Ipm P&G E11th
Ipm P&G E11th
Ipm P&G E11th
IOSA Audit
Handbook
Edition 11
PROCEDURES AND GUIDANCE
Audit Organizations and Airlines
NOTICE
DISCLAIMER. The information contained in this
publication is subject to constant review in the
light of changing government requirements and
regulations. No subscriber or other reader should
act on the basis of any such information without
referring to applicable laws and regulations and/
or without taking appropriate professional advice.
Although every effort has been made to ensure
accuracy, the International Air Transport Associ-
ation shall not be held responsible for any loss or
damage caused by errors, omissions, misprints
or misinterpretation of the contents hereof. Fur-
thermore, the International Air Transport Asso-
ciation expressly disclaims any and all liability to
any person or entity, whether a purchaser of this
publication or not, in respect of anything done
or omitted, and the consequences of anything
done or omitted, by any such person or entity
in reliance on the contents of this publication.
Revision Highlights
Reference Change Comments
All/General The sentence structure and the wording are revised for clarity throughout the
manual.
Introduction 4. IAH P&G and IAH Tables & MOs are included in the list of documents auditor should
para 5 keep up to date with.
1.2 AO and ETO Quality Performance Manual are added to the IOSA documentation
system.
1.4 IOSA Audit Software Auditee Manual is referred.
2.1.1 IATA pre-audit questionnaire is added to the additional planning items.
2.1.3 New paragraph is added to clarify procedures for identifying trainees in the Audit
Build.
2.2.1 Note regarding the program experience on auditing EGPWS, ACARS, ELT etc. is
deleted.
2.2.1 IPM MO exemption policy is referred to.
2.2.1 Review of the IATA pre-audit questionnaire is added to audit preparation tasks.
2.3.2 MO-5-MNT Line Maintenance is introduced to replace MO-5-MNT Maintenance
Outsourcing Management as of 1 September 2020.
2.6.2 Alternative internal oversight methodologies are included in compliance with ISM 14
ORG 3.4.6 changes.
2.6.3 Role of the AO during audits subsection is deleted.
2.6.4 CR references are deleted.
2.7.2 Recording the auditor actions in the audit software are not required anymore with
this paragraph.
2.9.4 Basic root cause and root cause analysis descriptions are added.
2.9.4 Root cause analysis methodologies 5 Whys and Fishbone Diagram are added with
their advantages, limitations and examples.
2.9.4 Best practices to be considered for root cause analysis are added.
2.9.4 Predefined root cause categories and their descriptions are added.
2.9.7 Final Action Taken is not required to be written anymore in the Audit Software by the
auditee.
2.9.7 Auditee responsibilities on uploading relevant evidences in the attachement section
of the Audit Software are added.
2.9.8 AO's responsibility to review FAT evidences is clarified.
2.9.11 Procedures for CARs raised in error are revised to clarify the scenarios to be used.
3.3.4 Figure 3.1 ISM Applicability for Internal Assessments are deleted.
3.3.4 Procedures to be followed when an ISM TR is issued are added. Alternative internal
oversight methodologies are included in compliance with ISM 14 ORG 3.4.6
changes.
3.3.5 Alternative internal oversight methodologies are included in compliance with ISM 14
ORG 3.4.6 changes.
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iv IOSA AUDIT HANDBOOK 11th EDITION, MARCH 2021
TABLE OF CONTENTS
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2 Applicability
This handbook is applicable to Audit Organizations (AOs) and all IOSA eligible operators in support of
the IOSA Program. The purpose of this handbook is to provide processes, procedures, methodology
and guidance for:
1. AOs and associated IOSA auditors in the conduct of IOSA Audits, reference IPM section 8;
2. Operators and associated internal auditors, in the conduct of internal IOSA Audits; and
3. Operators in the preparation for the IOSA Audit, reference IPM section 6.
This handbook covers pre-audit, on-site and follow up audit activities for the AOs and operators,
including the production of the:
1. IOSA Audit Report by the AOs; and
2. Conformance Report by the operators.
While this handbook provides procedural information of specific IOSA Program options, the source
information and program rules are available in the IOSA Program Manual (IPM).
Most of the procedures and guidance in this handbook are specific to the IOSA audit model and are in
regular use by the IOSA AOs. However, it is recognized that many operators have established
procedures in place for the conduct of internal audit processes. The information in this handbook is
therefore not intended to replace procedures currently being used by operators, but is available to the
operators' internal auditors who wish to integrate the audit methodology developed for IOSA and
currently being used by the AOs.
3 Handbook Description
The IAH P&G is designed to be used as an electronic source of information, accessing information by
means of hyperlinks.
The handbook is divided into five sections:
1. IOSA Program Overview, which covers general introduction information about the IOSA Program.
2. Audit Procedures for Audit Organizations, outlines the procedures used by the IOSA auditor to
conduct the pre-audit, on-site and follow up activities, and produce the audit report. Generally this
section contains information that may need to be referenced by the IOSA auditors to perform their
duties.
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IOSA Audit Handbook
3. Operator Audit Procedures for operators, outlines the procedures used by operator to prepare
for the IOSA audit and conduct the internal audits and follow up activities, and produce the
Conformance Report. Information is provided to support or supplement the operator's quality
assurance processes and procedures. Generally this section contains information that may need to
be referenced by the internal auditor and the operator to perform the duties under their IOSA
responsibilities.
4. Audit Methodology and Technique, contains guidance material and audit concepts and
methodology, which every IOSA and internal auditor should know through auditor training and is
not generally required to be quick referenced by the auditor in the conduct of their duties.
5. Program Options, outlines how the AOs and operators must utilize the options built into the audit
program, where applicable.
5 Handbook Revision
Unless otherwise specified, new editions of the IAH usually become effective 30 days after issue and
are applicable to audits conducted on or after the effective date. If an amendment is needed urgently to
address specific operational conditions, a Temporary Revision (TR) would be issued and the effectivity
period may be less than 30 days or immediate.
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xiv IOSA AUDIT HANDBOOK 11th EDITION, MARCH 2021
Introduction
For the purpose of IOSA, the IAH that was effective at the time of Opening meeting shall be applicable.
New editions are issued in PDF and contain ‘Revision Highlights’ as a description of changes. The
month of publication is displayed in the footer of each page.
6 Conflicting Information
This handbook and other IOSA documentation are not revised and published concurrently, thus
creating the possibility of conflicting information in different manuals and/or handbook.
If there are inconsistencies between the IOSA documentation, namely the ISM, IPM and IAHs, IATA
should be contacted for clarification and correction.
If there are inconsistencies between the IPM (and related content in the IAHs) and the Audit
Agreement, in accordance to IPM 8.2.2, the Audit Agreement shall prevail.
7 Modification Status
All changes in this document are listed in the revision highlights table. For readability, the following
symbols identify any changes made within each section:
10 Distribution
Electronic distribution only, via public website: www.iata.org/iosa.
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11 Authority
The IOSA Program operates under the authority of the IATA Operations Committee (OPC) with
reference to the IATA Board of Governors (BoG). This edition of the IAH P&G is approved for use by
the program management.
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xvi IOSA AUDIT HANDBOOK 11th EDITION, MARCH 2021
Section 1 IOSA Program Overview
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IOSA AUDIT HANDBOOK 11th EDITION, MARCH 2021 1
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2 IOSA AUDIT HANDBOOK 11th EDITION, MARCH 2021
IOSA Program Overview
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4 IOSA AUDIT HANDBOOK 11th EDITION, MARCH 2021
Section 2 Procedures for Audit Organizations
Note:
Allow time to arrange the line flight observations in some countries requiring NAA approval for
access to the cockpit.
8 Request the following documents from the Auditee:
(a) completed list of document using the template downloaded from the audit software. The
auditee is not required to fill in the ‘Audit Record No’, ‘Dated Reviewed’ and ‘Question Codes’
column in the template;
(b) Air Operator Certificate, Operations Specifications, or equivalent documents;
(c) IATA pre-audit questionnaire.
(d) Completed Aircraft Systems and Equipment form;
(e) if Active Implementation was utilized in the previous audit or will be used in upcoming audit,
the Active Implementation Record or Implementation Action Plan;
(f) any other documentation required for the auditors to prepare for the audit;
(g) identify at least one CAR administrator from the operator and obtain the Full name and email
address; and
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IOSA Audit Handbook
An operator may choose to undertake an IOSA Preparation Visit (IPV) to assist the operator in
understanding the IOSA Audit process, refer to 5.7.
When there are one or more affiliated operators that share a portion of their operational functions, and
when approved by IATA, one or more of the audits may be of reduced auditor-days due to the shared
function having to be audited only once, refer to procedures in 5.1.
If the audit being planned is a Verification Audit refer to additional information in 5.6.
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Procedures for Audit Organizations
For any changes made on the audit details after the approval from IATA, the user making the changes
shall add comments in the audit software and state the reason of the changes.
After the commencement of the on-site audit, if there is any further changes, the audit organization
and/or the lead auditor shall record those changes (e.g. change of auditor and change of operator's
address, etc.) within the audit software, before the closure of the audit.
Note:
The auditor trainee will not be given any access to the audit software production database. Instead, the
training/test database access will be granted for the training purpose.
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The conduct of the audit must be undertaken in accordance with the IPM, IAH and ISM.
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The following is the list of ISARPs which contain policy requirements and which should be pre-
assessed for documentation:
ORG 1.2.1 ORG 1.2.2 ORG 1.2.3 ORG 1.3.5 ORG 1.6.4 ORG 2.1.5 (i)
ORG 3.7.1 (v) ORG 3.7.4 (v) ORG 3.7.8 (vii) FLT 1.3.9 FLT 1.5.8 FLT 3.4.2
(viii)
FLT 3.4.3B (i) FLT 3.7.1 FLT 3.9.3 FLT 3.10.2 FLT 3.11.3 FLT 3.11.17
This is a pre-assessment completed before the on-site phase of the audit. All pre-assessments must be
verified on-site and corrected if necessary.
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Procedures for Audit Organizations
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IOSA AUDIT HANDBOOK 11th EDITION, MARCH 2021 11
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MO Nr Title Description
MO-1-FLT Line Flight Operations Observation of flight crew activities, procedures, flight
deck systems/equipment; interviews of personnel.
MO-2-FLT Flight Simulator Operations Observation of instructor/flight crew activities, pro-
cedures, simulator systems/equipment; interviews of
personnel.
MO-3-FLT Flight Crew Scheduling Observation/direct examination of flight crew schedul-
Operations ing activities, processes, records; interviews of per-
sonnel.
MO-4-DSP Operational Control/Flight Observation/direct examination of operational control/
Dispatch Operations flight dispatch activities, processes, procedures; inter-
views of personnel.
MO-5-MNT Maintenance Outsourcing Observation/direct examination of outsourcing
(Until 31 Management monitoring/oversight processes, documentation, re-
August 2021) cords; interviews of personnel. Accomplished during
Audits of operators that outsource any aircraft main-
tenance operations (line or base maintenance)
MO-5-MNT Line Maintenance Observation/direct examination of line maintenance
(As of 1 Operations operations and review of use of MEL and assessment
September of the repair status and the physical status of the
2021) aircraft/engine(s)/propeller(s) and their repaired
components as applicable. Such observation includes
direct examination of the aircraft condition, observa-
tion of the facilities, equipment, tools, standard parts &
materials and review of maintenance data & records.
Conditions: The activity observed must be performed
on the operator’s aircraft and include authorized
maintenance personnel and a standard part that must
meet applicable airworthiness standards. The activity
observed should include a scheduled line mainten-
ance task in accordance with Maintenance Program
or non-routine/deferred maintenance
activity.
MO-6-MNT Aircraft Part/Component Observation of an aircraft part/component installation/
Installation/Replacement replacement activity, procedures, parts, resources,
records; interviews of personnel.
Conditions: Activity must be performed on operator's
aircraft and include authorized maintenance person-
nel, appropriate tooling and a part/component that
must meet applicable airworthiness standards.
MO-7-MNT AD/SB Management Direct examination of engineering/planning pro-
cesses, documentation, records; interviews of
personnel.
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Procedures for Audit Organizations
MO Nr Title Description
MO-8-MNT Aircraft Parts/Components Observation/direct examination of parts/component
Management/Handling management/handling facilities, processes, documen-
tation, records; interviews of personnel.
MO-9-CAB Line Cabin Operations Observation of cabin crew activities, procedures,
aircraft cabin systems/equipment; interviews of per-
sonnel. Accomplished during Audits of operators that
conduct passenger flights with cabin crew.
MO-10-GRH Load Control Operations Observation/direct examination of load control activi-
ties, processes, procedures, records; interviews of
personnel.
MO-11-GRH Passenger/Baggage Observation of passenger/baggage handling activi-
Handling Operations ties, procedures, equipment; interviews of personnel.
Accomplished during Audits of operators that conduct
passenger flights.
MO-12-GRH Aircraft Loading Operations Observation of aircraft cargo/baggage loading activi-
ties, procedures, equipment; interviews of personnel.
MO-13-GRH Aircraft Ground Handling Observation of aircraft ground handling activities,
Operations procedures, equipment; interviews of personnel.
MO-14-CGO Cargo Acceptance Observation/direct examination of cargo acceptance
Operations activities, procedures, documentation, records; inter-
views of personnel. Accomplished during Audits of
operators that conduct cargo operations.
MO-15-CGO Cargo Handling Operations Observation of cargo handling activities, procedures,
equipment; interviews of personnel. Accomplished
during Audits of operators that conduct cargo
operations.
MO-16-SEC Passenger/Baggage Observation/direct examination of passenger/
Security baggage security activities, procedures, documen-
tation, records; interviews of personnel. Accomplished
during Audits of operators that conduct passenger
flights.
Certain situations and restrictions might preclude an auditor from conducting some mandatory
observations or parts of mandatory observations. To address some of these situations, the following
rules apply:
(a) MO-1-FLT may be omitted if prohibited by the applicable regulatory authority or if none of the
Operator's aircraft have an appropriate jump seat;
(b) MO-2-FLT may be conducted during a training flight if no appropriate simulator is available;
(c) MO-2-FLT may be omitted, if it must be conducted during a training flight and such observation is
either prohibited by the applicable regulatory authority or none of the Operator's aircraft have an
appropriate jump seat;
(d) MO-9-CAB may be omitted if the Operator does not conduct passenger flights with cabin crew.
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Operator’s Aircraft
● <5,700 kgs, or
Private Operations On a Wet Lease-in Different AOC ● a float, ski, or amphibious
aircraft, or
● Single pilot operation, or
● Single engine aircraft, or
● Piston engine aircraft, or
●
● <5,700 kgs, or Wet Lease-in ● Aircraft under sale, or Aerial Work AD Incorporation Operational
Noncommercial
● a float, ski, or amphibious but on the ● Long term maintenance, or (Non-PAX creates non- Exclusion
operations Non-Cargo)
aircraft, or AOC ● Retired, long term storage, or conformance (such as VFR)
(VIP or
● Single pilot operation, or ● Grounded for complete
Government)
● Single engine aircraft, or registration period
Figure 2.1— Categorisation of Operator's Aircraft
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Notes:
1. The exemption will only be applicable for the specific fleet or aircraft affected by the AD; any
exempt ISARP will still be applicable to other fleet or aircraft being audited.
2. The AD may instruct the operator to remove a particular item of equipment resulting in a
nonconformity, for example in FLT Section 4. However, the operator may still be in compliance with
the State regulations due to the listing of an ICAO difference by the State.
When these conditions occur, approval from IATA must be requested by the operator as soon as it
becomes known, but no later than 14 calendar days prior to the on-site audit as per the procedure
outlined in 2.5.7.
To ensure the IAR is an accurate reflection of the audit conducted and to provide clarity in the fleets
and aircraft that were audited, information must be recorded in the Operational Profile, ‘Fleet(s) and/or
Aircraft Exempted from the Assessment’ as outlined in Figure 2.1.
A letter of assurance is required from the CEO or Accountable Executive, as outlined in Figure 2.1
(refer IPM 7.1.10), stating that a fleet and/or aircraft which is not able to be audited will not be returned
to commercial operations without prior notification to IATA. See IPM 6.2.3.
This letter and the appropriate reference in the Executive Summary (ES) and Operational Profile (OP),
provides a traceable record of verification of the fleets and/or aircraft being exempted.
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Procedures for Audit Organizations
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IOSA AUDIT HANDBOOK 11th EDITION, MARCH 2021 21
IOSA Audit Handbook
Registration 17-Dec-20
T-150 Registration
Audit Date
Date Days Expiry
19 Months 5 Months
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22 IOSA AUDIT HANDBOOK 11th EDITION, MARCH 2021
Procedures for Audit Organizations
When a new edition of the ISM is published, it is the operator's responsibility to identify the provisions
that require assessment or re-assessment. There is no absolute procedure for the identification of
standards or recommended practices that might require auditing or re-auditing. Every operator will
develop its own detailed process for identifying significant changes.
As a minimum, the Operator must review the “Description of Changes” section of a new ISM Edition to
identify the provisions that might need assessment. This might be the case if, for example, a Standard
was changed significantly, or a Standard was added to the ISM. This will result in the assessments for
multiple ISM editions, which is acceptable according to ORG 3.4.6
The final result of these reviews will vary from operator to operator – It may happen that an operator
identified a change to a standard or recommended practice as significant, whereas another operator
did not do so. The AO auditor needs to show some flexibility in allowing the Operator to familiarize with
ISM revisions over a longer period of time.
The following gives a list of examples of changes in the ISM that may require asessment of the
provisions in the new ISM Edition:
• A new ISARP is added.
• A Recommended Practice is upgraded to Standard.
• A significant change is made to the content of an ISARP.
2.6.4 Procedures for the On-Site Verification of the Operator's Internal Audit Against the ISARPs
The on-site portion of the Audit will follow the conventional auditing process, with the addition of
specific activities designed to build confidence that the operator has correctly assessed the ISARPs
during the internal audits. All the steps and procedures described in this chapter are used to verify
whether the Operator has fulfilled its obligation to audit itself against all ISARPs.
The on-site verification of the operator's internal audit against the ISARPs focuses on the training and
qualification of the internal auditors, the verification of the internal assessments, and the integrity of the
QA program of the Operator. A sampling approach, see 4.3.2, is taken by the AO auditors to verify the
integrity of the Operator's results, see Table 2 below.
The AO must evaluate the specific methods and processes used by the internal auditors to audit
against the ISARPs and verify the sampled provisions. There should be a particular focus on the steps
used by the operator to confirm implementation.
Unless required by the operator internal procedures, the operator does not need to record the evidence
that was subject to the internal audits against the ISARPs, however this would be beneficial. Records
confirming the conduct of the Auditor Actions will assist in satisfying the requirement.
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1. Information to be verified
The AO auditors need to verify that all information required by Table 1.2 is recorded. This includes the
following items:
(a) All provisions are assessed;
(b) All relevant fields: documentation references, conformance status, etc..., are completed and in
English language;
(c) Details of all non-conformities, assessments, evidence listed, corrective actions, etc ..., are
complete;
(d) Reasons are provided for all N/A assessments;
(e) Internal auditors are listed;
(f) Audited sections were conducted by a qualified internal auditor on the internal auditor list;
(g) Audit dates are during the audit registration period (after the previous IOSA audit);
The specific provisions that need to be verified by the AO auditors on-site, include:
(a) Any findings or groups of related findings;
(b) A sample of N/A assessments;
(c) SMS and QA related provisions;
(d) Any assessments, group of assessments or other areas of concern highlighted by the internal
auditors or their managers; and
(e) Any assessment or group of assessments which the AO auditors have a reason to be concerned
about.
Note:
If the internal oversight is complete, however the content is of poor quality, the ORG auditor must
determine the root cause and reflect the nonconformity in the most appropriate ISARP.
2. Selection of provisions to be verified
The on-site verification of the Operator's internal audits by the IOSA Auditors will be as per the AO's
internal procedures and can be accomplished in different ways. The timing and sequence of the on-
site verification shall be coordinated by the Lead Auditor. Some examples of conducting the
verification include, but are not limited to:
(a) Conducting verification upfront before commencing with conventional IOSA auditing.
(b) Conducting verification concurrently with conventional IOSA auditing by:
1. pre-selecting the ISARPs to be verified and annotating them for verification as the audit
progresses;
2. randomly verifying an ISARP based on a time interval: as an example, every 30 minutes; or
3. randomly verifying an ISARP based on the number of ISARPs: as an example, every 10th
ISARP.
(c) Conducting verification at the end of the conventional IOSA audit to compare with the IOSA audit
assessment.
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(c) Internal auditors may be too familiar with their operational structure, processes and procedures that
they do not apply sufficient audit diligence and overlook or assume a level of conformance or
implementation.
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Procedures for Audit Organizations
2.7 Completing the Audit Checklists (AC) [Previously known as Questions and Responses
Report (QRR)]
2.7.1 Conventions used for the Audit and Report Production Process
(a) The grammar tense to be used:
1. Findings/Observations must be present tense;
2. Not Applicable items can be past or present tense;
3. Final Action Required (Planned Corrective Action) must be in future tense;
4. Review (Verification of Implementation) must be in past tense.
(b) “The operator” or the operator name should be used when referring to the operator in the IAR,
unless the phrase “Auditee” or “airline” is more appropriate to any specific titles, phrases or
descriptions.
(c) The term “conformity” must be used, not “compliance”, refer to the IRM definition.
(d) As the report is a recording of factual evidence, first person, subjective or personal terms must not
be used, such as: “I confirmed that....”, “we consider”, or “we are of the opinion that”.
(e) The standard format for dates in the report is: dd-Mmm-YYYY; the months are recorded as Mmm-
YYYY.
(f) Where an airport is stated also include the three letter IATA airport code.
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Option Description
AI (Active Implementation) or If the ISARP is an AI or PCO and the operator use AI or PCO to
PCO (Parallel Conformity) conform this ISARPs, select ‘Yes’. Otherwise select ‘No’. The default
value is ‘No’
The narrative description on which AI is used shall be stated as
per 5.5.
The narrative description on which PCO is used shall be stated as
per 4.2.9.
Open Item The auditor can use this button for highlighting any open ISARP. The
use of the button is up to the auditor's discretion. The default value is
‘No’.
The document reference must be recorded by adding the reference in the ‘Docs’ field in the Audit
Checklists, in accordance with 4.2.3.
The Auditor Actions must be completed and recorded using the check boxes in the Audit Checklists, in
accordance with 4.4.3.
The Auditor Actions must be completed however they do not need to be recorded in the audit software.
Please refer to 4.4.3 for detailed information.
If there are assessments resulting in nonconformities, then a Corrective Action Record (CAR) must be
raised for each nonconformity, in accordance with 2.8.
In the audit checklist, it is required to list the individual interviewed in the audit software. When
practicable, the auditor shall use the full name and position title of the individual interviewed.
Note:
The title and position do not need to be translated into English. See 2.7.3 Item 1.
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Procedures for Audit Organizations
Documentation References
1 Where an Auditee's language of operation is not English, documentation, titles, positions and
other key descriptors do not need to be translated into the English language (as long as the Latin
script is used) and can be recorded in the language used by the Auditee, accompanied by or
replaced by an appropriate explanation or equivalent title in English, as necessary.
Note:
If the language being used is that of the Auditee, it will need to be presented in Latin script, i.e.
not Cyrillic script, Arabic script, Chinese scripts or the many other scripts which are not easily
utilized in digital media.
2 All manuals and documents that are referenced as evidence in the Audit Checklists include
document title, code, version, revisions details and date of document (if applicable).
3 The field ‘Code’ is a mandatory field for the acronym name of the manual. It is suggested to
avoid any duplication of the name of the manual.
4 Title of the manual and document type are also mandatory field.
5 All manuals and controlled documents that are recorded in the DR, must include the document
type in the ‘Type’ column, as defined by the IRM (Type 1, 2, 3 or paper). This is done by
selecting the correct type from the drop down menu in the DR.
6 The ‘Date Reviewed’ field must be completed with the date that the document was accessed for
Type 1 and Type 2 documentation specified in ISM Table 1.1, but it is optional for Type 3 or
paper documentation specified in ISM Table 1.1.
If it was accessed multiple times or by multiple auditors, the first date it was accessed shall be
recorded.
7 The field ‘Audit Questions (Map)’ can be used to link the audit checklist item (i.e. ISARPs) to the
document reference. During normal operation of the audit software, the audit checklist items (i.e.
ISARPs) and the document reference are linked by responding the ISARPs in the ‘Audit
Checklist’ interface. It is not recommended to use this field to record the document reference.
Any document reference shall be linked to at least one audit checklist item (i.e. ISARPs). If not,
this means the particular document reference has not been used to demonstrate the conformity
of the ISARPs, and it shall be removed from the Document References.
8 If the Auditee uses a documentation structure that does not follow industry norms, or does not
have a readily available identifier (e.g. online/intranet documentation structures), the AO is still
required to provide some form of valid documentary reference, to ensure traceability of the
documentation that was used to validate the audit assessment.
9 Due to the software limitation, the unused document reference (i.e. the document reference is
not linked to any checklists or ISARPs) will not be removed automatically when the system
generates the Information Sources (IS) Report. The Audit Organization or Lead Auditor shall
ensure the unused document reference will be removed manually from the system before
proceeding the IS report.
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The audit builder can now save the data and go to the subsequent part of the Audit Summary as below.
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The AO shall submit the audit built at least 2 weeks prior to the commencement of the on-site audit.
Additional time shall be allowed if the auditee is required to review the document reference as per 2.7.1
item 6.
If the audit build has been approved by IATA, then the audit is ready to be used in the audit software.
The information will be logged under Program Admin Review. However, if there is any discrepancies
and required some amendment on the audit built, IATA will return the audit built to the builder with the
‘Return/Cancellation Reason’ and/or ‘Program Administrator’s Comments’ on what need to be
changed. AO shall either change the audit or communicate with IATA on the difficulties encountered.
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Examples
Some examples of reasons aircraft NOT on the AOC that would be listed
here:
(a) 23 B737-400s are wet leased from ACME Aviation in Ireland for one year.
(b) The Aircraft type, registration number, is used for private operations.
(c) The B737-700 fleet are listed on a different AOC.
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NOTE:
The last example above is sensitive in nature, but is indicative of future
challenges in implementing SMS in regions which have not historically
supported confidential or non-punitive safety reporting. The Lead/ORG
auditor must make a considered decision whether it is appropriate to make
reference to such sensitive aspects.
Providing an SMS overview will likely be difficult, but due to the industry focus
on SMS, will add real value to the Executive Summary and IAR. The
information in the examples above can generally be extracted from the SMS
assessment results.
Examples – Quality
(a) The Quality system functions effectively in most departments, but the
audit results confirm multiple areas of concern in the application of QA of
the Cargo Department.
(b) The Quality system has been decentralized and each operational division
has its own QA department and audit teams, which are functioning
effectively.
(c) The Flight Operations Quality system monitors internal processes well,
but the audit result identified that external providers and product control
was not being monitored consistently.
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NOTE:
Wet Lease In operations would normally be described in ‘Fleet(s) and/or
Aircraft Out of Scope’, but the Lead Auditor should evaluate whether any
substantial or dominant wet lease operation should also be mentioned in the
ES. An example would be if the wet lease in aircraft are required by the
Regulator to be on the AOC, see Figure 2.1.
The ES shall be completed within the reasonable time after the on-site closing
meeting.
The following descriptions are optional.
Training & Qualifications
Provide information on any significant characteristics or deficiencies in the
training structure, the following questions may provide assistance:
(a) What are the location(s) for simulator training, cabin crew training, fleet
specific training, conversion training, maintenance training, ground and
cargo training etc.;
(b) Are there any training organization authorizations held by the operator;
and
(c) What licences are issued by the authority for specific function(s), for
example dispatch staff.
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Documentation System
Provide information on any significant characteristics or deficiencies in the
documentation structure, the following questions may provide assistance:
(a) Does the operator have electronic, combined or paper based documen-
tation system?
(b) Does the operator use a centralized document control system, a
centralized library or department based document control?
(c) What is the level of access to the documentation system through out the
organization?
(d) Delivery system and storage architecture of the document repository? Is it
internet, intranet based, on a corporate server, cloud based etc.
(e) What is the language(s) used in documentation?
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2 Additional The information below should be described in this field ‘Additional Infor-
Information mation’, not the ES. However, The Lead Auditor must decide whether any
other pertinent information should be included in this field, or is sufficiently
important to be included in the ES.
The following are examples of unconventional or out of the ordinary situations
or circumstances which must be described, including reasons for and
confirmation of any approvals or waivers from IATA, as applicable.
Excluding any discipline in Audit Checklist – If any incomplete selection of all
8 disciplines of the checklist, the Lead Auditor shall mention this in the ES to
avoid any misunderstanding of incomplete selection of the audit checklist.
Suspended ISARP – If an ISARP assessment has been changed to N/A due
to a suspended ISARP during the course of the audit, see 5.2.2.
New ISM Edition – if a non-conformity was closed due to a new ISM edition
becoming effective, see 2.9.11.
Revisits – the frequency of return visits to verify the closure of the CARs may
be significant, and therefore mentioned (ensuring the details are kept
objective).
Use of Active Implementation Option – see 5.5. It is required to record
details of:
(a) the use of Active Implementation during this audit and all applicable
provisions;
(b) the status and progress of any previously utilized AI, see 5.5.6; and
(c) if an Implementation Action Plan is being re-used, has it been updated to
reflect the current status.
Use of Extenuating Circumstances Option – see IPM 7.5.6 – 7.5.11.
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The auditor must make use of the IATA provided Mandatory Observation
Checklists.
All aircraft related Mandatory Observations must be performed on an aircraft
type listed on the operator's AOC, excluding any out of scope and/or
exempted aircraft.
Additional Observations assessed – list any other or additional mandatory
or operational assessments which were carried out. The additional observa-
tions could be a full Mandatory Observation, or a portion thereof, or any other
observation that supports the assessment of conformity or nonconformity.
The auditor will include the details for any additional observations/
assessments conducted.
Additional Information
If any Mandatory Observation is performed greater than 30 calendar days
before or after the date of the closing meeting of the on-site phase of the
audit.
Details with the reason for any Mandatory Observation(s) that were not
performed, including Flight and Simulator Mandatory Observations, see 4.6.5.
The auditor(s) conducting the Mandatory Observation(s) does not have to be
part of the on-site Audit Team, see 4.6.1.
Refer to the IPM Table 3.1 for specific approval requirements for FLT
Mandatory Observations.
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NOTE: After completing the Report in the audit software, all sections of the final PDF files must be
reviewed before submission to IATA.
1 Local and regional abbreviations and acronyms will be familiar to the Auditee, but must be spelled
out, to ensure a clear understanding by the worldwide audience.
2 When interviews are part of the verification process, the evidence, any relevant actions and
references to records, reports or any documentation which were presented and/or described in
the interview must be included and/or referenced in the description of verification.
3 Information gained from one interview will very seldom be sufficient to substantiate and verify
evidence of corrective actions. If an interview is the only source of evidence available, the
reason(s) must be included in the evidence verification text.
4 AOs and operators are expected to use industry familiar audit terms and phraseology which
provide clear record of the audit process. Phrases such as “Verbiage added to.” are not
appropriate as a description of a corrective action.
5 References to email messages, computer screen prints, photographs or other information
sources, which can be altered, are not acceptable. Email information is acceptable if documented
as a controlled means of communication by the operator.
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6 Sampling is inevitable when assembling routine documentary references for the Audit Checklists
record.
However, for Findings and Observations, the CAR record must contain documentation references
& revisions for ALL fleets, operational functions, etc., affected by the nonconformity.
7 When referring to documentation, full names shall be used, unless an acronym is already listed in
the Document References from the on-site audit.
8 It is appreciated that documentary evidence is exchanged between the operator and AO, but all
attachments or references to external documentation (e.g. “please see attached”) must be
removed from the CAR before submission to IATA.
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The 5 Whys is a continuous question asking The most simplistic root cause analy-
technique used to explore the cause and sis method; might be inappropriate
effect relationships underlying a particular for complex issues.
problem. The answer to each question should
Solely using the 5 Whys approach
lead to the next question.
can lead to a very linear thought
Relevant participants should be brought process, where the Operator mis-
together and with the coordination of a takenly assumes there is only one
facilitator, the group should start asking “Why true root cause to an issue.
the Operator is not in conformity?”
The facilitators should be experi-
Despite being a simple technique, the tech- enced enough to be able to ask the
nique might help Operators to clarify the ‘right’ Why questions.
ambiguity around a nonconformity, create a
The success of this technique is de-
clearer picture, and strategically identify the
pendent on its participants i.e. if rel-
real cause of the problem, provided it is done
evant people are not available, the
with the right set of participants.
remaining group may not be able to
An example of 5 Whys technique is outlined find the correct answer to the Why
below. questions.
Example:
Problem Statement (Non-conformity): Altough
the Operator has a process in place, appli-
cable AD 2020-XXX is assessed incorrectly
as not applicable for two aircraft (XX-ABC
and XX-XYZ) in the Operator's fleet.
1. Why is the applicable AD assessed incor-
5 Whys Tech- rectly?
nique The engineer responsible for AD as-
sessed the modification status of the two
aircraft incorrectly?
2. Why is the modification status of two
aircraft assessed incorrectly?
The engineer responsible for AD is not
knowleageable about the AD assess-
ments, specifically checking the modifi-
cation status in the aircraft records sys-
tem.
3. Why is the engineer responsible for AD is
not knowleageable about the AD assess-
ments?
The operator's initial and recurrent train-
ing program for AD assessment are not
adequate.
4. Why are the initial and recurrent training
program for AD assessment not ad-
equate?
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Fishbone diagrams are diagrams that help to Disrupts the cause-and-effect re-
visually display many potential causes for a lationships underlying a problem by
problem or an effect. In general, this tool is groupin causes into categories
used in situations when the root cause is
A fishbone diagram does not single
entirely unknown.
out the root cause of the problem
To conduct analysis using the fishbone dia- because all causes look equally im-
gram, a fishbone shaped design is created portant. Therefore, the Operator
with the problem statement at the head of the should validate the causes before
fish, and significant causes of the problem as including into the fishbone diagram.
bones of its spine. Then, each of the ‘bones’
(cause categories) is analyzed one at a time,
and its causes are identified through ques-
tioning and brainstorming. These causes form
Fishbone the sub-bones of the spine.
Diagram
For each cause category, the Operator
should bring together experienced and rel-
evant personnel and the team should brain-
storm the possible causes of the nonconform-
ity.
Different sets of cause categories may be
used by the operator as required. Examples
are as follows:
1. Machine/Equipment, Method/Process/
System, Manpower and Material
2. Organization Factors - Resources,
Organizational Factors - Management
and Process/Task related Factors.
Operators should use the following best practices while performing root cause analysis. Exercising
these best practices might ensure the effective identification of the root cause of the nonconformity and
assist in defining effective corrective actions.
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5 The identified root cause should have the consensus of the team participating in the analysis
activity and the auditor if needed.
6 The complete root cause analysis process should be led by a qualified facilitator preferably
having previous experience and a formal training on the root cause analysis methodologies.
Predefined root cause categories are available in the Root Cause Category menu of the audit software
in order to provide effective assistance and guidance to the Operators in identifying the root causes.
The following table outlines the root cause categories and associated descriptions.
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Inadequate Risk Lack or inefficient risk management process that leads to unsafe/non-
Management desired operational outcomes.
Information is not adequately communicated within the organization, be-
Inadequate Communi-
tween all levels of personnel and to include other stakeholders such as
cation
Authorities, contractors, OEMs and etc.
Process/Task Related Factors
Process/Task is not
clear/understandable Self-explanatory.
and/or too complex.
Process/Task is not ef-
Self-explanatory.
fective
Process/Task is newly
Self-explanatory.
introduced or changed.
Process/Task is too re-
Self-explanatory.
petitive & monotonous
Process/Task re-
sponsibilities are not Self-explanatory.
clearly defined
Processes are not vali-
dated and/or not moni- Self-explanatory.
tored.
The Auditee must undertake a root cause analysis of the finding(s)/observation(s) in the audit software,
as outlined below.
Operators are obliged to have a Root Cause Analysis process in place as an integral part of
implementing permanent corrective actions and as an essential source of information for SMS.
The RC is very important information and must be completed for all CARs, even if no corrective action
is taken.
1 The RC must be added and completed for all CARs, even if no corrective action is taken. The RC
may be selected from the Root Cause Category menu of the audit software.
2 The AO must ensure that the operator provides an analysis of the situation, and records as a
factual, objective statement that give reason(s) for the IOSA policy, procedure, function, etc., not
being active or not implemented.
3 For the repeated ORG ISARPs when it has been identified that there are systemic deficiencies
throughout the organization, the root cause(s) for the ORG ISARP must also consider the
potential root cause(s) at the corporate level as well as the discipline level, so that the corrective
action(s) suitably address the systemic deficiencies throughout the organization.
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4 The Auditee will go to the ‘Root Cause Analysis’ heading and “Add Entry”. In the ‘Root Cause
Details’, tick the appropriate cause/code box in the drop down menu. Only one RC will be added
in the audit software per entry. Multiple entries can be made by the Auditee using this step
repeatedly.
Note:
To have the best view of all the root cause in one go, the ‘Item Displayed’ Button can be used for
the full list display. The button is located at the bottom of the page heading ‘Select Category for
Root Cause’.
5 If the chosen root cause/selected code requires additional explanation or clarification, the Auditee
will describe it in the field ‘Other’ and leave the ‘Category’ blank.
6 If the Auditee is unable to locate the proper root cause from the existing IATA/audit software
classification, the actual root cause description should be entered as free text into the ‘Other’
field.
Notes:
1. The Auditee must be advised not to use standard, generalized phrases or brief statements
such as “ISARP not considered”, or “Not needed”, which do not provide an appropriate
reason for why the operator had not incorporated the IOSA provisions.
2. The RC must not be a copy paste or an extract of the Narrative, or contradict the reasoning
and evidence for the nonconformity, or contradict any other assessment information in the
CAR.
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Example 1
“A program for annual recurrent training for cabin crew will be documented in the Cabin Crew
Operations Manual (CCOM), chapter 12.4. The CCOM and Annual Training program will be
revised to include recurrent training and are planned to be distributed to all stations by 20 July
2018. The training schedule will be revised”.
Example 2
“A process for senior management review of any significant issues arising from the quality
assurance program will be included in General Operations Manual”.
Example 3
“A secure quarantine area for rejected parts and materials awaiting disposition will be
established next to the Line Maintenance Office in Hangar 1”.
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The ‘Action Taken By’ field must contain the name of the auditee representative. The audit software
user name will be automatically logged in the field of ‘Submitted by’ and the date of submission of the
FAT must be reflected in the field of ‘Date of Final Action Taken’.
The Date of Final Action Taken cannot be later than the Review Date, or after the CAR or audit closure
date(s).
The operator shall then submit the FAT to the AO for review.
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1 The “RC” must always be completed, as essential input to the long term statistical analysis of
safety information.
2 If the Auditee has commenced implementation of corrective actions and wishes this progress to
be recorded in the CAR, this process can be followed the steps in IAH 2.9.1 – 2.9.8.
3 If the auditee will not implement any corrective action, then in corrective Action Plan, select ‘Final
Action’ and Corrective Action ‘No’, then click ‘Save’ in the header of the CAP. No further action
will be required.
Situation (a)
Root Cause RC shall state “The CAR was issued in error and there will be no root cause.”
(RC)
CAP Select ‘Final Action’ and Corrective Action ‘No’.
Then submit to AO for review.
Review ‘Expected Completion Date’ remains the same as the ‘Target Date’ in the ‘Initializing
Details’, to standardize the presentation of all CARs raised in error.
FAT/Final Leave field in ‘FAT’ and ‘Final Review and Acceptance’ as system default.
Review and
Acceptance
Situation (b)
Root Cause RC must be entered, explaining why the documentation was not available during
(RC) the audit.
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(d) IATA cannot practically provide specific procedures and standard CAR text for the many different
circumstances and combinations of when the option contained in IPM Section 8.12.4 may be used;
however the procedure below may be used for general circumstance and as a guide for other more
complex circumstances.
Note:
This IPM option applies only to open findings or observations. Even if a revision is published before an
audit, the AO is still required to audit to the ISM version specified in the contract. Any findings or
observations resulting from the audit may then be closed as per the new ISM revision.
A New ISM Edition or TR is Issued and is Effective well before the on-site Audit
The new/revised provision(s) will be issued as an AO Alert and incorporated in the Audit Checklists
template as temporary revisions, designated with a (T) suffix, before being issued to AOs.
1 The AO must immediately advise the operator of the ISM revisions/changes.
2 Conventional audit procedures apply.
A New ISM Edition or TR has been Issued and is Effective just before the on-site Audit
The Audit Checklists template would have already been issued to the AO for the audit and it is
impractical to incorporate the new/revised provision(s) in the audit checklist.
1 The AO must immediately advise the operator of the ISM revisions/changes.
2 The new or revised provision(s) must be conventionally audited from the AO Alert, and may
require the information on the AO Alert or TR to be inserted.
3 After audit completion, the new/revised provision(s) will be incorporated in the Audit Checklists
by an audit software administrator.
4 If nonconformities result from the ISM revisions/changes, conventional CAR(s) will then be
issued and closed.
A New ISM Edition or Revision is Effective on or after the Last Day of the Audit
As per Section 8.12.4 i) – iv), the AO has the choice of applying the new/revised provisions as
needed. The RC, names and dates in all CAR fields are completed conventionally.
1 CARs must always be issued for any nonconformities originating from the specified
version/revision of the ISM, to ensure a complete assessment record of the audit as contracted.
2 The original evidence which led to the nonconformity must remain unchanged.
3 If the new/revised provision(s) can be applied to close existing nonconformities, the CAR(s) must
be completed by inserting the standard Phrase below in the CAP and FAT fields.
Corrective actions are no longer required. See Verification of Implementation section below.
4 In ‘Final Review and Acceptance’, the verification of the corrective action shall include the details
of how the operator now achieves conformity with the new/revised provision(s). The Standard
phrase below is inserted after the Verification of Implementation text.
This finding has been closed in accordance with IPM Section 8.12.4. Conformity has been
verified against (ORG XX.xx (T), Revision XX), of the IOSA Standards Manual Ed NN (number
to be inserted).
The confirmation that the CAR has been closed based on conformity with the new or revised
provisions shall also be included.
5 A comment must be added to the Additional Information of the Audit Summary, to state that the
provision was closed based on a new ISM Edition or Revision.
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Note:
* indicated IATA recommended personnel for the specific function
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Changes in the operations might also affect other areas. An operator might, for example, decide to
transport dangerous goods or obtain new operational approvals. In this case, all relevant ISARPs must
be reviewed and audited, if not done before.
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There is a document reference template available for download from the audit software. The operator
or AO can fill in the document reference using this template or directly in the system.
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The responsible manager(s) will determine the need to audit the affected provisions and will
incorporate those into the internal audit plan. Typically, editorial changes to ISARPs (e.g. “IRM
reference revised”) would not require a re-audit of the revised ISARP.
Significant changes to the content of ISARPs can contain changes to the technical specifications, text,
notes or symbols (e.g. “[SMS]” designator, “►” symbol, etc.), related to the provision. The operator
shall evaluate the changes in provisions and determine if the re-auditing is required. In case of any
doubt, it is recommended to have the internal auditor revisit the provision.
When new ISM Editions have been incorporated, the operator may have assessments in the internal
Quality Assurance records that contain ISARPs from multiple ISM Editions. This is acceptable, as long
as the ISARPs are in accordance with the requirement as described above and ORG 3.4.6.
3.3.7 Training and Qualification Program for Internal Auditors (ORG 3.4.13)
ORG 3.4.13 requires a training and qualification program for the internal auditors. It also requires
specific initial and continuing training for auditors that perform audits against the applicable regulations
and standards and ISARPs, if applicable (see ORG 3.4.13 (iii)).
The conformity of this training and qualification program must, like for any other ISARP, be documented
and implemented. The operator can choose whether to develop an internal training or to purchase
specialized training from third party providers. In any case, the operator has to document the whole
training and qualification program, including training contents and all requirements as per the sub-
specifications of ORG 3.4.13.
Individuals selected as auditors must have the knowledge, skills and work experience that permits an
effective assessment of areas within the organization where the individual will conduct audits and that
are in alignment with the qualification criteria that the operator has defined as per ORG 3.4.13.
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Best Practice
The operator should establish a comprehensive management program for internal auditors that
includes a policy, standards and guidelines relevant to auditor selection, training and qualification in
accordance with ORG 3.4.12 and ORG 3.4.13.
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Best Practice
If external resources are used to conduct internal auditing against the ISARPs, the operator should
have published guidelines that specify appropriate criteria for the selection and use of such external
resources.
3.4.1 General
For the newly introduced method of auditing the effectivenss of implementation, an operator does not
necessarily need to prepare anything. The methodology simply probes certain ISARPs in more detail
and verifies additional aspects and criteria, which have not been verified formally up to this point.
The whole concept is introduced as a recommendation. Nothing new is required of an operator to
ensure the continued validity of the IOSA registry. Even if an operator has been assessed as not
implementing certain ISARPs effectively, this operator can still retain its IOSA registration status. To
have a positive result of the assessment, the operator should ensure sufficient efforts are invested in
implementing the corresponding ISARPs effectively and needs to be able to demonstrate it.
Following are some main points to be noted
1. To properly prepare, an operator needs to consult the Assessment Tool in the IOSA Standards
Manual for the corresponding ISARPs and identify the required elements.
2. The first element of the Assessment tool is the desired outcome. It is important that it is well
understood what the desired outcome of the ISARP is, as the rest of the elements, specifically
suitability and effectiveness, are there to support this desired outcome. For [Eff]-designated
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ISARPs, the desired outcome is defined in the standard, whereas for the rest of the ISARPs the
operator has some flexibility in defining it to ensure effective implementation.
3. The next step is ensuring the suitability of the implemented process. This will depend on the size,
complexity and nature of the operational environment. Clear criteria should be developed based on
which the suitability is evaluated internally. Achieving the desired outcome should always be in the
foreground of this evaluation. Ideally, there would also be some metrics associated which makes
the achievement of the desired outcome measurable. This will ultimately give an indication of
whether implementation is suitable. Another method to utilize could be benchmarking with other
operators of similar setup. This can also help in making the assessment and ensuring that the
suitability is given. The operator should be ready to communicate the rationales which went into
this internal assessment during the IOSA audit. Any type of benchmarking and analysis should
carry some form of proof (records).
4. Lastly, the specific effectiveness criteria need to be in place. The operator needs to study them and
make sure they are all in place and fully implemented. Every effectiveness criterion must be in
place to receive a positive assessment for effectiveness. If only one item is missing, the
assessment would automatically become negative for that particular ISARP. It is the operator’s
burden to provide sufficient proof of implementation.
3.4.2 Documentation
The main focus of the effectiveness methodology is the implementation – ensuring that all processes
are carried out in an effective manner. There is no documentation required for both, ORG 1.7.1 as well
as for the criteria underneath the [Eff]-designated ISARPs. The umbrella ISARP does not require a
document reference in the audit checklist.
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(b) If the operator does not meet the stated condition(s) anywhere in its system or does not have
authorization for the operational function, then the standard or recommended practice, or part
thereof, is not applicable to the operator (i.e. is recorded as N/A in the audit checklist, see 4.2.7).
(c) If the conditions stated in a conditional phrase are performed by external service providers (i.e.
outsourced), then the Standard or Recommended Practice is applicable to the operator and must
be included in the scope of the audit, and audited as per outsourced functions see Section 4.5.
(d) If the operator is approved for a specific operation, but does not perform that operation then it is
considered applicable and must be included in the audit, and audited conventionally (see Inactive
Operations in 4.1.4).
Although a provision may not apply to an operator, an auditor may choose (or may be requested) to
include a record of the development, implementation and status of a particular activity or function,
providing additional information and value to the audit record.
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relating to that activity must be checked and a finding given for not being ‘implemented’ with an
added narrative underlying the reasons thereof. As and when the operator commences that
activity, the implementation records can be examined to close the finding. Examples of this
kind may include a fresh approval for EDTO, or a fresh approval for the carriage of DG.
It must be noted that the differences between the two types of dormant activities are not well-defined;
mature auditor judgment must be applied with the overall aim of reducing the operational risk to the
operator utilizing those approvals on a non-regular basis.
If ISARPs do not meet the determination of applicability, they must be treated as Not Applicable, see
4.2.6, and recorded as per 4.2.7.
4.2.2 Documented
To determine conformity with ISARPs as documented, an auditor must be able to find information that
addresses the requirements as specified in the applicable IOSA specification(s) published in a
controlled document, such as a manual, handbook or other similar publication, that comprises content
approved by the operator, and where applicable the Authority; see ISM Introduction Section 7. The
ISARP must not to be copied verbatim into the operator's manuals and/or controlled manuals as a
mean to conform to the ISARP's provision. Instead, the substantive matters shall be described for the
purpose of conformity to the ISARP's provision.
The assessment of the requirement(s) being documented, is based specifically on whether the
provision requires a system, plan, policy, process or procedure. For example: if the ISARP states that a
process is required, then the auditor must assess the documentation to see that a process has been
documented. It is often an incorrect assessment is made due to the misunderstanding of these terms.
A controlled document must have associated processes for the positive control of content, revision,
publication, distribution, availability and retention, as specified in ISM ORG 2.1.1 and Table 1.1, which
is a specification that is repeated in all other ISM sections; this ensures appropriate operational
personnel always have access to the current version of the document; see IRM.
It is essential to note that the controlled documents are under the control of the operator and not
another entity: thus, the manuals of the Regulator are not acceptable for evidence of documentation.
However, the manuals produced by external companies for the operator, such as navigation manuals,
and the manuals produced by the manufacturer of the aircraft/components can be used for evidence of
documentation. Auditor shall ensure that these manuals/documents are controlled for the latest
version/revision.
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1 Identify the manuals and/or other document(s) that contain the information to address the
specification(s) in the particular ISARP. It is a fundamental principle of IOSA that the relevant
information must be contained in a controlled document.
Note:
The ISARP should not be copied verbatim into the operator's manuals and/or documents.
2 The documentation must be under the direct or indirect control of the operator. Manuals of the
regulatory authority, which are intended for use by the regulatory bodies, or generic aviation
industry manuals must not be accepted in the assessment of conformity with an ISARP.
Manuals produced by external vendors on behalf of the operator, such as navigation manuals
and manuals from the manufacturer of the aircraft/components, are acceptable.
3 Paper or electronic forms (Type 1: URL-Based, Type 2: Software Based, Type 3: Files on
Servers, see IRM Electronic Documents) of documentation are both acceptable, as long as the
medium meets the criteria for a controlled document and is traceable, see ISM Table 1.1.
4 The manuals and/or documents being assessed shall be available for use by all the staff, crews
and/or external service providers (if applicable) involved.
Note:
It is important that the documentation shall fulfill the common language(s) requirement and be
understood by all staff concerned.
5 Confirming that the process, procedure, etc., is documented and sufficient. The content must be
assessed, to confirm that all elements of the ISARP requirement have been addressed.
6 The content of a document must be written in a language, style and format that clearly and
accurately represents the meaning and fulfill the intent of the specification(s), and will be
understood by relevant operational personnel.
7 Documentary references must be provided for all ISARPs, exceptions are:
(a) ISARPs that require adequate infrastructure, workplace, etc., do not require a documentary
reference, but should be provided if available, such as ORG 1.6.1, FLT 1.5.1, DSP 1.5.1,
MNT 1.4.1, CAB 1.4.1, GRH 1.4.1 and CGO 1.4.1.
In such cases it should be stated in the audit checklist narrative: No document reference
required in accordance with the IAH.
(b) ISARPs which have a nonconformity because there is no documentation available.
8 Documentary references are not necessarily required to be listed individually for each sub-
requirement. However, all requirements (including sub-requirements) of the ISARP must be
traceable from the documentary reference(s) recorded for the ISARP.
9 The references for documents or manuals must include a title, edition or revision number, and/or
a date of issue, or other means of recording traceability of the information.
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10 When an ISARP is applicable to multiple fleets, then there must be a document reference
applicable to each of the fleets utilized by the operator.
11 To ensure there is no ambiguity for traceability, the auditor shall record either the full document
name, abbreviation or acronym listed in the Document Reference, followed by detailed sub-
references (e.g. chapter, section, sub-section number) as applicable to the documented format
and the ISARP specification. For example: “OMA Chapt 2.5.3 vi)” provides clear traceability
versus “OMA Chapt 2.5” which (unless all sub-sections apply) does not if the evidence resides in
2.5.3 vi)
12 Document references must be provided for controlled manuals, procedures and policies, as per
the ISARP provision. Supplementary documents such as meeting minutes, bulletins, records,
plans, checklists, etc., generally cannot be used as documentation references unless those
documents fulfill all the document control requirements.
13 Documents of a temporary or transitory nature, or records, (e.g. letters, email, memos, flyers,
posters, MS PowerPoint presentations), are not acceptable as sources of controlled documen-
tation, unless the information has been reproduced and included as part of the content in a
controlled document. This excludes the ISARPs related to the Aircraft Systems and Equipment
tables.
14 If the ISARP covers a broad range of procedures and there are document references within the
majority of the sections of a manual, a generalized reference may be used, i.e. a phrase such
as “GOM – complete document” or “OMA – all sections”.
4.2.4 Implemented
To determine conformity with ISARPs as implemented, an auditor must be able to determine that the
requirements as specified in the applicable IOSA specifications have been established, activated,
integrated, incorporated, deployed, installed, maintained and/or made available, as part of the
operational system, see ISM Introduction Section 7, using either of the following means:
(a) as an active and integral part of the operator's organization or operations, or;
(b) as a contracted or outsourced operational function. See 4.5.2, Assessment of Outsourced
Functions.
When assessing a specific ISARP, the Auditor must make a systemic assessment taking into
consideration the systemic applicability as stated in 4.1.4 c. Determination of a nonconformity for the
ISARP is based on systemic nonconformity.
1 In assessing implementation the auditor must be familiar with the content of the operator's
documentation.
2 Generally, the requirement(s) of the provision(s) must be effectively implemented in a manner
consistent with the way the requirement is documented, excluding occasions when a
requirement may be effectively implemented but not adequately documented. See 4.2.14.
3 The assessment of implemented is based on auditor judgement following, thorough observa-
tions, interviews and reviews of records (among other audit techniques). Evidence (see section
4.3), must then be identified to confirm that the specification(s) is/are being used on a daily basis
by the personnel concerned, in accordance with the documented requirement.
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4 Normally, the assessment of implementation should be conducted following the assessment that
the requirement(s) is/are documented.
However, there are many occasions where evidence must be collected at a later stage, due to a
number of circumstance, such as reviewed during the conduct of the Mandatory Observations,
sampling during multiple ISARPs (e.g. training records), or during the combined assessment of
linked ISARPs. When this occurs the auditor must have a method/process (e.g. a memory aide,
side-notes) to ensure that no assessment of implementation is missed, particularly when there
are many ISARPs treated this way. This should be done by leaving the ISARP open, or un-
assessed; the marking of the ISARP as assessed is not acceptable.
5 The provision(s) must be subject to monitoring to ensure desired outcomes are achieved.
6 The Auditor Actions (see 4.4.1) provide specific information on the actions that would normally
be used to confirm implementation for that ISARP. If local circumstances result in different
actions being needed to confirm implementation, these actions should be recorded under “Other
Actions”.
7 Mandatory Observations (see 4.6) provide activities that would contribute in the assessment to
confirm implementation for that ISARP.
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Once an assessment of N/A is made for the ISARP, it needs to be suitably recorded. The following
table provides information on what is required in recording N/A assessments.
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4 If a specification is not applicable to the operator, but it was documented and implemented by
the operator, the assessment will be N/A, but the additional information can be recorded in the
Comments to give due credit to the operator.
Example: Auditing of the external service providers
ABC Airlines does not use service providers for operational control, but has documented the
process, should service providers be required.
5 If a function is inactive, or not yet operational, but the operator has documented the required
procedures (in preparation for the function being required or becoming active), the assessment
will be N/A, but the additional information can be recorded in the narrative to give due credit to
the operator. Meanwhile, it also helps the audit report reader to understand the situation better in
case the operator activates the operation in future.
Example: RVSM operations
ABC Airlines is not yet authorized for RVSM operations, but has implemented all maintenance
requirements and completed the required training for all crews and staff.
When an assessment of Not Applicable has been made, a statement is made in the comments for the
ISARP; the following table provides some guidance on the phrases that should to be used.
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Note:
In the absence of regulator issued Operations Specification, see 2.4.1, the word “authorized” should be
replaced by “approved”.
Example
When assessing the operator's de-/anti-icing program, the auditor must gather evidence that shows
that the de-/anti-icing program is implemented, not only at the home station (if applicable), but at all
applicable locations where flights might be operated (including locations where de-/anti-icing
operations are conducted by external service providers).
The operator does not have to audit each location, but will have, through its monitoring processes, a
means of gathering evidence of implementation (e.g. inspections, evaluation questionnaires, Service
Level Agreements and other measurables means). If evidence indicates the de-/anti-icing program is,
in fact, implemented at all applicable locations throughout the operator's system, then the operator is
in conformity with the IOSA provision.
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Example
GRH 2.1.1 The operator shall have a process to ensure personnel who perform operational duties in
functions within the scope of ground handling operations for the Operator, to include personnel of
external service providers, complete:
(i) Initial training prior to being assigned to perform such operational duties;
(ii) Recurrent training on a frequency in accordance with requirements of the regulatory authority but
not less than once during every 36-month period, except for recurrent training in dangerous
goods as specified in GRH 2.2.1 or GRH 2.2.2 (GM).
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If the operator is assessed as meeting the optional means of conformity (PCO), insert the standard
phrase below and, if required, state the PCO option chosen, following the conventional documentary
reference(s) and any narrative response.
“The Operator (or ABC) is in conformity with the Parallel Conformity provision.”
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ORG 1.3.2 The Operator shall have a process for the delegation of duties within the management
system that ensures managerial continuity is maintained when operational managers, including
nominated post holders, if applicable, are absent from the workplace. (GM) ►
Documented not implemented
Narrative: Most managerial posts have published deputies in accordance with their procedure, but
deputies have not been nominated and published for the Head of Cabin Services and the Crew
Training Manager positions.
Document Reference: OMA 2.2.1
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FLT 1.10.2 The Operator shall have an audit planning process and sufficient resources to ensure
audits of flight operations functions are:
(i) scheduled at intervals that meet management system requirements;
(ii) completed within a specified time period. (GM)
Documented not implemented
Narrative: The scheduled audit of Flight Operations training records, as specified on the annual
Audit Plan, had not taken place within the specified time frame.
Document Reference: CTM 3.5.
ORG 3.4.2 The Operator shall appoint a manager with appropriate qualifications, authority and
independence that is responsible for:
(i) The performance of the quality assurance program;
(ii) Ensuring communication and coordination with operational managers in the management of
operational risk;
(iii) Dissemination of information to management and non-management operational personnel as
appropriate to ensure an organizational awareness of relevant quality assurance issues and results.
Implemented, not documented
Narrative: Although the operator had appointed a manager with appropriate qualifications, authority
and independence, who was responsible for the performance of the QA program, ensuring
communication and coordination with operational managers in the management of operational risk
and disseminating the information to management and non-management operational personnel to
ensure an organizational awareness of relevant quality assurance issues and results, there was no
documentation to ensure consistency in such appointments.
Document Reference: Nil
CGO 1.6.1 If the Operator transports revenue or non-revenue cargo, the Operator shall have an
Operations Manual (OM), which may be issued in separate parts, that contains the operational
policies, processes, procedures and other information necessary to ensure compliance with
applicable regulations, laws, rules and standards of the Operator. The content of the OM shall
contain standards and guidance that addresses the acceptance, handling, loading, securing and
transporting of cargo as specified in Table 7.1. (GM)
Implemented, not documented
Narrative: The Operator had implemented policies, processes and procedures to ensure
compliance with applicable regulations, laws, rules and standards, but the documentation was
contained in a loose-leaf binder that was not controlled.
Document Reference: None
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FLT 3.11.59 The Operator shall have a stabilized approach policy with associated guidance, criteria
and procedures to ensure the conduct of stabilized approaches. Such policy shall specify:
(i) A minimum height for stabilization not less than 1000 feet AAL for approaches in IMC or not less
than 500 ft. AAL for approaches in IMC as designated by the operator and/or State where a lower
stabilization height is operationally required;
(ii) A minimum height for stabilization not less than 500 feet AAL for approaches in VMC;
(iii) Aircraft configuration requirements specific to each aircraft type (landing gear, wing flaps,
speedbrakes);
(iv) Speed and thrust limitations;
(v) Vertical speed limitations;
(vi) Acceptable vertical and lateral displacement from the normal approach path. (GM)
Not documented not implemented
Narrative: Sub-provision i): The published minimum height for ABC Airlines for stabilisation in IMC is
800 feet AAL, which is below the ISARP AAL requirement.
Sub-provision v): Vertical speed limitations are not defined or implemented.
Document Reference: OMA 8.15
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Implemented, not documented assessments may be difficult or complex to close, and will include an
additional step to ensure the corrective action to document the requirement does not compromise the
original assessment of implemented. If the corrective action to document the requirement does impact
or change the implemented situation in the original assessment, then a complete review of the
corrective action as documented and implemented will be required (and may require a return visit) to
reassess if it is indeed implemented as documented.
In the cases where the corrective action to document the requirement impacts or changes the original
implemented assessment, and if this is anticipated in advance, the assessment must be Not
Documented, Not Implemented.
Due to the unique nature of an Implemented, not documented assessment, the process for raising
and closing CARs in 2.9 must be complemented with the following procedure in the table below.
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Repeated ORG ISARPs (both SMS and non-SMS) are identified in the ORG section is followed by a
“►”, or a “>” in the ISM, or Audit Software, facing towards the right, indicating that the ISARP is
repeated in other ISM Section(s). The linking ISARPs in the other disciplines have the triangle “◄”, or
arrow “<” in the ISM, or Audit Software, facing towards the left, indicating that it has been repeated from
the ORG Section.
For ORG ISARPs which are repeated (SMS and non-SMS), the ORG provision must be assessed in
conjunction with the repeated provisions in the other ISM sections.
Conformity with the ORG provision is determined by a combination of the results of:
(a) The assessment of the individual ORG provision; and
(b) The assessments of the repetitive provisions in the other ISM sections.
The assessment for the ORG provision will represent the overall level of conformity for each group of
repeated provisions, adding value to the audit result by demonstrating a conformity throughout the
organization.
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Auditors must establish the most appropriate method of harmonizing and ensuring completeness of the
assessments for the linked ISARPs across all disciplines.
The repeated and interlinked ISARP report from the audit software as a three letter coded method of
stating the ISARP assessment, the letters are either a ‘Y’ for Yes or ‘N’ for No. The three letters of the
code are:
(a) First Letter is if the ISARP was assessed in conformity – Yes/No;
(b) Second Letter is if it the ISARP was assessed as Documented – Yes/No; and
(c) Third Letter is if the ISARP was assessed as Implemented – Yes/No.
Best Practice
The operator should have published processes that provide for the identification of all interlinked
ISARPs and define the coordination necessary to ensure there is consistent applicability of interlinked
ISARPs in the internal audit process.
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Following the above standard sentence, all ISARPs and missing Effectiveness Criteria
must be listed. It is best to refer to the criteria by sub-item number.
Details for missing Effectiveness Criteria
ORG 3.1.2 Effectiveness Criteria (i) – (v) are not implemented
FLT 1.12.2 Effectiveness Criteria (ii) and (iii) are not implemented
In case an ISARP designated by the [Eff] symbol has been assessed as non-conformity,
the Effectiveness verification does not take place. In such a scenario, the auditor
comment needs to reflect the fact that the ISARP is not in conformity.
Non-conformity of a designated ISARP
DSP 1.12.2 has been assessed as non-conformity
Repeated The logic for Effectiveness Criteria of repeated ORG provisions follows the same as is
provisions applicable for SMS provisions.
If an Effectiveness Criterion has been identified as not implemented in one or more of the
operational disciplines, the corresponding Effectiveness Criterion in ORG cannot be
assessed as implemented. The ORG auditor therefore needs to check the results of all
the other disciplines before making a final assessment for the Effectiveness Criteria in the
ORG ISARP.
The recording in ORG 1.7.1 must list the missing criteria from the operational disciplines
as well as the missing one(s) in ORG, if the ORG assessment is a result of the repeated
provisions.
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4.3.1 Evidence
The auditor needs to secure sufficient factual or objective evidence, derived from all available sources
of evidence, information, documentation and activities assessed during an Audit, to determine that the
Auditee is in conformity with the ISARP or not. Conversely, conformity or non-conformity must never be
based on subjective evidence or opinion.
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The Auditor Actions (AAs), are customized for each ISARP, and provide the following:
(a) guidance to auditors for the actions to be taken to confirm implementation;
(b) a record of the actions taken to confirm implementation for Operator’s internal assessments; and
(c) a means of standardizing the assessment of implementation.
Factual evidence is gathered from a number of sources as a result of various activities undertaken by
an auditor during the course of an Audit, derived from the following activities:
(a) identifying and assessing documentation;
(b) interviewing personnel;
(c) observing facilities, equipment and other physical resources;
(d) observing the conduct of operational activities and processes;
(e) observing implementation of IOSA provisions;
(f) examining data collected from day-to-day operations (e.g. flight data analysis, quality control
inspections); and
(g) examining records (accident report, performance reports, supplier evaluation, maintenance,
training, checking, inspections, audits, agendas, minutes, action items).
Note:
Auditor Actions (see 4.4 below) are generally based on these types of activities for evidence collection.
The usefulness of evidence depends on the source; and not all evidence is objective or factual.
Auditors must exercise healthy skepticism and professional judgment when evaluating information
derived from:
(a) individuals that might be operationally uninformed, misinformed or not fully aware of all audit
requirements;
(b) representatives of the auditee who may be attempting to influence the objectivity of the auditor;
and/or
(c) sources that could have negative intentions designed specifically to mislead, hinder or prejudice
the auditor.
An initial determination of implementation may not always be easily possible. In such cases, an auditor
may need to collect sufficient evidence from multiple sources to confirm that a provision has been
implemented by the auditee.
In determining conformity, the sampled evidence must be corroborated with other sources of objective
evidence to gain certainty for the auditor to exercise ‘Auditor Judgement’ in making the final
assessment. A single sample is not enough to support an assessment of conformity or nonconformity.
If the auditor is not certain about an assessment, further evidence must be collected and corroborated.
However, in some cases where the operator recently commenced the operations (e.g. Dangerous
Goods Approval and Carriage of Live Animals), there may not be many records available for sampling
and auditor judgement needs to be applied. Also see 4.1.4 Dormant Operations.
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The completion of some training may be split over a three year period; part of which may have been
examined during the previous audit. However, in order to assess that the required training was
completed, the auditor must ensure that the depth of the examination of the training programs and
training records matches, at the very least, the training cycle of the operator.
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All efforts should be made to review sampled evidence during the assessment of the ISARP. However
due to practicality, sampling of evidence may not always be conducted immediately during the
assessment of the ISARPs. It may be delayed due to a number of circumstance, such as being
reviewed during the conduct of the Mandatory Observations, sampling during multiple ISARPs (e.g.
training records), or during the combined assessment of linked ISARPs. However, evidence must not
be accepted after the conclusion of the on-site assessment and auditing process, except when
Mandatory Observations are conducted after the on-site audit or there is an audit adjournment.
Note:
If the review of sampled evidence is not done at the time of the ISARP assessment, the auditor must
have a method/process to ensure that the sampling of evidence is not forgotten and control of the
assessment is not lost, particularly when there are many ISARPs treated this way. This is generally
done by leaving the ISARP open, or un-assessed; marking the ISARP as assessed is not acceptable.
Caution and judgement must be exercised by the auditor, to ensure their specific and randomly
selected samples requested are either selected immediately by the auditor or (when logistically
necessary) provided by the auditee in a timely manner. The time frame for the delivery of the samples
should be appropriate and prompt, to prevent the fabrication or alteration of the sampled evidence.
Best Practice
The AOs should have published guidelines that specify the sampling techniques that must be used by
auditors in the collection of evidence when auditing the ISARPs.
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Reviewing documentation is one audit activity that can be accomplished in advance of the on-site audit.
In an ideal situation, the auditee will provide various documents (manuals, handbooks, etc.) prior to the
Audit, thus permitting the auditor to accomplish a review before arriving on site.
To further improve efficiency of the documentation review process, the auditor (via their Audit
Organization) should request the auditee to provide all references from its manual system that directly
correspond to ISARPs. This will greatly assist the auditor by eliminating the necessity of having to
search through various manuals on-site when attempting to verify that specifications are properly
documented.
It will not always be possible to receive documents prior to an Audit; so in many cases the auditor will
be required to review documents in the early stages of the on-site visit. This obviously leads to a certain
degree of inefficiency because of the on-site time needed for this review.
The fact that specifications are properly documented does not always mean that they are properly
implemented. The process of confirming implementation is comprised of two distinct elements and the
auditor needs to assess that:
(a) A specification is (are) established, activated, integrated, etc. (e.g., observations, records reviews),
where applicable, in accordance with the documented systems, programs, processes, procedures
and plans in use by the operator.
(b) An equally important element is that a specification is (are) monitored and evaluated, as necessary,
for continued effectiveness (e.g. minutes of meetings are distributed, action items from
management reviews are carried out and closed, control charts, job descriptions, workouts,
process improvement strategies are actively managed, carried out and closed).
The auditor's on-site activity will involve corroborating and verifying information found in documents
with information examined in records, evidence collected from interviews and direct observations, in
order to determine if IOSA specifications are properly implemented.
Notes:
1. Document references must be of documents controlled by the operator, not a reference to state
regulations or industry guidelines e.g. IATA Airport Handling Manual.
2. Where an ISARP requirement may be applied differently for different aircraft types, or it states ‘all
aircraft in its fleet’, document references must be provided for each aircraft in its fleet.
3. For recording document references refer to 4.2.3.
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standardization of interpretation, and to address questions in the verification of the internal audit results
against the ISARPs.
To ensure effective Audit interviews, preparation is important, an auditor must study the checklist in
advance and prepare specific questions for each anticipated interview situation.
The IOSA Checklist does not provide a list of questions that can be asked by the auditor. Therefore, for
efficiency in gathering evidence during interviews, an auditor must be prepared and proficient in posing
questions appropriate for the interviewee, in a way that will create productive dialogue and enhance the
return of information from interviewees.
Information gained from interviews should normally be considered subjective evidence and will seldom
be enough by itself to justify a final audit assessment of conformity or nonconformity. Additionally, one
interview may seldom be enough to justify an assessment of conformity or nonconformity. The
evidence from the interview should always be accompanied by corroborative evidence (preferably
objective), which must be analyzed together in order to arrive at a conclusive determination of
conformance or nonconformance. For confirmation of implementation, interview evidence should
always be supported by the Auditor Actions listed.
Additional interviews (perhaps of individuals of varied levels of responsibility or from different
departments) may also be required together with other supporting actions.
During the interviewing process, the auditor must take into consideration:
(a) the arduous and stressful process, and the effect on the interviewee;
(b) cultural factors, (i.e. breaks for prayer time etc.);
(c) operational priorities of the person being interviewed; and
(d) the well-being of the interviewee, with regular comfort breaks.
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Note:
Templates, forms and other documents that are blanks do not constitute a record, they do not
demonstrate that a requirement is active, and does not support the assessment of implementation.
When auditors are examining records, they need to ensure that the record is the most recent and from
a reliable source in an attempt to ensure it is factual in its content. For example getting copies of
meeting minutes from an email, may not be the most reliable source, getting it from the network/server
where all the official minutes are kept may be more reliable.
In some cases there are no records available to demonstrate that the requirement(s) have been
implemented, for example, emergency response or abnormal situations, or the confidential safety
reporting system, when the system has not been used. In these cases the auditor must find other
sources of evidence to support the assessment of the ISARP, usually through interview by asking if
staff are aware of the system/actions/response, and if any confidential reports or abnormal situations
have occurred.
Records may support the assessment that ISARP requirement(s) is/are monitored and evaluated, as
necessary, for continued effectiveness (e.g. minutes of meetings are distributed, action items from
management reviews are carried out and closed, control charts, job descriptions, workouts, process
improvement strategies are actively managed, carried out and closed).
In some cases, the records might not be available due to the recent commencement of a new approval
by the operator. For example, the operator was approved to carry Dangerous Goods two days before
the on-site audit; in this situation, the auditor should not use the availability of Dangerous Goods
records as the only means to verify the implementation. Also see 4.1.4.
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(d) statistical summaries of operational performance (e.g. accidents, incidents, failure rates);
(e) regulatory requirements or approvals;
(f) audits of the operator by Regulators (or other organizations); and
(g) reports of accidents, incidents, irregularities or other events.
Note:
Records must be complete, identifying blank forms or an electronic system, does not constitute an
assessment of implemented.
4.4.1 Introduction
Auditor Actions published by IATA are action steps that have been specifically compiled for each
individual IOSA Standard and Recommended Practice.
Whereas the Auditor Actions must be followed to assess and confirm the implementation of the
ISARPs, IOSA Auditors are no longer required to record Auditor Actions taken in the audit software.
Auditor Actions (AAs) support the focus on implementation and auditing standardization. As internal
auditors conduct separate assessments for documentation and implementation, the AAs will assist
internal auditors as a key source of information for and provide guidance on the actions needed to
confirm implementation. The term “Auditor Action” is defined in the IRM.
Auditor Actions accomplished by Internal Auditors must be recorded and retained to provide evidence
of implementation as required by ISM Table 1.2 and IAH Chapter 4.4.3 provide detailed procedures for
auditor actions.
AAs have been incorporated in the IOSA Program for the following reasons:
(a) to address growing industry concerns that implementation was not being adequately assessed;
(b) to provide a basis for standardizing the assessment of implementation across the Program; and
(c) to provide transparency and traceability to assessments.
The options an operator has in defining and utilizing the Auditor Actions is outlined in 4.4.5.
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1 The auditors are responsible for completing sufficient actions to gather the evidence needed to
confirm an assessment of conformity or nonconformity. However, they are not obliged to record
these actions taken in the Audit Software. Operator's internal auditors are responsible for
providing a record of the AAs.
2 For conventional audit situations, the auditor should expect to complete all the listed AAs for each
ISARP. However, there will often be situations when:
(a) The IOSA auditor has completed enough actions to confirm the assessment, without having
to accomplish all listed AAs;
(b) Conventional operating structures, facilities, functions, processes, etc., are not being used by
the operator and cannot be assessed;
(c) Members of management or personnel, facilities, functions, etc., are not accessible to the
IOSA auditor and accomplishing one or more AAs is not possible.
4 The AAs in groups 4.4.2 line 1 a. & b. above are the basis of the initial assessment and will
almost always be completed, For example: if a document reference has been listed, action 1
above was completed.
5 After identifying the specific documentation (AA1) and interviewing responsible personnel/
management (AA2), the actions in 4.4.2 line 1 c. above, are used to assess functionality and
implementation of that ISARP.
Note:
The responsible manager refers to the manager that carries out that task in their day to day work
function, not the Quality Manager or other manager(s) that may be aware of the task, procedure
or function.
6 Where an Auditor Action requires sampling (i.e. where the action step specifies the assessment
of selected items as evidence), auditors will determine the sampling size and selection in
accordance with sampling guidance specified in 4.3.2 (or sampling guidelines published by the
operator).
7 The completion and ticking of an AA (Recording is only applicable to Operator internal auditor):
(a) confirms that the auditor took that action while gathering evidence;
(b) will be one of multiple actions taken to assess conformity; OR
(c) will result in non-conformities being identified, when specifications of the required policy,
process procedure, function, facility, etc., do not exist, or are deficient.
8 If action(s) need to be taken which are not in the list of AAs, the last Auditor Action, “Other
Actions” will be used to provide a description of the action(s) taken.
This is the only time when auditors will need to provide any written description of action(s) taken.
Note:
The operator has the option to substitute or add one or more auditor actions (i.e. accomplishing
action step(s) that are different from those published by IATA), which would be recorded under
“Other Actions”, refer to 4.4.5.
9 The Narrative remains the primary evidence description for all non-conformities. The narrative will
have to be harmonized with the audited AAs.
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Best Practice
The IOSA registered operator should require its internal auditors, to the extent possible, to complete
all Auditor Actions when auditing the ISARPs.
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When an operational function is outsourced by an operator, the operator must ensure the following
requirements are in place (these are addressed in the repeat provisions in ISM ORG 3.4 and 3.5):
(a) the execution of a formal contract/agreement between the operator and the provider;
(b) measurable specifications;
(c) a functional process to monitor the outsourced operational function, which would include programs
and processes;
(d) the monitoring the outsourced operational function must be periodical and systemic, and if the
oversight is done by auditing, then the operator’s audit plan must adequately cover the entire
outsourced operational function;
(e) the persons overseeing the outsourced operational function must be impartial, functionally
independent and competent for the task, and if the monitoring is done by auditing, then the auditor
quality (qualifications, training, etc.) must be commensurate with the audit requirements.
As can be seen with these elements of outsourcing operational functions, and as the amount of
outsourcing increases, the monitoring function of the Operator must be strengthened. With an increase
in outsourcing, there should be visible changes in the Quality Assurance program to handle in the
increase, for example, there should be an increase on the audit schedule, resources, checklists to
cover the expanded scope, auditor training, post-audit follow-up and closures, escalations,
management reviews and strategic changes, etc.
The approach to be taken by IOSA auditors in auditing outsourced function(s) is different; the audit
methodology must verify that the Operator is performing adequate oversight of the outsourced
operational function(s), and they are included in the oversight program of the Operator.
For the monitoring of outsourced functions in the area of ground operations, an Operator might choose
to participate ISAGO Program and/or in one or more IATA/Industry audit pools such as the DAQCP,
IFQP or IDQP (please visit www.iata.org/whatwedo/safety/audit for further information). Participation in
a pool as mentioned above can be used to complement the monitoring activities of an Operator on a
particular external service provider. The Operator will typically have more monitoring elements in place
to cover other requirements (for example, local regulation, etc) that are not included in the above
mentioned audit pools, or that do not address a particular service (for example cleaning, etc.)
Note:
There is a difference between the monitoring of outsourced activities by the Operator, and the
assessment of outsourced activities by an AO during an IOSA audit. Operators conduct oversight
directly on the external providers of outsourced functions, however the IOSA auditors will confirm that
the Operator has an adequate system in place to monitor the external provider, to ensure that safety
and security requirements are being met.
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The “Quality Control of Outsourced Operations and Products” related sections of all eight IOSA
disciplines contain specifications for contracts with measurable specifications, monitoring processes
and processes to ensure product technical requirements are met. The intent of these specifications
must ensure robust control and monitoring of the many outsourced functions contracted by most
operators.
The organization providing these operational functions to the Operator always remains responsible to
their own management structure and regulatory authority, however the primary IOSA assessment
cannot be applied to the third party organization (Service Provider) providing the outsourced service.
When assessing any function that has been outsourced, a conventional assessment of conformity
cannot be used. The audit methodology then changes to a verification that the Operator is carrying out
adequate oversight of the outsourced function(s) and that the Operator is ensuring that the
requirements are being met. To verify the effectiveness of the oversight, and determine what is
occurring in practice, the auditor can access the relevant Service Provider(s) to collect evidence to
support the assessment of the requirements, refer to IPM 8.7.1 (v).
Confirmation of effective oversight by the Operator can be a challenge, due to the wide variety and lack
of standardisation of the methods used. Certain outsourced functions have historically been a source of
IOSA quality problems, due to a lack of understanding of the need to verify oversight. For example:
(a) Confirmation that an operator is carrying out oversight of its larger affiliate operator for outsourced
(shared) ground handling, dispatch or similar functions.
(b) Ensuring that an adequate standard exists for training which has been outsourced.
(c) Mandatory State control over, or outsourcing of, key security functions.
ORG 3.5.2 specifies that the Operator must have a processes for the monitoring the external Service
Providers of outsourced functions; however the level and type of oversight activity for outsourced
functions is not specified (the recommended practice ORG 3.5.3 specifies auditing should be used);
since there are many methods to conduct oversight, auditors must assess whether the level and type of
oversight is adequate, effective, and ensures that all safety and security requirements are being
satisfied.
The oversight by the operator, of the external Service Providers of outsourced functions, must include
all stations and locations used by the operator at which the function(s) are active, see 4.2.8 on
Systemic Assessment.
The documentary reference for each ISARP:
(a) will include that of the oversight process in use by the operator for the outsourced function;
(b) should include, where relevant, a document reference to the operator's controlled documentation
that addresses the ISARP requirements directly; and
(c) may include a reference to the audit checklist used for the oversight audits/inspections.
Note:
The referenced checklist must be a controlled document, and must not be simply a ‘copy and paste’
directly from the ISM.
Whenever the requirement(s) of an ISARP are associated with an outsourced operational function, the
usual AAs may not apply, and care must be exercised in applying the possible AAs.
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Nonconformities identified in outsourced function are raised against the operator, and cannot be raised
against the Service Provider(s). Auditors need to use their judgment to determine the most appropriate
ISARP against which to raise the nonconformity. If there are numerous deficiencies, which are
significant and not just a one-off deficiency, identified in the oversight process, it may be more
appropriate to raise the nonconformity against the quality assurance ISARPs. If the deficiencies are
associated with the technical requirement, the nonconformity must be raised against the specific
ISARP itself.
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Operators that participates to the ISAGO program enter into an ISAGO Airline Membership Agreement
to subscribe to receive access to ISAGO Audit Reports as they become available and may view or
download the document from the ISAGO Registry. An annual subscription gives unlimited access to all
ISAGO Audit Reports and also an Operator that does not subscribe to receive access to ISAGO Audit
Reports may purchase a report on an individual basis.
ISAGO registration is an acceptable mean as part of the Operator's monitoring process, provided the
Operator has requested the latest of the applicable audit report(s) through official program channels,
and has considered the content of the report(s) in its monitoring process.
If the ISAGO Audit Reports are not acquired by the operator through the official channels, the IOSA
Auditor cannot accept the reports as evidence of monitoring and conformance with ORG 3.5.2 and/or
ORG 3.5.3. Annual subscription agreement or adhoc purchase proofs are required to be observed.
Furthermore, just awareness of the GSP’s ISAGO registration or possession of a copy of the
registration certificate are not acceptable means of monitoring. The operator has to demonstrate that a
valid ISAGO audit report obtained through official channels was used in the operator’s monitoring and
risk management processes. A valid ISAGO audit report means a current headquarters, combined or
station audit report that covers the ground operations within the scope of ISAGO provided by the GSP
to the operator.
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The Mandatory Observations are a means to collect further evidence to assess implementation.
However, if the Mandatory Observations identified areas of concern or a potential nonconformity, the
auditor always has the option of increasing the sample size by conducting one or more additional
observations. This is encouraged, as such additional sampling could help substantiate the previous
observed evidence leading to an assessment of a nonconformity. Any nonconformity will be raised
against the relevant provision or sub-provision, and generally will contribute to the assessment of
implementation as a nonconformity.
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GRH Example
If Ground Handling is outsourced, Mandatory Observation MO-12-GRH Aircraft Loading Operations,
then this may be carried out by assessing the operator's monitoring of aircraft loading on the ramp
or, by observing the operation of the service provider.
This may include, but not limited to:
(a) observing the loading of the aircraft by the service provider;
(b) observing how the Operator's Airport Manager ensures oversight, particularly if he/she sampled
and/or observed the ramp operations around the airport;
(c) observing a periodical ramp inspection and completion of an associated checklist; and/or
(d) observing the Operator's Airport Manager's weekly meeting on the performance and challenges
of ramp operations.
MNT Example
If the Continuous Airworthiness activities are outsourced, Mandatory Observation MO-7-MNT AD/SB
Management, then this may be observed by observing the Operator's approval and authorization
steps in the AD process, as well as the oversight and monitoring activities for AD/SB management.
This may include, but not limited to:
(a) observing the process of how the Operator's Maintenance Post Holder or his staff:
1. ensures that all AD/SB are monitored for potential applicability;
2. is made aware and approves the assessment of applicability and actionability of an AD;
3. approves the Engineering Order to undertake the tasks, on the Operator's aircraft, as
specified in the AD;
4. is made aware of the completion of the incorporation of the AD on the Operator's aircraft;
5. control the process to ensure all the applicable Operator's aircraft have had the AD
incorporated; and
6. notify the authorities, as required, that the AD has been incorporated on all the applicable
Operator's aircraft within the time frame specified on the AD;
(b) observing a meeting between the Operator's engineering staff and the Continuing Airworthiness
Management Organization on the status, management and control of AD/SBs which should
include the key steps above;
(c) observing how the engineering staff vet the assessment of applicability and actionability and/or
the Engineering Order; and
(d) observing how the operator ensures that no AD/SBs are missed.
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For example MO-16 for Security Management does not have entry fields in Mandatory
Observations of the Audit Summary, so it would be added in the ‘Additional Operations Assessed’
field.
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IOSA Checklist. Such information may serve as documented factual evidence that supports a Finding
or Observation.
The Line Flight and Simulator Checklists are supplementary working documents, and will be destroyed
at the conclusion of the Audit.
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5 Other SMS Provisions, the remaining SMS ORG provisions, listed in Table 3 of the IAH
Interlinked and Repeated ISARPs, are not repeat provisions, they are stand alone. These
provisions are generally assessed independently of other provisions.
However, some of these provisions specify implementation throughout the organization. To
finalize the assessment for each of these provisions, the ORG auditor will require input of the
assessment from the other disciplines, to evaluate the level of implementation within and, for the
example of communication, between all departments or functional areas throughout
the organization. The determination of conformity is in accordance with 4.2.15.
6 If not involved in CAR closure and audit finalization, ensure a comprehensive handover of the
overall SMS assessment and corrective actions to the auditors who will be closing the CARs.
Note:
SEC 1.3.1, 1.9.2, 1.10.1, 1.10.3A and 1.12.1 are not designated as SMS, but as provisions repeated
from ORG, are subject to the procedures detailed in IAH 4.2.15.
Additionally, there are existing standards for the Quality Assurance programs in all disciplines, except
SEC, which have been designated as [SMS] provisions, due to the complementary functions between
QA and SMS structures. These provisions are still classified as repeated provisions, linked by the “►◄
and > <” symbols in the ISM and audit checklist respectively. Because operators may manage their QA
programs separately to their SMS structure, an IOSA requirement for a linked assessment of all QA
programs in all disciplines could be seen as exceeding the initial scope and intent of introducing SMS in
IOSA, therefore there are no specific linked assessment requirements for this group. To accommodate
known variations in QA/SMS structures/relationships between operators, auditors have the flexibility to
assess QA and SMS structures either as:
(a) operating independently as separate entities, with operational overlaps where necessary; or
(b) integral components of the overall SMS structure.
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ORG 1.6.6 is a logical extension of ORG 1.6.5 and applies to any external service provider that
performs services for the operator within the operational scope – again, not including any services
which do not fall within the scope of an IOSA audit.
The training must extend to direct sub-contractors, as well as any potential third parties which perform
service on behalf of the sub-contractor. Ultimately, any operational person performing duties within the
scope of the IOSA audit for a particular operator should be trained on SMS, irrespective of which entity
this person has a contract with.
The actual training can be performed in any way deemed appropriate by the operator. The key is that
the operator must specify its own needs for the training and should then ensure that any sub-contracted
organization meets these training requirements. This can be done in a number of different ways, for
example:
(a) by accepting the sub-contracted organization’s own training, if this organization has an SMS, for
example
(b) by recognizing other training delivered by a third party
(c) by providing the operator’s training to the sub-contractor (could also be in the form of a web-based
training)
(d) by inviting the sub-contractor’s personnel to attend operator trainings
The key is that operator first must specify what the training should contain through its own training
requirements, and then ensuring that the sub-contractor’s personnel have received those same
subjects through any of the channels described above. The implementation is ensured and monitored
through the same channels and methods as any other operational service/requirement which is
subcontracted to that organization.
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equipment is installed on the applicable aircraft groups. An operator's Aircraft Operating Manual
(AOM), the Minimum Equipment List (MEL) and Aircraft Illustrated Part Catalogue (AIPC) typically
contains aircraft fitment and other reference information (e.g. equipment description, specifications,
locations) that could serve as the documentation reference for IOSA aircraft systems and equipment
requirements.
If an operator's Aircraft Operating Manual, General Operations Manual, MEL or other parts of the OM
do not contain system descriptions linked to specific aircraft or lists of installed equipment (per fleet or
per aircraft), an auditor may have to look elsewhere for suitable evidence. For example, Illustrated
Parts Catalogue (IPC) and Layout of Passenger Accommodation (LOPA) as long as it specifies the
alternate equipment that is fitted to the specific aircraft group. Alternatively, this information may have
to be extracted from aircraft maintenance records, airworthiness review records, aircraft inspection
records, engineering orders, work orders or other records. Meanwhile, it is important to highlight the
source of the reference shall be a controlled document.
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Method of The method of verification is the method that was used to assess the aircraft system or
Assessment equipment requirement, to be selected from the drop-down menu:
(a) If the aircraft system or equipment requirement was assessed by directly
inspecting the aircraft, then ‘Inspection’ must be selected.
(b) If the aircraft system or equipment requirement was assessed through being
documented in a controlled manual, then ‘Documentation’ must be selected.
(c) If the aircraft system or equipment requirement was assessed by examining the
maintenance records, then ‘Maintenance Record’ must be selected.
(d) If any other method is used, ‘Other’ must be selected, stating the method used in
the comment field.
AO Verify This field must be completed by IOSA auditor when verifying the assessment made by
the operator.
Reference The reference field is used to record any document or record that demonstrates
conformity.
If ‘Documentation’ or ‘Maintenance Records’ (or ‘Other’ method involving a record or
document) has been selected, then a reference must be entered.
Comments The comment field is used to add comment or narrative from the auditor undertaking
the assessment.
If ‘N/A’ is selected for ‘Assess’, the comment field must state the reason of ‘N/A’.
If ‘Other’ is selected for the method of verification the comment field must state the
other method that was used to verify the conformity of the requirement.
1 Every aircraft system or equipment requirement (in each row of the table) must be verified, by
checking:
(a) the referenced document;
(b) the referenced record; or
(c) through visual inspection during the Mandatory Observation or other aircraft inspection.
2 When verifying the assessment made by the operator for each aircraft system or equipment
requirement (in each row of the table), sampling of the implementation of the requirement
across aircraft groups (in the columns of the table) may be applied.
If sampling the aircraft groups is utilized, the selected aircraft group being sampled must be
varied between aircraft systems and equipment requirements, to represent all aircraft groups.
3 The IOSA auditor must verify the operator’s assessment, recording the verification in the ‘AO
Verify’ field by using the drop down menu.
The verification is an assessment by the IOSA auditor of conformity, select:
(a) ‘Yes’ for conformity;
(b) ‘No’ for non-conformity; or
(c) ‘N/A’ for not applicable.
The ‘AO Verify’ field must only be completed for the aircraft types that were sampled.
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4 When the verification is complete the IOSA auditor must complete the relevant ISARPs in the
audit checklist.
If a deficiency of the aircraft systems and equipment has been identified, it must be recorded as
a nonconformity for the relevant ISARP, specifying the table line item and details of the
deficiency in the narrative.
If all verified aircraft systems and equipment requirements have been in conformity, then the
relevant ISARPs must be recorded as conformities.
5 The IOSA auditor must utilize the repeated and interlinked ISARP report to harmonize the
aircraft systems and equipment assessments.
6 The document reference in the audit checklist must refer to the Aircraft Systems and Equipment
Forms, quoting the form numbers (ISM.F02 or ISM.F03).
In the comments field the following statement must be entered:
Refer to the complete forms for the associated document references.
7 The IOSA auditor must attach and upload the completed forms (in MS Excel) into the audit
software under the ORG audit checklist.
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Europe, the application date is the date the OEM applied to the FAA for Type Certification. The
application date will be different to the actual date of the Type Certification and is generally listed on the
Type Certificate Data Sheet.
Note:
Not all Type Certificate Data Sheets list the application date for Type Certification, it may be listed
separately or found in the text under the certification basis. In the event that the application date is not
recorded, the approval date will suffice.
For any applicable ISARPs that reference aircraft certification, the auditor must take the Type
Certification application date of the exact variant of the aircraft that is being operated as listed on the
operator's AOC. To assist in this assessment, for the State of Manufacture for more common OEMs,
the typical sources obtaining application dates for type certifications or the dates of type certifications
are listed below (this list is not exhaustive).
(a) Transport Canada: http://wwwapps.tc.gc.ca/saf-sec-sur/2/nico-celn/c_s.aspx?lang=eng;
(b) FAA: http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgMakeModel.nsf/Main
Frame?OpenFrameSet;
(c) EASA: https://easa.europa.eu/document-library/type-certificates;
(d) UK: http://www.caa.co.uk/default.aspx?catid=1419&pagetype=68&gid=1540; and
(e) Brazil: http://www2.anac.gov.br/certificacao/Produtos/EspecificacaoE.asp.
The MNT auditor to clarify aircraft certification details, as required, as the certification records may be
kept in the flight, engineering, or maintenance departments.
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Generally, the ADs will specify an action to take if the inspected component was at risk of failure, or
beyond acceptable limits. Normally, the action will be to remove and replace the component with a
serviceable component or an alternate component. In some cases there may not be an alternative, and
in some cases the action taken is to inspect or remove the item without a replacement action identified,
pending action by the OEM to rectify the fault. In these cases where the component or item of
equipment is removed and not replaced, the affected fleet/aircraft may become nonconforming with an
aircraft equipment ISARP.
Evidence of this situation should be collected from the operator, in the form of the AD and the
assessment of applicability on which fleet/aircraft. Reliability on the State of the operator's AD alone is
not always prudent, therefore the AD must be as a direct result of an AD issued by the State of
Manufacture or the State of Design, which should be referenced in the AD or attached (if not attached
collect it as part of the evidence). This ensures that there has been some official engagement with the
OEM which increases the credibility of the AD.
In these cases when the operator is complying with the AD from the Authority resulting in a
nonconformity with an ISARP, the ISARP or a portion thereof may need to be exempt, see
IPM 7.1.9 (iv).
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The Performance-based compliance allows greater operational flexibility without degrading the
safety performance of an operational activity. It is dependent on other systems, policies, processes
or procedures and the specifications contained in a regulation typically define “what” must be
accomplished and allow for variations in “how” it is accomplished.
Performance-based compliance is not a new concept. The following are existing performance-
based concepts:
(a) Advanced Qualification Program (AQP)/Advanced Training and Qualification Program
(ATQP)/Evidence-based Training Program (EBT);
(b) Extended Range Operations (ETOPS)/Extended Diversion Time Operations (EDTO);
(c) Safety Management Systems (SMS);
(d) Fatigue Risk Management Systems (FRMS); and
(e) Statistical Contingency Fuel (SCF).
In a performance based compliance system, the operator (and the auditors) must ensure the
following essential elements are in place:
(a) Statistical data and analysis to prove the compliance and to seek variations;
(b) Safety data analysis, based on the statistics;
(c) Monitoring of hazards and risks on a real time basis;
(d) Risk assessment and mitigation systems;
(e) An approval from the regulator for the performance based compliance; and
(f) An oversight system to ensure that the conditions of the approval by the authority are met.
In the absence of any of these, a ‘performance based compliance’ may not be possible and an
auditor must not accept the same.
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Yes
No
No
Yes
No
Yes Finding
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4.11.1 General
The method for auditing the effectiveness of implementation must be applied to all ISARPs which have
been marked with the designated Symbol in the ISM. The methodology is made up of the following
components:
(a) a set of ground rules;
(b) an umbrella ISARP, which captures the overall state of effectiveness;
(c) the Assessment Tool, which contains all the items which need to be verified by the auditor, to
include:
1. Desired Outcome
2. Suitability Criteria
3. Effectiveness Criteria
(d) special recording requirements.
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can be verified – generally of qualitative nature. The desired outcome however does not provide very
detailed requirements or expectations. To discuss the desired outcome, the auditor needs to change
the course of questioning and interviewing from verifying specific pieces of evidence, to asking more
globally how the operator accomplishes this desired outcome and which factors contribute to reaching
this outcome. There is no formal assessment or recording of the Desired Outcome discussion - it is
there primarily to set the framework and to start the discussion.
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Start
No
Yes
No
Yes
Does the Authority allow the use of amended document to be used prior to
the approval or acceptance?
No
Yes
Does the amended document require the users to undergo training
in order to implement the amended process/process,
which has NOT been completed?
Yes
No
Has the operator effectively distributed the amended document to all users ?
No
Yes
Is there an “effective” date for the amended document that is after the date
of the closing meeting of the audit?
Yes
No
Auditor judgement
End
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IOSA provisions that require regulatory/State approval or acceptance contain the phrase: “... approved
or accepted by the State ...”, as per the IATA Reference Manual (IRM) Glossary definition. If an IOSA
provision requires regulatory/State approval of a manual or function, but it is evident that the
regulatory/State approval process in that region is not active, there may be an effect on the audit result
which is beyond the control of the operator.
Note:
Auditors must consider that amending internal documentation is part of an operators function; the
presence of IOSA auditors cannot interrupt that process, effectively, manuals can be revised at the
discretion of the operator; the auditor must check that due processes have been followed.
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(d) Use of the analysis. Check how the analysis is passed to the Fleet office and the Training office. Is
it confidential?
(e) Proof of action taken. Check on who takes action, and how do they do it; it could be done directly
by safety department or via the unions or via gate-keepers. Or it could be done by the flight ops
department.
(f) Follow up actions by the Safety department. Was there an improvement? How did safety
department measure the improvement?
4.12.5 Auditing Continuing Airworthiness Information, Repairs & Modification (ADs, SBs, MEL, and
etc.)
An Airworthiness Directive is a document issued or adopted by the relevant Authority, which mandates
actions to be performed on an aircraft to restore an acceptable level of safety when evidence shows
that the safety level of this aircraft may otherwise be compromised. Following best practices should be
considered by MNT Auditors for auditing continuing airworthiness information, including Airworthiness
Directives (ADs), Alert Service Bulletins and recommendations. (MNT 2.5.1):
(a) Check the latest relevant ADs applicable to the airframe, engine(s), propeller(s) and equipment
through Authority websites such as EASA Safety Publication Tool https://ad.easa.europa.eu/ and
FAA Airworthiness Directives https://www.faa.gov/regulations_policies/airworthiness_directives/
and ensure that applicable ADs (including their revisions) are obtained, assessed and have been
incorporated in the AD-status.
(b) While sampling within the current AD status that applicable ADs have been or are planned to be (as
appropriate) carried out within the requirements of these ADs; IOSA MNT Auditors should at least
sample one record from an Open, a Repetitive and a Closed AD as deemed necessary.
(c) Examining a maintenance record relevant to an AD should include a review of task-cards correctly
reflect AD requirements (latest revision) or refer to procedures and standard practises referenced
in ADs. This is important, specifically when the manufacturer task card system is not used and
Service Bulletin (SB) referred in the AD has multiple revisions.
(d) Auditor should review AD status and if available, sample an AD for which compliance can be
physically checked and review during MO-5 Line Maintenance Observation. (As of 1 September
2021)
Minimum Equipment List (MEL) is a list that provides for the operation of an aircraft, subject to specified
conditions, with particular equipment inoperative, prepared by an Operator, and approved by the
Authority, in conformity with, or more restrictive than, the MMEL established for the aircraft type.
Following best practices should be considered by MNT Auditors for auditing MEL ISARPs (MNT 2.4.2,
MNT 2.4.3 & 2.5.3):
(a) MEL is required to be audited and necessary records to be examined for all applicable aircraft in
the operator's fleet.
(b) When an MMEL item refers to the regulations (as required by regulations, as required by FAR, and
etc.); IOSA Auditor should check this wording to ensure that the MEL is customized appropriately.
(c) When an MMEL item requires alternate procedures to be established by Operators, IOSA Auditor
should check this wording to ensure that MEL is customized appropriately.
(d) If possible, when examining the selected records of MEL usage requiring maintenance activities,
IOSA Auditors should check repetitive maintenance actions required to be performed prior to each
flight or within a time interval.
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(e) Selected records of MEL/CDL restricted items should not be sampled solely through the
maintenance records system, but also shall be observed and examined during MO-5 Line
Maintenance Operations. This shall include checking if rectification interval expiration, reviewing
maintenance procedures applied when required, and/or visual observation of MEL items if
applicable. (As of 1 September 2021)
In auditing repairs and modifications, the following best practices should be considered by MNT
Auditors (MNT 2.6.1) (As of 1 September 2021):
(a) Selected records of aircraft modification(s) and/or repair(s) should not be sampled solely through
the maintenance records system, but also shall be observed and examined during MO-5 Line
Maintenance Operations.
(b) This shall include sampling repairs on the sampled aircraft and then comparing with relevant
records afterwards. MNT Auditor may take notes or photos of the repairs and/or modification as
necessary for a better examination of the records.
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5.2.1 Applicability and Conditions for Auditing Suspended or Partially Suspended Provisions
(a) The procedures below must be used when an IOSA Provision, or a specification within an IOSA
Provision, is suspended in accordance with the IOSA Standards Special Review Process, as per
IPM Figure 1.4 and Section 8.12.
(b) When an IOSA Provision or a specification within an IOSA Provision comes under special review,
the Provision is normally suspended until such time as the IOSA Standards Special Review
Process is completed.
(c) Irrespective of the procedures followed below, all listed nonconformities remain included in the total
Findings/Observations in the Audit Summary.
If a nonconformity has been raised against a provision that has been suspended subsequent to the
audit, the following procedures apply:
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2. An open Finding against an IOSA Provision solely as a result of a nonconformity with the
suspended specification(s) within that Provision
1 The CAR is retained as the existing evidence record of the finding and completed as follows:
2 The RC, CAP, FAT remain blank.
3 Insert the following statement at the end of the ‘Final review and Acceptance’ section, including
the name and date: “The specification(s) within this Provision which resulted in this Finding
being generated have been suspended in accordance with Figure 1.4 of IPM Ed NN (number to
be inserted). This Corrective Action Record is no longer applicable but will remain as part of the
audit record.” In the verification of corrective action.
In all situations, if the ISARP has been changed to N/A as a result of a suspended ISARP during or
after the audit, a statement must be entered into the Additional Information of the Audit Summary form
(see 2.7.3). The statement must reflect the applicable statement as specified above.
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Example 1
The operator has a Finding in MNT 2.9.1 for the inspection of the FDR/CVR.
In order to complete the final corrective action of conducting the inspections, an Engineering Order
and approval is required. Additionally, the Approved Maintenance Program is required to be
amended to incorporate the inspection requirements, and requires approval. While the approval an
Engineering Order and the Approved Maintenance Program may be forthcoming before the due date
to have the CARs closed, the conducting of the inspections based on these documents on a fleet of
80 aircraft is unlikely to be performed before the due date due to operation restrictions and
scheduling.
Interim Corrective Action is applied for by the AO and approved by IATA.
The interim corrective action is the approved Engineering Order, Approved Maintenance Program,
the inspection schedule showing all aircraft to be inspected and when, with some of the inspections
completed.
The final corrective action is evidence that all the aircraft have been inspected, which is then to be
verified by the AO.
Example 2
The operator has a Finding in FLT 2.2.27 for the training and evaluation of flight crew in normal and
non-normal procedures, that demonstrates competence of each flight crew's competence during
recurrent training.
In order to complete the final corrective action, it is required that all 114 flight crew undertake the
training and evaluation in normal and non-normal procedures, and the training manuals are updated
to reflect this requirement in the recurrent training program. While the amendment and approval of
the Training Manual may be possible before the due date to have the CARs closed, it is unlikely that
all the training and evaluation will be conducted before the due date due to flight crew scheduling
and operational restrictions.
Interim Corrective Action is applied for by the AO and approved by IATA.
The interim corrective action is the approved amended Training Manual and the training schedule
showing all flight crew and when they will undertake the training and evaluation, with some of the
flight crew having completed the training and evaluation.
The final corrective action is the evidence that all the flight crew have undertaken the training and
been evaluated as competent, which is then verified by the AO.
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Interim CAR
1 The “RC” is completed conventionally.
2 Under the CAP, the “Interim Action” and “Corrective Action” fields will be selected, describing in
“Corrective Action Plan” field on the interim corrective actions which were planned and taken to
close the CAR on a temporary basis.
3 Under the Final Action Taken (FAT), the “Submitted by” and “Date of Final Action Taken” fields
must remain blank. The FAT field must include the standard phrase “See Interim Action Taken”.
The “Action Taken By” fields must contain an AO Representative name.
4 The “Verification of Corrective Action” under the “Final Review and Acceptance” must include
detailed evidence of the temporary corrective action verified by the AO.
A statement that the Interim CAR has been closed based on the interim corrective action taken
by the Auditee shall be included.
5 The Audit Report is then closed in the conventional way.
Final CAR (the second CAR is raised)
Note:
The Interim CAR, Audit Summary and other sections of the audit are not to be modified at all.
1 The Audit Report is opened; contact IATA Quality to perform this function.
2 The RC from the Interim CAR will be repeated verbatim.
3 The “Final Action” will be selected under the CAP, describing the final corrective action
implemented by the Auditee and the verification done by AO.
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4 The “Verification of the Corrective Action” under the “Final Review and Acceptance” must
include detailed evidence of the final corrective action verified by the AO.
A statement that the Final CAR has been closed based on the final corrective action taken by the
Auditee shall be included.
Note:
The verification of implementation must be conducted in a conventional manner or it may require
100% sampling, refer 4.3.2 on sampling.
5 As per IPM Section 8.10.5, AOs shall notify IATA in writing within seven (7) days of verification
of implementation of final corrective action(s), which must occur within the period of 120
calendar days following the expiry of the current registration.
Procedure if a Permanent Corrective Action is Verified before Audit Closure
If a final Corrective Action for the finding is confirmed before audit closure, the use of this IPM option
will become inapplicable and a single CAR will be completed conventionally. In this case, the original
text in the “Interim Corrective Action” fields in the CAR will remain and the following standard text
must be inserted:
The Interim Corrective Action option will no longer be used. Refer to the Planned and Final Corrective
Actions below.
5.5.1 Applicability
Active Implementation (AI) permits an operator to be in conformity with a designated IOSA Standard,
based on active execution of an acceptable Implementation Action Plan (IAP).
Only certain IOSA Standards will be specifically designated for the application of AI. Such standards
will have always have undergone a risk analysis, the results of which must indicate that application of
AI to the particular standard will not create an unacceptable operational risk.
An IOSA Standard that has been designated under AI will be clearly identified in the ISM and on the
IOSA Checklist. The following phrase will always follow a designated provision in the ISM: “An operator
may conform to this provision through Active Implementation”.
Completion of the proposed IAP must project conformity with all technical specifications contained in
the designated IOSA Standard, including deadline dates for achieving conformity.
Application of AI to designated standards is not mandatory; the option will normally be used following
an assessment of corrective action options by the AO & operator. The audit team will then assess
conformity with the relevant designated standard(s), in accordance with the guidance that follows.
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(c) Acceptable evidence that permits the auditor to verify that execution of the IAP is actually
underway. An operator that is unable to prove to the Audit Team that execution of an IAP is
underway does not meet the criteria for having its IAP accepted under AI. Unless prerequisite
conditions specify otherwise, acceptable evidence may include:
1. executed contracts with external organizations for work to be accomplished, equipment to be
purchased or training to be conducted;
2. components, parts or material that has been acquired by and/or is in possession of the
operator;
3. specified equipment having been installed on a number of applicable aircraft;
4. some or all applicable personnel having completed specified training.
The IAP must meet the following requirements:
(a) Specify a projected date of completion; which must be in accordance with applicable prerequisite
conditions, if any.
(b) Contain a detailed schedule of all work or activities necessary for the operator to complete the plan
within the planned time period.
(c) Identify a series of progress milestones over the total duration of the plan that permit a comparison
of actual work completed against the projected work schedule, to allow the AO to assess if the IAP
is progressing toward completion according to the schedule. Progress milestones will be stated as
future dates, by which a defined amount of work is projected to be complete, and will be spaced at
intervals of 6 months or less.
(d) Detail all equipment, components, material or any other physical resources necessary to complete
the plan.
Example 1
If the designated standard specifies installation of aircraft equipment, the IAP must:
(a) Include an acquisition schedule of all specified components and all other parts or material
necessary to equip the applicable aircraft.
(b) Map out projected installation schedule dates for all applicable aircraft in the operator's fleet as
identified by registration or tail number.
(c) If the designated standard specifies training for certain operational personnel, the IAP must:
1. include all resources necessary to complete the training of all applicable personnel.
2. show projected training dates for all applicable personnel.
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Examples:
Note 1: Enter the specific dates for subsequent progress milestones within the 24 months following the
date of the Closing Meeting.
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contact the AO, who in turn, shall contact IATA for approval. If approved by IATA, a telephonic approval
must be followed by a formal request and approval.
During the audit, AOs should keep IATA updated on the progress of the Verification Audit, and advise,
in confidence, of any serious deficiencies that were noted during the VA.
When auditing linked or repeated provisions, the assessment of the related ISARPs shall be limited to
only those ISARPs that fall within the IATA defined scope of the VA. AOs must assume that the
provisions that are linked or repeated in disciplines that are outside of the scope of the VA, continue to
remain in conformity (as in the previous IOSA audit of that operator). This must be stated in the
Additional Information of the Audit Summary form with the following standard statement:
‘Interlinked and repeated ISARPs that fall within the scope of the Verification Audit have been assessed
as part of this audit, any that do no fall within the scope of this audit have not been assessed and are
considered to be in conformity as per the last audit report, refer to IOSA Auditor Handbook –
Procedures and Guidance’.
Mandatory Observations that have been designated for the Verification Audit, must be performed in the
conventional manner. However, if there is a nonconformity arising from the MO, then the
Finding/Observation must be raised against the ISARP whether within the Verification Audit specified
scope or not.
Note:
IATA reserves the right to send an Observer to witness the Verification Audit, at the last minute, with
limited prior notification.
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International Air Transport Association
ISBN 978-92-9264-372-0
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