STRIVING FOR MORE THAN JUST COMPLIANCE WITH AUDITS
It is not unusual to be apprehensive about an audit. However, there is a big difference between trying your best to have everything compliant, and really hoping auditors don’t discover something you know may not be compliant.
I remember participating in a defensive driving course many years back and following some basic theory the instructor asked; “How many believe that you are a better than average driver?” Sixteen of 20 participants raised their hands. Of the first three practical exercises, only two people passed. Simply mentioning the words compliance audit will send many into a spin. But with appropriate training, maintenance of procedural systems and record maintenance, the spin will not be terminal. Compliance is about meeting the minimum standards, but that is no reason why the minimum requirements should not be exceeded.
Back to the defensive driving example, what is average? As a licensed driver, it should be assumed that all have met the minimum standard competencies. So, whilst it is all somewhat subjective, in a competent group there will be three, broadly segregated categories – below average, average, and better than average – but all are deemed competent. Aviation safety means the state of an aviation system or organisation in which risks associated with aviation activities, related to, or in direct support of the operation of aircraft, are reduced and controlled to an acceptable level. It encompasses the theory, practice, investigation, the categorisation of failures, and the prevention of such failures through regulation, education, and training. An operational audit is the type of audit where the review is mainly focused on the key processes, procedures, systems, as well as internal control in which the main objective is to improve productivity, as well as efficiency and effectiveness of the operation and operational processes. The audit is about confirming that you are doing what you say you are doing – complying with the approved processes.
Being approved as a Recreational Aviation Flight Training School and Chief Flying Instructor is an endorsement of compliance to the minimum standards for an FTS and CFI. So, the FTS was compliant when the approval/s were issued. But what is the process of ensuring that these compliances are maintained? Welcome to an operational audit. On many occasions (not just about aviation), I have heard comments in response to an impending operational compliance audit as just more bureaucratic red tape. Pause and consider, what is Red Tape? The following quote provides a good summation: “Red tape is an idiom referring to regulations or conformity to formal rules or standards which are claimed to be excessive, rigid, or redundant, or to bureaucracy claimed to hinder or prevent action or decision-making. It is usually applied to governments, corporations, and other large organizations.”
So, what can you do to help yourself?
IF IN DOUBT – ASK:
- Evidence to show that the attempt to comply was
genuine, will promote discussion to improve the
system, if you demonstrated intent - If you are not confident about an FTS audit (it will
come) now is the time to contact the Ops Team and
start the improvement process to ensure you are
confident if the auditor were to arrive unannounced –
maybe tomorrow.
DO NOT:
- Assume the auditor is out to find fault. It is a sharing process
- Cruise along in the hope there will not be an audit. It will come!
- Procrastinate – start now and bring ALL records up to date
DO:
- Ask questions, an audit is not one-way information.
- Maintain good student records – the records belong to the student. The FTS is the custodian of the student’s student records.
- Review the RAAus FTS requirements
- Use checklists for currency and critical dates. Checklists are used in the cockpit, so we do not forget! The use of these should not limited to the cockpit checklists. A single office checklist can be used to include and highlight anniversaries, instructor checks, instructor renewals, medicals, aircraft registration, RAAus membership, etc.
Our FTS recently had an audit and as CFI, I think we went well overall. There were some discussion items, a couple of highlights being differences in records of authorisations – but for me, this is the continuous improvement process.
Operate on the basis that the FTS audit is tomorrow and keep all records complete and up to date on the day. Set yourself a target today. Do not aim to just simply meet the minimum standard, aim to be in the ‘better than average’ group. Focus on continuous improvement. By doing this, the benchmark will become higher and the reputation of RAAus will be elevated.
