CAVU Café: Royboy’s Prose & Cons

*Note: The views expressed in CAVU Café: Royboy’s Prose & Cons blog are those solely of the writer and are not necessarily shared by the Aviation Suppliers Association or the Association’s staff, members, or Board of Directors.

   About Roy Resto

WILL THERE EVER BE A SINGLE SET OF GLOBALLY ACCEPTED CERTIFICATION STANDARDS?

I do a lot of work with Repair Stations/AMOs (Approved Maintenance Organization). For MROs (Maintenance Repair and Overhaul) which do business internationally, the customer’s national CAA (Civil Aviation Authorities) often require that maintenance performed on aircraft based there be performed by MROs certified to their nation’s regulations. Thus, it is common to see MROs with multiple certifications for all the nations they do business with. Each nation typically charges fees, and requires a dedicated Manual (AKA Expositions, Supplements, etc.) detailing how their regulations will be implemented by the MRO.

Manufacturers of aircraft and engines similarly must endure multiple certifications as this headline demonstrates1:

For airlines it is the same. You must get certificated in your host nation followed by whatever additional certifications are required to fly to international destinations.

For MROs, Airlines, and Manufacturers involved in these maddeningly multiple certifications, all ask privately, when will there ever be a single set of globally accepted standards?

The answer is, it’s complicated. Yes, it’s possible, and it will occur, but first some interesting realities to discuss.

To start, let’s look at a few topics:

  • Fees
  • National sovereignty
  • Commonality
  • Reciprocity

    FEES:

    Ask anyone involved with these multiple certifications and they will hiss at the fees and costs being accrued to achieve the certifications they are being required to obtain. Add to this, these significant collateral costs:

    • The travel costs for, in some cases the teams of certification inspectors.
    • The endless hours your staff will spend on not only achieving the certification, but to maintain it.
    • In many cases the Certificate only lasts 2-3 years, requiring more audits, travel costs, staff time, and yes, new fees.

    CAAs will not likely divulge it publicly, but if we’re honest we must look at the possibility that the fees contribute to their sustainability, and thus are internally looked upon favorably, perpetuating the certification requirement.

    NATIONAL SOVEREIGNTY:

    A nation’s right to make their own laws is universally accepted and tied to the ideals of sovereignty; the nation is sovereign and will make any laws or regulations it deems to be in its best interest. And so it is with their aviation laws and regulations.

    The idea of subordinating or delegating one’s own domestic aviation laws and regulations to an international standard would predictably chaff against nationalistic sentiments.

    COMMONALITY:

    If you have ever been involved in implementing and maintaining multiple CAA certifications for your products or services, you’re immediately struck by the degree of commonality among them. CAA’s admirably and harmoniously implement rules and regulations which appear to be best practices globally. A good recent example is the various CAA’s requirement to implement Safety Management Systems (SMS), so multiple certifications will require you to implement SMS. Because of this, a reasonable, unbiased person would conclude that all of this represents irrational duplication of effort.

    RECIPROCITY:

    The current state of any global acceptance activity is entrenched in nation-to-nation statecraft, and that word endeared among generations of diplomats: reciprocity. In simple words, if your country accepts my requirements, I’ll accept yours. If you charge me fees, I’ll charge you fees. If you suspend or revoke my nations aviation companies, the same will happen to you.

    A common title used to identify reciprocal acceptance of nation-to-nation requirements is Bilateral Agreement. For example, the FAA maintains a publicly available listing2 for the US’s Agreements. Bilaterals are meticulously negotiated, take time, and have the potential to be influenced by politics. Because of this, it’s hardly the model which would usher-in globally accepted standards.

    GOING FORWARD:

    While some nations may exhibit hubris in claiming to have the best set of aviation regulations, due to the reality of international politics it is unlikely that any one nation would emerge to be the universally accepted global standard. So, what’s needed? Mutual recognition between the nation and the standard/regulation-setting organization. But who?

    To be globally accepted, you’d need an organization which is independent (not connected with any country), probably a non-profit, and which commands a degree of respect in the aviation community. Today we have two such organizations: ICAO (International Civil Aviation Organisation3) and IATA (International Air Transport Association4). But first a little history.

    HISTORICAL BASIS:

    For those of you who may take the time to read the fine print on many aviation documents, you’ll likely have noticed references to the Chicago Convention. For example, on the Incident/Accident Clearance Statement there is this entry:

    “A. none of the above-listed article(s), has been:
    1. damaged during, or identified as the root cause of, an accident or an incident subject to mandatory reporting as described by Annex 13 to the Chicago Convention, …”

    By the way, for those of you curious about that commonly seen statement, an aviation accident is defined by the Convention on International Civil Aviation Annex 13 as an occurrence associated with the operation of an aircraft, which takes place from the time any person boards the aircraft with the intention of flight until all such persons have disembarked, and in which a) a person is fatally or seriously injured, b) the aircraft sustains significant damage or structural failure, or c) the aircraft goes missing or becomes completely inaccessible. Annex 13 defines an aviation incident as an occurrence, other than an accident, associated with the operation of an aircraft that affects or could affect the safety of operation.

    The Convention on International Civil Aviation, also known as the Chicago Convention, established the International Civil Aviation Organization (ICAO), a specialized agency of the UN charged with coordinating international air travel. The Convention establishes rules of airspace, aircraft registration and safety, security, sustainability, and details the rights of the signatories in relation to air travel. The Convention also contains provisions pertaining to taxation5. The Chicago Convention originally had 52 signatories in 1944. Today 191 nations have signed-on to recognize and operate by ICAO’s Convention on International Civil Aviation known as Doc 7300.

    History will recognize the Chicago Convention as among the first successful efforts to gain global unity and acceptance of aviation rules. It brought us closer to but did not provide relief from the multiple-certifications dilemma.

    KEEP YOUR EYES ON:

    Today nearly every major airline is part of a code-sharing alliance designed to make inter-airline global travel a seamless passenger experience. Examples include Sky Team, Star Alliance, and One World. For a given airline member, their respective CAA expects that the airline is able to assure that the connecting airline (particularly international airlines) has an acceptable degree of safety and quality. This had meant that airlines audited each other multiple, overlapping times (sound familiar?), with the aim of certifying safety and quality. Again, irrational duplication of effort…until IATA’s IOSA program (IATA Operational Safety Audit).

    “The IATA Operational Safety Audit (IOSA) Program is an internationally recognized and accepted evaluation system designed to assess the operational management and control systems of an airline. The IOSA audit creates a standard that is comparable on a world-wide basis, enabling and maximizing the joint use of audit reports. This has saved the industry over 6400 redundant audits and continues to lead to extensive cost-savings for IOSA participating airlines”8.

    As of the writing of this article, there are 437 airline operators listed in the IOSA registry.

    With IOSA we are getting closer to a working model of globally accepted standards. Ask any airline employee involved with IOSA audits and you’ll be met with a roll of the eyes regarding its toughness and level of preparedness needed to meet the auditors. Briefly, the over 600 pages of the IOSA Standards Manual covers airline:

    • Section 1 - Organization and Management System (ORG)
    • Section 2 - Flight Operations (FLT)
    • Section 3 - Operational Control and Flight Dispatch (DSP)
    • Section 4 - Aircraft Engineering and Maintenance (MNT)
    • Section 5 - Cabin Operations (CAB)
    • Section 6 - Ground Handling Operations (GRH)
    • Section 7 - Cargo Operations (CGO)
    • Section 8 - Security Management (SEC)

    How have the CAA’s accommodated IOSA? First consider this example6:

    Second, how does a given CAA integrate its recognition of the standard? Consider this FAA excerpt from their FSIMS (Flight Standards Information Management System) manual7:

    “1.4.2 U.S. Air Carrier. The U.S. air carrier is responsible for all requirements associated with their Codeshare Safety Program to include the qualifications of the foreign air carrier(s) with whom they wish to conduct codeshare operations. All requirements must be satisfactorily completed prior to the DOT’s authorization of the codeshare.
    a) International Air Transport Association (IATA) Operational Safety Audit (IOSA). Before a codeshare is authorized, the U.S. air carrier must have accomplished, or had through a third party, an IOSA of the foreign air carrier.”

    Repeatedly the IOSA Standard requires that the host nation’s civil aviation regulations be consulted. And there you have it. A standard that recognizes the CAA’s regulations, and CAAs which recognize the standard; mutual recognition and accommodation.

    WE’RE NOT THERE… YET

    Clearly, mutual recognition and accommodation does not equate to the desired end-state which is globally accepted certification. If IOSA ever becomes such a certification standard, it would only apply to airlines. That would leave out Repair Station/AMOs, and Manufacturers. Nonetheless, observers of history will note that IOSA was indeed a harbinger of how it can be done.

    Over ‘n out

    Roy ‘Royboy’ Resto

    www.AimSolutionsConsulting.com

    1 https://embraer.com/global/en/...

    2 https://www.faa.gov/aircraft/a...

    3 https://www.icao.int/

    4 https://www.iata.org/

    5 https://en.wikipedia.org/wiki/...

    6 https://www.easa.europa.eu/new...

    7 https://fsims.faa.gov/PICDetai...

    8 https://www.iata.org/en/programs/safety/audit/iosa/

    Posted By Tony Brigham | 12/1/2020 2:56:44 PM