Over the past several weeks, I’ve presented several concerns frequently uncovered during third party audits of Part 135 operators, including ineffective internal evaluation programs; flight and duty issues for flight managers; errors in pilot training records; questionable use of “safety pilots”; and more. Here are some other tips for ensuring a happy audit:
1. Know Your Objective
What do you want to get out of this audit? If we’re all honest with each other, we know different audits have different meanings within your company. Is this a marketing move so you have a logo on your website? Does a particular client require the audit? Are you looking for an critical review of your safety program or operations? Do you want to improve operational processes?
None of these objectives are necessarily “wrong” or “bad”, although I don’t recommend telling the auditor you need a logo on your website so make it snappy. Most auditors will figure out your objective on the first day anyway. (True story: I once had four people ask me on the first day of an audit if we could finish the audit a day early. The main contact on that audit darkened the door of the conference room every afternoon promptly at 4:58, asking if the maintenance auditor and I were finished for the day. The operator’s staff wanted to leave at 5 whether we were finished for the day or not.) Your objective shouldn’t change the quality or content of your audit but it should help you gauge the resources you want to put towards the audit and any subsequent findings.
2. Be Prepared
You get the best quality audit if you are prepared. Complete the pre-audit checklist if the audit standard organization provides one. If a pre-audit checklist isn’t provided, complete the actual audit checklist to see where you stand. Close any gaps you identify before the auditor arrives. Send the auditors the checklist and relevant manuals at least a couple of weeks in advance, if it’s part of the standard protocol for this type of audit. It’s important for them to be prepared for the audit too.
Double check the revision status of your documents. Make sure you send the auditors current versions of documents. I’ve arrived to an audit before with an electronic rev 8 of the SMS and been given a hard copy rev 8 of the SMS. The documents didn’t match, even though they were both rev 8. Double check your revision numbers to make sure everyone is on the same page – literally.
3. Be Available
Be sure appropriate individuals (the Accountable Executive, Director of Operations, Director of Maintenance, Chief Pilot, and director of safety if you have one) are scheduled to be in the office for at least part of the audit. This is not a good time for the Accountable Executive to go on vacation or the DO to go to school for a week. If any critical personnel have scheduling conflicts, tell the auditors and determine an interview schedule. I know you fly airplanes for a living – not complete audits for a living – though it might seem that way sometimes – so I understand if the chief pilot or DO has to go fly. I can’t give you a complete audit if those individuals are unavailable for the entire period though. Make sure you are accessible to auditors for at least part of the audit.
This sounds obvious but provide appropriate resources for the auditors. Twice now I have conducted audits in lobbies. That is a really uncomfortable situation for both the auditors and the operator. To conduct a good systems audit, the mx and ops auditor have to be able to communicate and sometimes we’ll say things you don’t want your customers or even staff to hear. You might not even be doing anything wrong – we might just be sorting things out between the auditors – but it can be awkward.
4. Responding to Findings
Each audit standard has different requirements for timelines and expectations for corrective actions, so I won’t go into this in detail. Ask your auditor if the expectations are unclear. Be sure to keep track of the time remaining to submit corrective action plans or completed actions. Many audit standards require a process or procedure to meet a particular standard, not just a policy statement. Make sure the staff closing the audit findings know how to write a process or procedure and don’t just submit a policy statement and hope the auditor will accept it.
5. Solving Conflicts
We’re all human. Sometimes you and your auditor will disagree. This happens on maybe 1 out of 10 audits I conduct. In most cases, the operator and I reach a common understanding and the issue is resolved. In one case, I had to bring in the audit standard organization to mediate the issue. Remember the auditor is obligated to the audit standard organization – be it IBAC, ACSF, whoever – to uphold their standard. You might not like a particular requirement and that’s okay. You don’t have to like it. But if you want to play in their sandbox, you have to play by their rules.
Let’s say a standard is impossible for your particular operation to comply with, it is totally inconsistent with your operations model, or you just don’t like it. Keep in mind all of these standards exist because someone lobbied for the item to be included. If you disagree with a standard, I recommend one of the following actions: lobby the audit standard organization for an exemption; lobby the audit standard organization to change the standard itself (this is often a long process as most of the customer advisory boards or review boards only meet once a year); or convince the auditor you do something else that meets or exceeds the INTENT of the standard.
Keep an open mind. Sure some auditors like to hangar fly and drink coffee but many of them have good experience and insight and just want to help operators be safer and more efficient. Most of us would rather be there advising you than playing auditor cop but we do have a responsibility to uphold the audit standard and most audit standard organizations have strict rules against consulting while on the audit.
Know a good audit when you see. Did you have no findings? Not a one? Don’t go celebrate. You just wasted your time and money. Okay, if you’re a 135 operator and this is your 3rd round at IS-BAO or whichever audit, maybe you don’t have any actual findings. But different auditors should have different perspectives and might see something another auditor didn’t. If you don’t have any actual findings, were you at least provided with some suggestions for improvement?
Know the difference between a required standard and an auditor’s opinion. Sometimes I’ll offer a suggestion aside from the actual audit. You’re not required to do anything with that. I just saw something that might help you be safer or more efficient. You can take it or leave it. But if an auditor writes up a finding that you feel is not substantiated by the standard itself, question the auditor. If that doesn’t work, go to the audit standard organization. The auditor is there to verify compliance with the standard, not enforce their own opinion.
And finally, don’t assume because you just passed an FAA inspection that you will sail through an audit. First, back to the “we’re all human” idea. Your inspectors might have missed something. On the other hand, your inspector might be allowing activity that isn’t really permitted. And guess who gets to pay if another inspector decides you aren’t in compliance? You do. Also, most third party audit standards are meant to enforce best practices, not just regulatory compliance.
Contact me at Lindsey@mcfarrenaviation.com or by phone at 703-445-2450 if you need assistance preparing for your next audit or closing audit findings!