organisations of the State with specialized training courses and seminars/workshops. The aim of such a policy would be the preparation and implementation of the comprehensive systems approach.(Safety Oversight Manual, p.40)
ICAO may provide advice or propose the most appropriate course of action for required activities that the state's regional safety oversight system is not able to implement or is facing problems with. (Safety Oversight Manual, p.22)
The analysts are predicting that domestic traffic in the State can reach 160-180 million and international traffic in excess of 50 million by 2020. With such a predicted growth, we have a challenge in creating a safe, secure, efficient and environment friendly system conducive to meet the growth. All the efforts and recommendations of USOAP seek to achieve improved implementation of Standards and Recommended Practices (SARPs) and promote uniformity of international aviation practices. With apt safety oversight by approaching safety auditing from a systems perspective, the State can ensure that its national aviation industry meets or exceeds the safety levels established by the ICAO. In addition, obtaining consistent and standard data and analyzing information at the national level is a great asset to the CAA. The project hence has to be given high priority and has to be completed in the timelines recommend in the report and it can be successfully managed to completion by utilising the strategies and methodologies recommended in this report.
This is a high risk project that requires meticulous planning and cooperation amongst the aviation sectors of the State. A critical success factor for the transitional project is a well-defined governance model that provides the appropriate level of control during the transition period. Thom, W. (2009, para. 3) says that "If projects exist without a project management process to reference, though they can be successful, often times these projects are managed in chaos". Therefore, for a successful transition, CAA's approach to transition and transformation should follow the project management methodologies complemented by quality, risk, change and safety management processes outlined in this report to design and implement the transition successfully.
There should be enough qualified experts available for the State to fulfil the safety oversight responsibilities. They may be provided necessary training from experts from ICAO so that the tools and processes can be integrated into the Aviation Safety - wide enterprise management.
The transition has to be completed by March 2011 so that CAA can schedule the audit process with ICAO and aim for completion before end of 2012. This will ensure that national aviation industry meets the safety levels established by the ICAO and maintain the corporate reputation.
It is recommended that sufficient time be taken to set the baseline plan to ensure that the processes, tools, technology etc are designed to facilitate the integration of processes into the nation-wide aviation organisations. This should be completed and implementation plan communicated in two months. The implementation should begin soon after planning and be completed by March 2011.
The CAA should perform regulatory audits to monitor the progress of the implementation of the transition by the stakeholders in this project which includes all organisations of the State that are regulated by the CAA.