ICAO’s USOAP 20th anniversary of ACTIVITIES- time to RETHINK?
Activities v. Actions
Audits at a Point in Time v. Continuous Collaboration
Duplicative, even contradictory, Audits
Single, Consolidated, Consistent, Cooperative
In a self-congratulatory press release (see below), the ICAO President commemorated 20 years of Universal Safety Oversight Audit Program (USOAP) ACTIVITIES (later quote cites “900 activities”).
ICAO HQ, Montréal, 11 March 2020 – During a special ceremony conducted at yesterday’s fourth meeting of the ICAO Council’s 219th Session, ICAO Council President Salvatore Sciacchitano accepted a framed gift from the UN agency’s Secretary General, Dr. Fang Liu, commemorating the 20th Anniversary last year of ICAO’s Universal Safety Oversight Audit Programme (USOAP).
Dr. Liu highlighted that “the one constant throughout the programme’s history has been its commitment to adapt to achieve its objectives through continuously more effective and efficient approaches,” and that she looked forward to “the improvements now being considered to enhance the efficiency of the USOAP while maintaining safeguards to guarantee its independence, universality, standardization and global acceptance.”
Mr. Sciacchitano appreciated that the prestigious ICAO programme had completed close to 900 activities since its inception, of which more than 450 were audits…
The USOAP programme continues to be one of the most visible that ICAO has launched in the last two decades. Its eight Critical Elements (CEs) have provided an aligned set of safety oversight categories for the aviation community to work with, and the Effective Implementation (EI) metric ICAO uses to measure safety oversight performance under the USOAP is just as widely understood as an important and objective global aviation safety indicator.
The record cited does not include any mention of objective, substantive, measurable improvement in the performance of the ICAO members’ regulatory actions.
Audits are comparable to a still photograph at a point in time. The USOAP assesses structures, standards, processes, statutes and even staff while the ICAO team was there. Regulatory performance is a movie in which those civil servants implement and apply standards over time.
The USOAP team travels around the world to “audit” the competence of their Members against a comprehensive set of criteria. After their work is done, they leave the CAA being reviewed with a list of deficiencies. It is incumbent on the institution being criticized to heal itself. The very same individual, hypothetically, found deficient is charged with taking remedial steps. Another example, a USOAP finding that the CAA lacks necessary statutory independence must be rectified by that civil servant, stereotypically, has to tell his/her Minister or Parliament that political influence must be reduced [consider that conversation and wonder if the bureaucrat updates her/his resume before the meeting].
The point is that an audit and leave process makes it very difficult to see improved regulatory actions as a result of the USOAP. For example after 20 years of audit the lack of advances in real regulatory performance is the recent ICAO convening of a Member meeting to review pilot licensing standards. The release acknowledge that the review was “part of a discussion that has gained urgency following two fatal crashes of Boeing 737 Max aircraft in the past year.” (i.e. concern that the CAA did not rigorously test the pilots). To support this thesis there are analyses of these accidents which have included strong suggestions that the training of the pilots was deficient. The UN audits likely saw the pilot training standards reflected the ICAO criteria, but the auditors appear not to have examined whether the actual application of criteria was effective.
ICAO Universal Safety Oversight Audit Programme
EU Safety Assessment of Foreign Aircraft – SAFA
Consider that these CAAs working hard to perform the essentials must deal with all of these foreign VIPs crawling around their offices to find fault. Then, the civil servant must carefully write responses to these publicly announced critiques. More time away from their essential duties.
If quadruple audits are not taxing enough, consider that the different reviews do not produce congruent critiques. There is every reason for a CAA to minimize the value of this “feedback” in that the experts, supposedly using the same standards, come to different conclusions!!!
The 20th Anniversary poses an opportunity to reconsider the USOAP/IOSA/IASA/SAFA regime. Some thoughts to consider:
- consolidating these redundant audits into one
- a single review could
- reduce the burden on the CAAs and
- avoid the confusion caused by differing assessments
- the single analysis could change the process
- from fault-finding-and-leaving to
- a more SMS like process utilizing collaboration and cooperation
- recognizing that an approach defined by 189 Members in Montreal may not work elsewhere
- perhaps not the global ideal, but a realistic, achievable standard within the CAA’s competence
- emphasizing the process would allow the “consulting team” to help, for example, to identify the local talent capable of performing the required regulatory regimen and/or work with the political powers to define independence. STAY and COMPLETE the REMEDIAL ACTIONS.
Clearly a revolutionary proposal which will rock the boat in Montreal, Washington, Brussels/Cologne and other capitols. How will the consulting team be funded [ICAO alone, single bank account with deposits from all of the old auditors, etc.]? Who will select the team of professionals? How will this process be guaranteed real independence? Much needs to be debated, but now is a good time to venture into this initiative!!!
YOUR COMMENTS WOULD BE APPRECIATED!!!
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