IS-BAO—Industry Standard or Political Placeb

IS-BAO—Industry Standard or Political Placeb

By Karen Di Piazza

Ray Rohr, IS-BAO standards manager, defends the IS-BAO audit for Part 91 and Part 135 operations.

Ray Rohr, IS-BAO standards manager, defends the IS-BAO audit for Part 91 and Part 135 operations.

During the last few months, the National Business Aviation Association has made efforts to promote a positive safety image to mainstream media, trying to defend against a series of high-profile fatal business aircraft accidents that have dominated headlines. That campaign isn’t going well. Since 2002, the nonprofit organization has been promoting IS-BAO to its members.

Ray Rohr, IS-BAO standards manager, said the program is misunderstood; flight departments should purchase the generic manual/template for $950 through the NBAA to make their operations safer. He claims IS-BAO is the “industry standard” and that it “was created by industry for industry.” However, aviation safety auditors interviewed say otherwise. They say that only 30 out of 300 manuals sold through the NBAA have been implemented; even 300 is a small number compared to thousands of flight departments that exist.

What is the IS-BAO manual? The NBAA’s website promotes it this way: “The flight operations manual is the primary reference for all operations, maintenance and administrative issues in flight departments; having a comprehensive and current manual is essential to safe and efficient operations. The workshop uses the new International Standard for Business Aircraft Operations (IS-BAO) as the basis for providing participants with all materials needed to develop or update an excellent operations manual, custom tailored to your operations.”

Rohr is also the standards manager for the International Business Aviation Council, a nonprofit organization that employs 1.5 people and owns the copyright to IS-BAO. The NBAA and its foreign nonprofit equivalent organizations subscribe to IBAC, but the NBAA is by far the largest organization, with 7,400 memberships.

After developing the IS-BAO, IBAC decided it needed to have a board for it. Before 2001, IBAC and the NBAA decided to name it the IS-BAO Standards Board. It has appointed various NBAA, its counterpart organizations in foreign countries and IBAC members. Next, the board agreed to sell the manual, and then to sponsor a one-day, six-hour workshop/course study through the NBAA. Then its members could pay $950 and become an IS-BAO auditor, meeting IS-BAO requirements. Professional safety-auditing companies sent several of their auditors to attend the one-day course. IBAC in return dubbed them “IS-BAO accredited auditors.” They could go out and independently audit flight departments to the IS-BAO standard.

Auditors that weren’t employed by established safety-auditing firms also became IS-BAO auditors. For some of them, IS-BAO has become the main source of their income, either preparing operators for the IS-BAO audit, or auditing the companies. Some have little or no practical in-depth aviation experience, according to several IS-BAO auditors that were interviewed.

All the safety-auditing firms such as Wyvern, ARG/US and the VanAllen Group had the understanding from the beginning that IS-BAO was designed and approved for Part 91 departments, and as such, was supposed to be used to help them establish a basic flight operations manual. Under the FAA’s guidelines, it’s not required that 91 operations have an FOM. IS-BAO supporters believed having one would raise the safety bar and help those departments reduce risk—and learn about JAR OPS 2, international flight guidelines.

Based on that, all the major safety-auditing companies supported IS-BAO. However, they never agreed it should take the place of having in-depth audits in Part 91 operations or ever agreed IS-BAO should be involved with Part 135 operations. IS-BAO doesn’t meet basic FAA regulations that Part 135 operations must follow. Nevertheless, to everyone’s surprise, the IS-BAO Standards Board agreed in 2002 to go ahead and sell IS-BAO to Part 135 operations. It’s also been revealed that IBAC and the IS-BAO Standards Board plan to sell this idea to Part 121 operations.

Many industry safety analysts find this laughable. A growing number of IS-BAO detractors point out some of the recent Part 135 accidents, and believe if IS-BAO is ever used in Part 135 operations there will be a much higher accident rate.

Not a positive GA safety message

The NBAA has its hands full trying to combat all of the recent headlines that paint a negative image that business aviation is not safe.

Last month, after a Challenger 600 smashed into a warehouse building’s structure, after a failed takeoff on Runway 6 at Teterboro Airport, it became engulfed in flames, after it leaked jet fuel onto the ground. Luckily, the plane’s eight passengers, one flight attendant and two pilots survived.

The aircraft struck two cars as it blasted its way through airport perimeter fencing, crossing a six-lane highway before crashing into the warehouse. Twenty people, including a warehouse employee working inside the building at the time of impact and five firefighters, were admitted to nearby hospitals. The copilot sustained broken bones.

When a WNBC television reporter quoted a witness, “The pilot told me the crew lost control of the plane,” it thwarted the NBAA’s usual positive safety messages following accidents of late. No one would argue that the Feb. 2 accident received an unusual amount of media attention, especially since there were no fatalities.

Walter D. Lamon, founder and CEO of New Jersey-based Wyvern Consulting, Ltd., has withdrawn support of IS-BAO.

Walter D. Lamon, founder and CEO of New Jersey-based Wyvern Consulting, Ltd., has withdrawn support of IS-BAO.

Some aviation safety consultants believe the media will continue this trend, which is another reason they said IS-BAO’s 135 efforts needs to stop. They said that since the Nov. 28 crash of a CL-Challenger 601, when a son of Dick Ebersol, NBC Sports chair, and two others were killed in Colorado, the media has been watching and reporting on more incidents.

“The could’ve been Bush accident,” which occurred in November as well, is also still a fresh memory. Two pilots and one flight attendant were killed when a Gulfstream G-III crashed on approach to Houston’s Hobby Airport to pick up former president George W. Bush. The month before that, all 10 aboard a Beech King Air 200 were killed when the aircraft impacted a mountain, missing its intended approach to Blue Ridge Airport in Martinsville, Va.

The recent high-profile fatal business aircraft accidents have increased the public’s fear about corporate aircraft being safe. The reason for that fear is mainstream media’s message: If you’re flying anything other than a commercial scheduled transport carrier, you’re not safe.

The fatal accident rate for “all” of general aviation is about 2.5 times higher than that of Part 121 operations. There is a vast difference between GA “overall” fatality rates vs. “corporate business” fatality rates. According to the NBAA, mainstream media keeps lumping fatality rates outside of “business corporate” aviation. The organization says that “business aviation has an excellent safety record.” That is based on corporate operations only. The NBAA said fatal accident rates of 0.014 per 100,000 flight hours nearly equals that of Part 121 transport operators of 0.012 per 100,000 flight hours.

Figures provided by the NBAA are correct, if you remove “overall” GA fatality rates that include piston-powered airplanes, balloons, dirigibles, gliders, etc. Industry experts agree that the NBAA has done a poor job of “educating” the media by simply telling them that “corporate aviation has an excellent safety record.”

If the NBAA hasn’t been listening to the media’s message, the FAA has. In mid-February, the organization scheduled an emergency meeting over the string of fatal biz accidents. The focus was to determine what “best practices were being used in industry—looking at safety cultures and safety systems—to see if anyone had a really good safety management system.”

IS-BAO conflict

Several safety auditors want to make sure the IS-BAO program isn’t promoted to the FAA, or anyone else, as being a solution to serious safety issues. To demonstrate obvious IS-BAO deficiencies, New Jersey-based Wyvern Consulting, Ltd. prepared a “Wyvern vs. IS-BAO” comparison chart, which illustrates some areas that the IS-BAO audit doesn’t cover.

Wyvern, a worldwide aviation services company established in 1991 that has performed more corporate safety audits than any other company, said it’s easy to see why IS-BAO isn’t qualified for Part 135 operations.

“Although this is a preliminary chart that we have made, I encourage all safety-auditing firms to do the same,” said Walter D. Lamon, Wyvern founder and CEO. “It’s obvious just looking at this preliminary chart that IS-BAO isn’t a qualified process to be used to evaluate and identify risk, which is critical for any flight operation to operate safely. IS-BAO and the NBAA are trying to use marketing—making their perception a reality, but it should be the other way around.”

Auditors said that by reading accident reports, it’s clear that IS-BAO shouldn’t be used to determine safety criteria. The causes of most accidents aren’t included in IS-BAO criteria.

David Perdue, president and CEO of Memphis, Tenn.-based iviation LLC, agreed with Wyvern and said that IS-BAO isn’t a method suitable for Part 135.

“I think making a chart like that is a good idea. We’re doing one, too,” he said. “We believe IS-BAO does a disservice to operators and those shelling out the cash to purchase an IS-BAO audit, when it’s clearly not an audit. An audit should be in-depth, covering every aspect of a flight department, which clearly IS-BAO doesn’t.”

He said that an audit “isn’t about running a checklist.”

“Real audits trace the nuances and connect the dots that lead to not only identifying and managing risk, but also to liability and evaluating how you can improve efficiency of the operation overall,” he said. “IS-BAO may call itself ‘the standard,’ but unlike other organizations that have checks and balances and quality control over the final product produced for the client, IS-BAO is a shallow, 1.5 man organization that does nothing to control quality at any point in the process.”

Rohr doesn’t agree and believes IS-BAO has checks and balances.

“IS-BAO is a process by which operators can identify hazards and associated risks that are inherent in their operation,” Rohr said. “They can develop and implement appropriate mitigation to reduce the level of risk to an acceptable level.”

IS-BAO detractors allege that the NBAA has allocated its funds, derived in part by its memberships, conventions, convention booth fees, etc., to promote an agenda they don’t support. They don’t support IS-BAO Standards Board’s agenda to “reduce and eliminate” the need for other third-party auditing firms to perform safety audits of Part 91 and 135 operations.

NBAA’s director of international operations, Bill Stine, a paid employee, is also a member of the IS-BAO Standards Board; he supports IS-BAO. In fact, he said he supports IS-BAO in Part 121 operations.

“We have several airlines looking at this,” he said. “I think IS-BAO should be used for all flight operations.”

When Stine was asked to justify how IS-BAO could be used for Part 121 airline operations, he didn’t answer. The FAA has approved of the International Air Transport Association’s IOSA-audit for Part 121 operations. IATA represents a majority of the airlines. It’s highly unlikely that IS-BAO, which doesn’t meet basic FAA guidelines for Part 135 operations, would ever be considered for 121s.

Most people interviewed said they were shocked at how far the NBAA has allowed this to go and that the organization’s leaders should justify their support for IS-BAO. Several requests to talk with the NBAA chair, Kenneth Emerick of General Motor’s worldwide flight operations, have gone unanswered. The NBAA’s public relations department refused our request, saying they didn’t want to put him on the phone.

The NBAA may support the IS-BAO, but detractors pointed out that GM’s flight department is not an IS-BAO registered operation. When asked if Ed Bolen, the NBAA president and CEO, would comment, Stine said it wasn’t necessary for the president or chair of the NBAA “to know everything” and that he was the “frontline on the IS-BAO document.”

David Perdue, founder, president and CEO of Tennessee-based iviation LLC, said he doesn’t support the IS-BAO program or its audit process for any flight operations.

David Perdue, founder, president and CEO of Tennessee-based iviation LLC, said he doesn’t support the IS-BAO program or its audit process for any flight operations.

Calls made by Don Baldwin, former NBAA chair who left in December and now works with Business Aviation Support Services, also received no response. Baldwin said he would promote IS-BAO and hire IS-BAO auditors to audit Part 135 and 91 operations for its “shared services” clientele. He doesn’t personally plan to become an IS-BAO auditor. His company will contract out to have his clients audited, and then become an IS-BAO registered company. He said he did attend the six-hour, one-day class workshop through the NBAA, which is the same class that all IS-BAO auditors attend.

Most safety-auditing consultants interviewed said they didn’t feel a six-hour course was nearly enough education to have before auditing flight departments. Stine said he would promote his belief that all a Part 135 or Part 91 flight operation needed was IS-BAO.

“I think it does suffice as a safety gauge,” he said. “It gives Part 91 and Part 135 operations the ‘safety management system’ they need to operate safely.”

Numerous safety-auditing firms said IS-BAO was supported “only for a supplemental aid to Part 91 operations,” as a good place to begin using rudimentary flight operation manuals. IS-BAO auditors themselves and other safety analysts warned that IS-BAO shouldn’t be considered as a safety gauge in any way in Part 135 operations, as it would jeopardize safety.

Issues cause supporters to abandon program

Many auditors don’t believe that the NBAA should be selling IS-BAO manuals, and then promoting its audit. They say it’s a conflict of interest, and that the corrupt concept is used to further individuals’ businesses or to advance individuals politically on the board of directors of the NBAA. Stine said it was “not a conflict of interest” and that the “IS-BAO is industry best practices.”

Gregory A. Feith, Colorado-based international aviation consultant and former National Safety Transportation Board senior air safety investigator, said IS-BAO shouldn’t be considered the end-all for Part 91 departments.

“Industry best practices are boundaries with infinity as it’s boarders!” he said. “It’s not a document you can hold in your hand and look up information, and apply it to a real-world flight operation situations. It’s the new buzz word, with little to back it up, and comes in handy when someone can’t justify what they’re talking about.”

Feith agrees that there could be a benefit for 91 departments using IS-BAO for a place to start—for some basic structure—but not for Part 135.

“Beyond that, it has to go deeper, as the flight department uses IS-BAO as a tool to maintain that structure in a 91 environment,” he said. “The way IS-BAO is currently, it’s not suited for Part 135 operations. There’s just no method to adhere with using IS-BAO to identify and correct deficiencies, and it doesn’t meet the FAA’s minimum level of safety. The FAA regulations far exceed what the IS-BAO standard is.”

He said the FAA is not the end-all answer either.

“The FAA currently has a difficult task overseeing 14 CFR Part 91K and 135 operators. I believe more thorough oversight is necessary of these types of operations,” he said. “To believe that the IS-BAO standard, with only a periodic audit, will insure safety, rather than frequent and thorough FAA oversight, isn’t reality. Unfortunately, the lack of thorough and frequent oversight by the FAA of Part 121 air carriers has been identified as a cause and/or contributing factor by the NTSB in several accidents. ”

Feith said IS-BAO lacks in-depth CRM, as well as crew fatigue-counter-measure programs.

“By auditing Part 135 departments, and then having IBAC present them with a certificate of compliance, that’s really handing out a certificate that says you’ve just failed to meet FAA minimum standards!” he said. “Also, flight departments shouldn’t depend on various outside training organizations that currently provide simulator training to teach pilots CRM.”

Rohr said that the IS-BAO recommends pilot proficiency and recurrency training annually, but that it isn’t a hard and fast rule. The IS-BAO manual didn’t specify exactly how pilots were to receive such training; it’s the operator’s decision.

“The IS-BAO program does require that every two years pilots undergo recurrency and proficiency training,” he said. “But depending upon what type of aircraft the pilot is rated in, it could be done by an annual checkride or a Part 142 training provider. It may be that both a checkride and simulator training are done, but we use the term ‘as to what is practical,’ meaning, what’s practical for each operator.”

He explained that by purchasing the IS-BAO kit/manual, and adapting its generic outline, it could be used in any flight operation. Each operation could add its own specific rules above what’s required. But he said the true test to appreciate the program was to implement it and have an IS-BAO audit.

The cost of the audit, depending on which IS-BAO auditor you call, ranges from $1,500 to $35,000. There’s also a $200 fee for the IS-BAO certificate. That’s another reason numerous safety auditors don’t see the value in it. They say flight departments shouldn’t be paying for an audit that, by their standards, fails basic government oversight.

Feith, responding to Rohr’s comment that the IS-BAO favors Part 142 training providers, warned operators that the safest way to train is having on-site CRM/CFIT programs. He’s not advocating abandoning Part 142 training, however.

“CRM and other safety programs need to be established on-site, and that includes 91 and 135 operations,” Feith said. “Providing in-depth training and a more formal process addressing such training is desired. Unfortunately, the IS-BAO standard doesn’t require anything other than something very generic. It must go beyond generic-type information. You cannot just pick up a book, and say, ‘In my flight department, we make our pilots read this book about CRM,’ but that’s how loose IS-BAO is.”

Rohr completely disagrees with all IS-BAO detractors, but he admitted that neither he nor other members of IS-BAO or IBAC are accredited IS-BAO auditors. Additionally, there’s not one safety-auditing firm on the board of IS-BAO. Over two years ago, Wyvern submitted a letter to Don Spruston, the director general of IBAC, asking to be included on the board to help with guidance.

“We were told, basically, no thanks,” Lamon said. “They, however, had no problem accepting Wyvern’s money to send nine IS-BAO auditors through its one-day audit program. They expect Wyvern, ARG/US, the VanAllen Group and so many more companies to support their program, which we all believed was to aid 91 departments. It’s apparent they’re competing against qualified safety auditing firms, which have far superior auditing expertise and auditors who have in-depth practical aviation experience.

“What they offer is a placebo. I can no longer support IS-BAO. I’ve sent a letter to Ed Bolen stating why Wyvern will not continue to support a program that’s competing with one of the very companies they use in its marketing efforts. I cannot support thinking like this; IS-BAO appears to be full of it.”

Independently, the three IS-BAO auditors listed with Wyvern had the opportunity to continue supporting IS-BAO audits if they so desired. All three of them have decided to stop supporting IS-BAO. Howard Fuller and Russell Lawton, both Wyvern U.S. based auditors, have dropped out. Wyvern’s U.K. auditor, Richard Kneale, who also dropped out, said there “isn’t much interest” in IS-BAO in Europe.

Jim Holmes, former NetJets vice president of operations, and at one time, the operations director of Wyvern, said he saw the writing on the wall before this and decided not to reinstate his IS-BAO accreditation. He became an IS-BAO auditor while at NetJets, but didn’t perform any audits because he felt it would have been a conflict of interest.

“Most people are just now realizing that we were told one thing, but actually, IBAC’s agenda has always been clear—to move into Part 135 operations,” he said. “It’s in the IS-BAO annual board minutes, item 10, December 2002, which I suggest everyone reads. IS-BAO doesn’t belong in Part 135 operations as a stand-alone audit; it would jeopardize safety and I will not support that.”

He said there have been three IS-BAO Part 135 audits done in the U.S., and that Wyvern did all of them.

“But those operators only wanted the IS-BAO accreditation, because Wyvern had already conducted a very thorough audit,” he explained. “They wanted it for marketing purposes; they know it’s just a piece of paper.”

Item 10 from the IS-BAO Standards Board annual December 2002 meeting reads: “In subsequent discussion, it was agreed that all associations should take an active part in marketing the IS-BAO and that business aircraft manufacturers be approached and encouraged to recommend IS-BAO to aircraft purchasers. A significant, potential IS-BAO market particularly for audit and registration of Part 135 operators (or equivalent) was considered as worthy of additional attention. Currently, such operators can be subject to multiple audits commissioned by business aircraft operators who hire charter operators to supplement their fleet. Reducing or eliminating such multiple audits and having all such audits conducted to one standard would considerably reduce costs as well as enhance audit comparability. Action – All.”

Robert E. Werner, president of Edwards Group International—Hybrid Quality/Business Management Systems, is an accredited ISO 9001:2000 auditor, with the rank accreditation in the aerospace category as well. He’s also an IS-BAO auditor, and recently audited Textron, Inc., which was his last audit.

Werner doesn’t have any practical aviation experience, and said Rohr knew that. Rohr and Stine both said they didn’t have any IS-BAO auditors presently who lacked practical aviation knowledge.

Werner said he doesn’t believe IS-BAO meets the same high standards of ISO and that he decided not to reinstate with IS-BAO. He doesn’t feel the IS-BAO accreditation audit is equal to the ISO accreditation audit, and doesn’t see how anyone can learn how to audit flight departments by going through a one-day, six-hour course. He said the testing criteria for ISO alone, and the course itself takes weeks, but it could take years to fully study for it before you tested. He said it took him years learning and testing for his various ISO accreditations and that he has performed hundreds of ISO 9001:2000 audits.

“As far as I’m concerned, you need ‘competency witness audits’ and oversight, which IS-BAO doesn’t have,” he said. “I’ve been telling Ray Rohr that for some time now. I’ve also pointed out numerous other deficiencies. The program shouldn’t have been launched when it was. It wasn’t complete enough; it still remains incomplete.”

Feith said once he looked into IS-BAO, after someone had asked him to become an auditor, he decided not to engage the program, because it lacks teeth. VanAllen Group founder and CEO Pete Agur, who has some IS-BAO accredited auditors working for his company, said he didn’t know much about IS-BAO until after the NBAA started promoting it. He doesn’t support IS-BAO in Part 135 or Part 121 operations, but he believes it’s beneficial for Part 91 departments, especially for smaller flight departments that don’t have many procedures.

“Part 91s have far less FAA regulations to adhere to than does Part 135 or Part 121s, so getting some basics in 91 operations is favorable,” he said. “However, I can’t say the IS-BAO audit should take the place of other third-party audits. Three members of the VanAllen Group attended the first IS-BAO auditor’s training session in 2002, conducted at Coca-Cola’s hangar, when Don Baldwin was involved.”

Prior to chairing the NBAA, Baldwin ran Coca-Cola’s flight department, which he made sure he got involved as one of its first IS-BAO audited flight departments. He encouraged employees to become IS-BAO board members under his tenure at the NBAA. However, Texaco, which Baldwin oversaw before, decided not to follow his IS-BAO enthusiasm. They stopped IS-BAO registration after he resigned and they aren’t an IS-BAO registered company today. He also said he asked all the major auditing firms to help him develop a flight operations manual for Coca-Cola, but interest wasn’t there.

Agur said his firm had very little contact with IBAC before that first session.

“At no time were we asked directly by them (Coca-Cola) or IBAC to assist in developing any program,” he said. “I wasn’t asked to help develop the IS-BAO standards either. While we were in that training session at CC, along with other attendees, we openly contributed to conversations about how the IS-BAO standards could be improved. I don’t recall being asked to share our review protocol. I would have declined; our review process is a confidential document. In fact, I published our standards in a paper I presented at the 2004 Flight Safety Foundation Corporate Aviation Safety Seminar. In other words, Don’s recollections are, at best, inaccurate.”

Baldwin said he used Wyvern at Texaco, but while at Coca-Cola turned to IS-BAO because he couldn’t find help creating polices for the FOM.

“We hired Wyvern for Texaco, not Coke,” he said. “With Coke, we did things in a different way. We had an agreement with a third party, Air Partner, Inc., for our charter brokering. Air Partner went out and learned about IS-BAO. We actually had it written into our agreement that they would first try to find IS-BAO registered operators, but we had to leave it open because IS-BAO was so new. If Air Partners couldn’t find an IS-BAO registered 135, they were free to use Wyvern, ARG/US, one of the majors.”

Baldwin introduced his friend Emerick, the NBAA’s new chair, to the ins and outs of leadership. He was asked if he thinks Emerick supports IS-BAO, and if as much funds would be allocated to support IS-BAO.

“I can’t speak for Ken, but as for Texaco, the company merged with Chevron in October 2001, before IS-BAO,” he said. “We were headed for IS-BAO, which was in a draft form at the time, but the merger occurred and I retired from the company, so all certification efforts came to a halt. As for mood, again, I can’t and won’t speak for Ken, but the NBAA is very supportive of IS-BAO, and the NBAA encourages members to seek certification and registration; so do I.”

He said he went back and looked at the IS-BAO package again and couldn’t find anything that lowers the standards for 91 and 135 operations.

“As I see it, IS-BAO addresses what needs to be addressed and not ‘how.’ That’s left up to the regulatory agencies and the operator,” he said.

Lamon said IS-BAO is taking away years of progress in identifying good performance by experienced safety auditing firms and moving it backwards. He explained that he expected competition, and he respects that competition, but not IS-BAO, because the program isn’t competent to compete in Part 135. He also warns operators not to accept IS-BAO as being an end-all to Part 91 operations.

“I believe such marketing rhetoric supporting an inefficient program from the IS-BAO board and Baldwin—who have obviously shown what their motives are—is a smokescreen to direct attention from the gaping faults of IS-BAO,” he said. “Don Baldwin seems to have selective memory loss. While Don was at Coke, the first meeting was held in August 2002; In June 2002, before that meeting, I sent Don Spruston the Wyvern Standard that included must-haves for audits, which were ignored. Spruston sent me the IS-BAO registration information. If Don Baldwin was unaware of that, then he should check with Rohr and Spruston, the two Air Transport Canada guys who came up with IS-BAO.”

He also said that the three Part 135 IS-BAO registered companies that Wyvern audited gave their opinions of the IS-BAO process, which wasn’t a resounding “higher standard” comment.

“If Don is serious about his feeling that we should all make it better by participating, then why were my overtures ignored?” Lamon said. “He doesn’t perform audits, and to my knowledge, he hasn’t demonstrated he is capable of doing so. His statement, ‘If a Part 91 or Part 135 had an IS-BAO audit and passed it, those operators then would be considered safe; they wouldn’t need a third-party audit,’ is contrary to real safety management systems and quality verification.

“If that were true, no discipline would require external audits—financial, quality, legal, etc., which is how the real world operates. What he appears to be saying is, ‘Use IS-BAO; audit and monitor yourself. That’s okay; doers can be checkers.'”

He said no business he knows of operates under that premise.

“When Don was with Texaco, IS-BAO wasn’t a system available to the public,” he said. “That happened when he was with Coca-Cola. He had a contract with FlightTime and Wyvern to audit and procure lift. The standard was Wyvern, not IS-BAO.”

Lamon said Wyvern was the first system Coca-Cola placed under contract.

“After FlightTime declared bankruptcy, Coke entered into a contract with Air Partner, but there weren’t IS-BAO 135 operators registered,” he said. “Additionally, Air Partner is a Wyvern authorized air charter broker.”

Wyvern and others said that originally Spruston told them in 2002 that IS-BAO was intended only for 91 flight departments, which was the reason they supported the effort.

“We believed they would help corporate operators with JAR OPS, which we supported, but as the facts have played out over the past few years, we don’t feel that IS-BAO has the value we expected,” Lamon said. “The program isn’t being used for what IBAC said. We participated in the formative meeting in Atlanta, in August 2002, which at that time was comprised of seasoned aviation professionals and auditors. In fact, I sent three of our auditors from around the world to participate in that meeting. I think we all assumed that an IS-BAO auditor’s background would have to match that of the auditors who were present at that meeting.”

Lawton and other auditors at the time, including Holmes, verified this was true.

“We know now that IBAC has accepted unqualified, inexperienced people to become IS-BAO accredited auditors, after attending one six-hour class,” Lamon said.

Further, Fuller, Holmes, Lawton and Lamon said some of these individuals have little or no actual, practical aviation experience in flight operations. They also said that if Baldwin’s new company is so adamant about IS-BAO, then they’re beginning to understand the motivation for many of his previous actions.

“As a decision-maker at NBAA, he heavily promoted IS-BAO and allocated NBAA resources to promote it,” Lamon said. “Now it’s become an integral part of his business model.”

Mark R. Fischer, Aviation Research Group/US’s executive vice president, said he supports IS-BAO for corporate aviation.

“With regard to IS-BAO, I want to make sure I’m not quoted out of context, since we definitely support the IS-BAO concept in the Part 91 world,” he said. “Our position with regard to the Part 135 world is that IS-BAO may have some value in as far as it goes, but it certainly should not be the only audit for this industry segment.”

He said ARG/US believes that an aviation auditor using any method must have direct aviation experience in order to be effective, as evidenced by their audit teams. Under the audit guidelines for IS-BAO, having practical aviation experience in the areas that an audit takes place isn’t a requirement.

Stine said it was more important to have “auditing” experience than “aviation” experience. In fact, he admitted they have turned down people with “great in-depth aviation experience” because they didn’t have as much auditing experience.

Defending IS-BAO

Rohr said his background includes doing regulatory audits as a former Transport Canada civil aviation inspector, and managing audit programs as a senior executive in Transport Canada. He also did audits and safety management work for a number of clients worldwide before he became IBAC’s standards manager.

“I can assure you that the IS-BAO is a comprehensive set of standards, with a safety management system as its cornerstone, which is used by business aviation and on-demand charter operators to effectively manage the safety, security, efficiency and effectiveness of their operation,” he said.

Rohr, the secretariat and standards manager of IBAC, with headquarters in St. Albert, Canada, addressed questions about revocation, a system in place to remove the good status of an operator not performing as they should, which other safety auditing firms employ.

“If you’re asking about an IS-BAO registration, it’s issued to operators who are operating under Part 91 or Part 135, and there are no specified provisions from cancellation of the registration,” he said. “It’s issued for a two-year period based on the fact that the operator has demonstrated that they’re in conformance with the IS-BAO, including that they have an appropriate SMS.”

He said IBAC “recognized the need for the business aviation community to take a lead role in fostering harmonization of operating procedures and requirements.”

“IBAC works closely with the International Civil Aviation Organization towards international standardization,” he said.

Rohr said he used to consult through ICAO.

“In many business sectors, international standards are recognized for their role in facilitating global commerce,” he said. “IS-BAO is similar in this respect as its fundamental purpose is to foster standardized, safe and highly professional aircraft operations. It’s based upon ISO 9000:2000 principals and standards.”

An issue is that IS-BAO compares itself to and markets itself using ISO 9000:2000. First off, accredited ISO 9001:2000 auditors said IS-BAO is using the wrong standard; ISO 9000:2000 was discontinued in 1994. They also said IS-BAO, if anything, was a “watered down” version.

Werner said that actual ISO polices, for example, don’t allow companies to “self-monitor” themselves in-between audits.

“ISO 9001:2000 audits don’t allow a company to go two years without audits,” Werner said. “ISO audits are preformed annually, and sometimes depending upon the company, it’s done every six months. There’s no oversight with the IS-BAO audit. They want to use people’s ISO 9001:2000 accreditations as marketing for IS-BAO; that’s what they say and have said to me. They wanted me as an auditor because of my ISO accreditation.

“The problem with saying that IS-BAO was built using ISO 9000:2000 principals and standards, as Ray Rohr does tell people, is a problem; people might think they’re getting an audit like ISO, but they’re not. If people want the real thing, they should have an ISO 9001:2000 audit; it’s designed for the whole company, not just a flight department.”

When asked why IS-BAO was promoted “behind the scenes,” using phraseology that IS-BAO was built on ISO 9000:2000 principals and standards, Stine denied that IS-BAO ever promoted its program using those words or that Rohr had said that to individuals. He maintains that IS-BAO’s marketing has not used the term “ISO 9000:2000” as a means to recruit auditors or promote its program. He said you couldn’t find that on its website, and challenged this reporter to prove it.

It was suggested that he read his own IS-BAO marketing—right on IBAC’s 2004 PowerPoint presentation (inset), promoting the benefits of IS-BAO, which was presented at the NBAA’s convention this past October.

Safety auditing companies complained that the process of accepting or declining applicants was hidden, and that the feedback it received wasn’t openly available to them. Who’s in charge of accepting or declining IS-BAO applicants? Rohr said that for the most part he was delegated authority to accept or reject IS-BAO applicants, but occasionally, “if he had any problems deciding on whom he had rejected,” he ran it by the IS-BAO Standards Board. As for feedback, he said that, too, was privileged information that he and the board viewed; however, he said “industry supports IS-BAO.”

Several safety-auditing companies have complained that their expertise has been ignored, and if they had been part of the IS-BAO Standards Board, this program today wouldn’t be falling apart. Stine responded that the reason they haven’t included safety auditing firms on the board is because, “they wanted people that wanted to contribute, not tear it down.” But safety auditing firms, such as Wyvern and iviation, and numerous auditors that have dropped out of the program view Stine’s statement, as really saying, “You don’t want to hear anyone else’s opinion if it differs with the IS-BAO agenda.”

Rohr defended the IS-BAO, too, by saying that when it comes to part of the audit process—for example, CRM/CFIT training—the SMS requires the operators to track the mitigation to ensure it’s appropriate and effective. He said it wasn’t required that an auditor do that.

“As controlled flight into terrain is a common safety risk, it would be logical for an operator to use a proven system such as CFIT training, and the CFIT checklists as a mitigation to address this safety risk,” he said. “The same goes with CRM principles and training, etc. The IS-BAO is structured, making maximum use of such proven initiatives—using a checklist.

“This process also assists in ensuring that senior management of the company is engaged in management of the flight department and its safety, security efficiency and effectiveness activities. Operators who have effectively implemented IS-BAO have said it was one of the important benefits they’ve gained.  Having senior management engaged should also include having them involved in the IS-BAO registration audit and follow-up, as well as understanding and supporting routine safety management initiatives and training.”

Rohr said that most of the time auditors don’t communicate with CEOs; they don’t start or end the audit process with them either. He also doesn’t believe it’s practical for flight department directors to report to CEOs.

When asked if it wasn’t a one-sided point-of-view on the NBAA’s part to only promote IS-BAO as a valuable audit, Stine said he didn’t see it that way. He also confirmed that the NBAA hosts IBAC/IS-BAO websites, and that IBAC needed money. Safety auditing firms said that proved why IS-BAO was created—not for safety, but for revenue.

“All right!” said Stine. “The IBAC website is run from a broom closet in the ICAO building in Montreal. The server for that website, yes, is in this building. IBAC is essentially not a large organization. It has one full-time person and another person that is on contract! It doesn’t have the resources, other than the eleven organizations that comprise its membership. NBAA being one, and no question, the largest of those.”

When first asked if they were competing with its auditors’ companies, Rohr denied it, but IS-BAO’s December 2004 newsletter says otherwise. It reads in part: “There are now a number of Part 135 operators who have completed IS-BAO registration. By doing this, they are demonstrating their compliance with the industry code of practice as well as the relevant regulatory requirements. Business aircraft operators who now are conducting audits of Part 135 operators, whom they charter, may wish to take IS-BAO registration into account and consider reducing or eliminating audits of such operators.”

Rohr also denied that he and IBAC were “pushing auditors and companies into IS-BAO registration.” But the same newsletter reads: “Most of the insurers we have worked with have indicated that they will consider IS-BAO registration as a significant positive factor in determining insurance rates. Our position would be strengthened by an increased number of registered operators. Therefore, we urge you to help yourself and the rest of the business aviation community by completing your IS-BAO implementation and registration. The potential benefits to your operation and your company of an effective system to manage safety, security efficiency and effectiveness that can be achieved through the IS-BAO are so great that failure to complete implementation should be strenuously avoided.”

Two senior underwriting managers, Kyle Sparks for Part 135 operations, and Will Lovett for Part 91 operations of AIG Aviation, Inc., in Atlanta, one of the largest insurers of aviation, says that having a Wyvern or ARG/US audit, which audited above what the FAA minimums were, went into the “good attitude” file, when evaluating insurance. They made it very clear, though, that they didn’t base insurance on the fact that someone has been audited.

Rohr said that “a number of 135 operators” have gone through the IS-BAO audit. In fact, there are about six—three in the U.S. and three in foreign countries. He said there were 52 IS-BAO auditors worldwide; there are less now.

There are 30 flight departments worldwide that have been IS-BAO registered. In other words, out of 300 total IS-BAO kits/ manuals sold worldwide to operators, only 30 of those operators have gone through with implementation audits to receive an IS-BAO registration certificate presented by IBAC.

In verifying how many total corporate flight departments there are, Ken Green, vice president of Aviation Data Service, Inc, a JETNET Company, said that not including piston-powered aircraft, the total number of corporate operators worldwide increased approximately 5.2 percent last year. At the end of 2004, there were approximately 15,050 corporate operators in the world utilizing a fleet of 23,013 aircraft. In the U.S. alone, there were 11,070 operators utilizing a fleet of 15,704 aircraft at the end of last year.

He said fractional ownership programs continued to grow in 2004. Again, using preliminary data provided by AvData, the number of individuals and companies in the U.S. that own a fractional share of an airplane increased approximately 5.5 percent last year from 4,516 to 4,765. The number of airplanes in fractional programs grew just over 5.3 percent in 2004, from 826 to 870.
Link to IS BAO PDF