ICAO’s USOAP 20th anniversary of ACTIVITIES- time to RETHINK?

USOAP Countries with IASA Category 2 and their ICAO ratings
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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 safety audit programme celebrates 20-year anniversary

ICAO USOAP AWARD

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.

 

 

 

 

 

 

 


USOAP globe

 

 

 

 

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.

 

ICAO USOAP report

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.

 

The ICAO award also does not mention that these activities are redundant. The truly independent Flight Safety Foundation identified four different forms of international audits (full article):

Air Safety Network Flight Safety Foundation

ICAO Universal Safety Oversight Audit Programme
FAA’s IASA

IATA’s IOSA
EU Blacklist
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[1].

If quadruple audits are not taxing enough, consider that the different reviews do not produce congruent critiques.[2] 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!!!

all auditors


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!!![3]

 

YOUR COMMENTS WOULD BE APPRECIATED!!!

[1] Redundant Safety Systems-YES, Duplicative Audits-NO; How Many International Audits Are Enough?;

[2] ICAO Removes Thailand’s Red Flag Two Years After A Finding Of Deficiency ISO Certifies ICAO’s USOAP; What Does The FAA IASA Downgrade Of Malaysia Really Mean In Terms Of Aviation Safety?; ICAO Recognizes The Ghana Civil Aviation Authority’s Progress; FAA Has Problems Thailand’s Below Average Scores, But Not ICAO–WHAT’S UP?; FAA’s IASA Audit Vietnam CAA’s Poses Some Seminal Questions

[3] Reflections On The Global System Aviation Safety Audits; Redundant Safety Systems-YES, Duplicative Audits-NO; IATA Director General Defines Problem, Here’s A POSSIBLE SOLUTION; ICAO Defines International Safety Problems, The US Government Should Initiate A Global Solution Program

 



 

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1 Comment on "ICAO’s USOAP 20th anniversary of ACTIVITIES- time to RETHINK?"

  1. Sandy points out that once deficiencies in a State’s oversight are identified it is that same State’s responsibility to fix the problems. True but some comments:
    a) In the Commission’s discussions at one point it was proposed that the audits would be conducted by the ICAO technical assistance Office. Some Commissioners opposed that on the basis that the audits should be operational, and not have the possible tinge of project proliferation.
    b) It was my experience the aviation officials in many States were aware of their problems and used the “public exposure” from a recognized, and respected international organization, to convince their Governments that action needed to be taken. I remember one Assembly meeting when three representatives from African States requested a meeting with Tony Broderick. They used my office to explain to Tony what they were doing to fix their problems.
    c) Enforcement in the ICAO system comes from the Member States. If a USAOP reports indicates action needs to be taken it is the Member States that should do it.
    Next is the question of multiple audits. Of the four noted two deal directly with the States of Registry, two deal directly with the airlines, as Sandy has pointed out, moving to the States if significant deficiencies are found. ICAO’s program grew directly from the FAA’s and their findings of significant problems with the first few States audited by the FAA.
    Sandy is correct in proposing that these two programs should merge into one. In the early days FAA specialists participated in ICAO audits with ample opportunity to judge their competency. At the time I never heard any major complaints.
    I even tried to get such a proposal into the Administrator’s speech at the opening of an Assembly. Needless to say, I escaped with my job. There no reason that the FAA couldn’t participate in audits of States that are of interest. It would serve to eliminate differences in evaluation that we now experience, and it would reduce some of the burden on DGCAs.
    I do think that if the FAA decided that drastic action was necessary that an FAA only audit would be necessary.
    The EU and IATA are a different philosophy, They start with the airlines. It surely would be better if they joined in the ICAO program but it would mean a change in philosophy. More so with IATA, perhaps, since theirs is an “in-house” program.
    By now it should be obvious that I think ICAO should do the auditing. One day, when the ICAO Council was debating USOAP, one State representative spoke against the FAA program as being aimed at giving US carriers advantage over the State’s carriers. That sort of accusation is less likely when ICAO does the audit.
    There is the question whether there is another organization that could take the responsibility, such as the Flight Safety Foundation. Funding is the problem with that possibility. When I was on the Commission, we toyed with the idea to get RTCA more involved directly with the development of technical SARPS. Seemed like a great idea until they mentioned they would have to be paid. (I actually thought maybe the funds would come out of the FAA program, but that would defeat the purpose.) Last I knew USOAP is funded from the regular ICAO budget. Separate funding would be subject to those who don’t want to be audited, or to those States who just decide to withhold funding.
    Sandy proposes an international SMS process and simplified Standards. Taking the second first, consideration of simplifying the Standards was a discussion that was well established before I left Montreal. It is not as simple as it sounds.
    SMS is another question. If ICAO could be a secondary place to receive reports on possible safety problems. They could be used in the next audit to see if action actually had been taken A politically sensitive route but maybe doable. ICAO audit teams could use the reports (diplomatically) on site.
    I regret that ICAO doesn’t report on the success of the program, even if it’s small. I believe that things have to be better. It’s got to be don’t you think?

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