EASA AUDIT vs. SMS-based consultation in Pakistan

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EASA subjects Pakistan to another AUDIT

Past Deficiencies have yet to be satisfied

Instead of Fault-finding move to SMS solution defining

“I am here to audit you” ranks as one of the most troubling sentences an individual or company can hear. The implicit consequence, as exemplified the below instance, is the end of your country’s airline authority to fly to one of the globe’s largest passenger and cargo markets. Added anxiety arises when you recognize that the audit may lead to similar, repeated reviews by others, all carrying similarly, potentially damaging consequences. The recipient of this message knows that news of the audit will result in major headlines and significant political pressure to make the problem go away.

As with the example of Pakistan, this is not the first time that this aviation safety organization has been subjected to this FIRE DRILL. The previous “audits” ( EASA, FAA and ICAO also performed similar reviews) ended with a long list of “corrective actions. (although there may be varying criticisms and priorities among the three).

usaop elements

Some of the corrections are within the control of the Director General of the CAA (or DGCA) and you can immediately direct the needed changes, even though being told of your deficiencies by some Eurocrat, UNocrat or USBureaucrat may feel demeaning  (i.e., you have more experience than your foreign colleague). Your “inquisitors” may not be sensitive to your local politics (we have greater priorities than aviation safety) or cultural limitations. Yes, the CAA desperately needs, for example, more inspectors, BUT

  • our salaries are not sufficient to attract the necessary talent?
  • our training professionals and/or curricula are not adequate?
  • we need staff in the field, but housing/schools/lifestyle not adequate?
  • the boss is a member of Parliament and to ask that the basic legislation be rewritten is embarrassing because the original authority was written by a colleague?

The transition from audit to implementation is a treacherous break in the process. The auditors leave and are not present to help recruit qualified candidates for the position—is an example. Their legislative critiques must be carried to higher authorities without the presence of the experts. Fixing all the problems may not be easy without continued outside support.

Enhancing global aviation standards, as recently highlighted, is an important mission. Once the term “audit” is uttered, the context of these interventions can be precarious. Oversight by one’s peers seems as though  a superior finding fault with an inferior—in the mind of the audited. Finding fault has been abandoned by international aviation safety experts; SMS looks to identify risks and to address them in a way designed specifically for the organization, its people, culture, resources, etc.

The specifics of the Pakistan story cry out for a consultative, SMS approach. The past audits of the PCAA neither captured nor remediated the fraudulent pilot licensing as witnessed by this ICAO USOAP chart:

USAOP chart for Pakistan

Regaining its aviation regulatory status is critical to the Pakistan Civil Aviation Authority and Pakistan International Airlines. The past triplicate audits have had little impact. Instead of fault finding perhaps a consultative approach based on SMS principles would result in an aviation safety regulatory structure which works for the country and meets/exceeds global standards.

audit picture

Scope of probe extended: EASA to conduct audit before lifting ban on PIA flights

KARACHI: Following the concerns expressed by Directorate General for Mobility and Transport (DGM&T), European…

Muhammad Ali 11 Dec 2020


KARACHI: Following the concerns expressed by Directorate General for Mobility and Transport (DGM&T), European Commission (EC) regarding corrective measures taken by Pakistan Civil Aviation Authority (PCAA) to prevent reoccurrence of safety deficiencies, the European Union Aviation Safety Agency (EASA) has broadened its scope of investigation and will conduct audit before considering the lifting of flight suspension.

The EASA in its letter to the Pakistan International Airlines (PIA) informed that the agency reviewed the submitted material provided by the airline as evidence to support the implementation of the agreed corrective action plan for the remaining open level-1 finding related to identify issues in airline’s safety management system (SMS) and found it satisfactory and sufficient as a first important step towards the closure of the findings.

Considering the recent suspension for safety concerns, it was further informed that the agency shall conduct audit of the third country operator (TCO) when considering the lifting of a suspension when the conditions in ART.205 (c) are met in accordance with regulation 452/2014 (TCO regulation) and in particular article ART. 235(d) of part-ART.

The EASA also stated that the conditions laid down in ART 205(c)(2) were not met and indicated that there was a possibility that the audit would not have the expected positive results as the investigation conducted by the EC on the issuance of professional licenses was still on-going.

On the other hand, the DGM&T, EC in its letter to PCAA confirmed that a continued concern with the measures taken by the PCAA in terms of a proper root cause analysis and suitable corrective measures to prevent reoccurrence of the same and similar safety deficiencies and added that the concerns still persisted about the PCAA safety deficiencies not only on the pilot licensing areas but on the whole licensing and authorization processes, application and oversight of SMS and the establishment of the occurrence reporting system, amongst others. Therefore, it has been decided not to make any changes to the list of air carriers subject to an operating ban with respect to air carriers certified in Pakistan.

Furthermore, it also informed that the EC would continue its monitoring further action and assessment of how the situation develops further and this may include a visit to Pakistan when travel conditions would permit it.

“EASA has this time extended their scope and included our national regulator PCAA in their investigation as well,” said Capt. Bijarani, Vice President Pakistan Air Line Pilots Association  (PALPA).

He said that PCAA has been downgraded by EASA and now all airlines of the country might face a ban to fly to Europe if PCAA did not satisfy EASA by resolving license issues of pilots.

EASA, he added, has been concerned about SMS and issued many warnings to implement it by 2019 but PIA failed to do so.

“Instead of implementing SMS, the national airline introduced the ‘Essential Service Act’ which was completely against the spirit of SMS,” not only ESMA but also the de-recognition of unions and association which is a basic component of SMS to work by getting positive feedback from employees through unions and association. Capt. Bijarani.

He further said that this type of punitive culture works against the goal of SMS that requires participation of all unions/associations to implement it in a true manner.

This is the reason, he added, EASA has extended this ban to an indefinite period and now after their audit it will be clear whether they will lift the ban or not.

He said that EASA also monitors things on their own like ‘waiver flights’ the PCAA allows under any Air Navigation Order.

“EASA also shows its reservations on the procedure of issuing licenses to pilots and PCAA has to resolve this issue otherwise it is almost impossible to come out of this ban,” said Capt. Bijarani.

Similarly, he added, the International Civil Aviation Organization (ICAO) is also coming for an audit of PCAA in June 2021.

It is to be noted that ICAO conducts routine audits of its member states after every two years and PCAA’s last such audit was held in 2011.

“PCAA’s last audit in 2011 was also an eye-opener for us as ICAO put the PCAA in the yellow category and asked for corrective actions proposals,” one of the important corrective plans was the deputation issue, said Capt. Bijarani.

He said that PCAA assured ICAO of taking corrective action plans and set things right by different time frame but in fact they never did anything and got worse over the years, so much so failing to implement State Safety Program (SSP) till this date.

“We don’t know how CAA can resolve such issues in just six months till June 2021 when they could not do it in past many years,” until and unless they put the right people at the right places, said Capt. Bijarani.

He added that this time not only ICAO but EASA has also raised objections on almost every department and sector of PCAA including pilots’ licenses and their examination procedures.

Not only that PCAA received a warning letter on 3rd November 2020 to be put on ICAO’s website in significant safety concern (SSC), if the pilot license and the examination issue is not resolved within 90 days so the clock is ticking since 3rd November 2020.

Copyright Business Recorder, 2020

Pakistan Flag


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