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Presented By: Norm Sanders, Airport Manager Dryden Regional Airport Joe MacKay, Vice President, Aviation WSP Canada Inc. PVI / Your Audit Findings AMCO 2014. Overview. Background Areas to be audited or subject to a PVI Conducting the Audit/PVI
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Presented By: Norm Sanders, Airport Manager Dryden Regional Airport Joe MacKay, Vice President, Aviation WSP Canada Inc. PVI / Your Audit FindingsAMCO 2014
Overview • Background • Areas to be audited or subject to a PVI • Conducting the Audit/PVI • Tips for preparing for a PVI or Audit • Common types of audit findings • How findings are delivered to an airport • What should be included in the finding • What to do when a finding is unclear • Lessons learned • Next steps
Areas to be Audited/ Subject to a PVI • Activities authorized under a certificate need to be audited (also subject to a PVI): • Wildlife Management Program • Emergency Response Plan • Obligations of the Operator • Airport Operations Manual • TP312 • ARFF • Safety Management System • Quality Assurance • Winter Maintenance Inconsistency across Canada on whether “Activities” means 100% of the Regulated Areas need to be reviewed or 100% of All Regulations/Standards
PVI • Background Materials • Surveillance Procedures: SUR-001 Issue 5 • SSI (Civil Aviation Ontario Region): SUR-001-P Issue 2 Focusing on Findings
PVI • Program Validation Inspection (PVI) – a focused review of one or more components of an organization or Safety Management System • Notice received about 6 weeks ahead of time • Notice often sent to the AE (same with the final report) Should also be sent to SMS Manager or the Airport Manager • Past: • Inspections • Now: • Surveillance procedures • Assessing an organization’s ability to hold itself accountable for its own compliance • Compliant with the regulatory requirements, processes being used and are effective
PVI Findings Form • The output of a PVI is findings of non-compliance
QA Audit Finding Form • Use for an Internal QA Audit • Outline details of the audit • Problem statement • Evidence
Preparing for a PVI or Audit • Ask TC or Auditor what they intend to review • Review all relevant manuals/documents: • Updated/reviewed as per the CARs requirement or written processes • Copies of relevant SOP’s • Updates distributed to the proper individuals/organizations • Copy of Most Recent QA (Internal) Audit Report • Make sure we have recorded: • Who did it • When they did it • What was audited
Preparing for a PVI or Audit (Cont’d) • Staff training records: • Current as per CARs or written processes? • Confirmation of content of training • SMS Reports/ Previous Audits /PVI Findings • Corrective action plans complete • Follow up complete Make sure what we actually do matches what we say we are going to do
Common Findings: AOM • Obligation of the operator relating to Human and Organizational Factors training is not enumerated in the AOM • Description of the SMS components missing • Geographic coordinates are not given to the nearest 1/10th second • Aerodrome data inaccurate and/or not presented in accordance with requirements
Common Findings: TP312 • Preventive maintenance program and inspection records incomplete • Potential OLS violations • Transition plates on navigational aids are elevated above grade defeating their frangibility.
Common Findings: TP312 • Erosion at runway/taxiway edges • Alignment and aiming of threshold/end lights
Common Findings: Wildlife Plans • Wildlife Plan • Lack of or limited consultation with a representative number of operators that use the airport • Incomplete processes (not feeding wildlife, accounting for endangered species, communication procedures) • Reporting wildlife strikes to Transport Canada
Common Findings: Emergency Plans • Emergency Plan • Emergency exercises not completed and/or incomplete records of emergency exercises • Duties and procedures of the On-Scene Controller are not provided • Older templates might not reflect current regulations, therefore missing some areas (training and qualifications, communication procedures and radio frequencies, adverse climatic conditions and darkness)
Common Findings: SMS and ARFF • SMS • SMS report form not completed all the way through to corrective actions • Monitoring corrective actions and follow up • Updating and monitoring goals and objectives not complete • Completing Management Reviews and Reporting to the AE • Trend Analysis incomplete • ARFF • ARFF training not completed within the mandated three (3) year cycle for recurrent training
Types of findings (PVI) • Minor: Activity is being maintained and demonstrated to be effective, however requires administrative enhancement. • Moderate: Activity not being fully maintained with examples of non-compliance indicating that it is not fully effective. Airport has clearly demonstrated the ability to carry out the activity and a simple modification to processes are likely to correct the issue. • Major: Activity has not been established, maintained and adhered to or is not effective, and a system-wide failure is evident.
Types of findings (QA Audit) • Level 3: Observations that are likely to impact safety or become a regulatory issue before the next audit. • Level 2: Failings that require resolution within a fixed and predetermined time period. • Level 1: Serious discrepancies with respect to regulatory requirements.
Delivery of Findings • During the Audit • Daily briefings • Final exit briefing Provides opportunity for an airport to review findings to determine if they are reasonable • At this stage a finding could incorrectly be identified because of a misinterpretation and/or some information may have temporarily been missing
Delivery of Findings • Final Report • Findings should be detailed • Clearly describe the state of the airport’s systems and how they resulted in non-compliance to regulatory requirements • Sufficient evidence to support observations and any findings of non-compliance • Factual EVIDENCE or EXAMPLES that will validate the finding • Link back to a specific regulation Require enough detail to develop a corrective action plan
Unclear Findings • As per SUR-001, a finding should: “Provide sufficient narrative information such that the enterprises can clearly understand the nature of the systemic failure which led to the finding and its associated non-compliances and develop adequate CAP” • If a finding is not clear: • Seek clarification from TC or your Auditors • Ask for more examples/evidence to support the finding
Things We Learned During the Audit/PVI • Ensure documentation is current • TP312 requirements are in order • Markings are in good shape • Lighting maintained and aligned • Overall field looks good • OLS has been checked and is in good shape
Next Steps • Agree on findings: • Audit Findings • PVI Findings • Next Steps: • Developing Corrective Action Plans • Including an Investigation and Root Cause Analysis
Thank You Norm Sanders, Airport Manager Dryden Regional Airport P: 807 937 4959 E: nsanders@dryden.ca Joe MacKay, VP Aviation WSP Canada Inc. P: 519 571 3255 E: joe.mackay@wspgroup.com