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Transcript of Presented to: Pacific Aviation Directors’ Workshop By: Jim Spillane, Sr. FAA Representative,...
Presented to: Pacific Aviation Directors’ Workshop
By: Jim Spillane, Sr. FAA Representative, Pacific Rim
Date: 3/14/2012
Transition to the USOAP Continuous Monitoring Approach(CMA)
Federal AviationAdministration
Global Transition to USOAP CMA2012
2
Transition to CMA• Background on CMA
– What is CMA– How USOAP Evolved to CMA– Benefits
• CMA Components– How it works– State Safety Risk Profile
• US Transition
• What States Can Do– What States Can Do– Challenges
• Role of Regional Offices and RSOOs
Federal AviationAdministration
Global Transition to USOAP CMA2012
3
What is CMA?
• CMA is the next evolution of the USOAP
• The objective of CMA is to promote global aviation safety through continuous monitoring of Member States’ safety oversight capabilities
Federal AviationAdministration
Global Transition to USOAP CMA2012
4
What is CMA?
• CMA provides a mechanism for ICAO:
– To collect safety information from Member States and other stakeholders on a real time basis
– To analyze the information using a risk-based approach to identify and prioritize appropriate activities to be carried out by ICAO
Federal AviationAdministration
Global Transition to USOAP CMA2012
5
How USOAP Evolved to CMA
Mandatory Audit
Programme (USOAP)
A32-11
1999 – 2004
181 Audits, 162 Follow-
ups
Annexes 1, 6, 8
(Annex-by-Annex
Approach)
35th Assembly
2004
Comprehensive Systems
Approach (CSA)
2005 – 2010
177 Audits Safety-related
provisions in all Annexes
36th Assembly
2007
Development of
Continuous Monitoring Approach
(CMA)
beyond 2010
A36-4
Federal AviationAdministration
Global Transition to USOAP CMA2012
6
Benefits
• Collective sharing of safety data
• Continuous monitoring of capabilities and performance- “real time”
• Proactive approach to safety- better analysis
• More efficient- less labor and resource intensive
Federal AviationAdministration
Global Transition to USOAP CMA2012
7
CMA Audit Areas
Federal AviationAdministration
Global Transition to USOAP CMA2012
8
CMA Components
Collection of safety information
Determination of State’s safety risk profile
Update of Lack of effective implementation (LEI) and status of SSCs
Prioritization and conduct of USOAP CMA activities
Federal AviationAdministration
Global Transition to USOAP CMA2012
9
How it Works
Through an online framework States will
provide information through:
- State Aviation Activity Questionnaires (SAAQs)
- Updating the Compliance Checklists and Electronic Filing of Differences (EFOD)
- Updating USOAP Protocol Questions (PQs)
- Updating Corrective Action Plans (CAPS)
Collection of safety information
Federal AviationAdministration
Global Transition to USOAP CMA2012
10
How it Works
External Stakeholders that have audit programs,audit activities, or generate safety data or information will provide input to ICAO • External Stakeholders include:
– European Aviation Safety Agency (EASA)– EUROCONTROL– International Air Transport Association (IATA)– Regional Aviation Safety Oversight Organization (RSOOs)
• Formal agreements must be in place with ICAO
Collection of safety information
Federal AviationAdministration
Global Transition to USOAP CMA2012
11
How it Works
ICAO analyzes all of the data to determinesafety risk indicators and management capabilities • Safety Risk Indicators
– Lack of effective implementation of standards (LEI)– Existence of Significant Safety Concerns (SSC)– Level of aviation activities for each audit area– Level of acceptability and progress of implementing CAPs– Ongoing or planned assistance projects– Progress in implementing a Safety Management System
(SMS) and a State Safety Program (SSP)
Collection of safey information
Determination of State’s safety risk profile
Federal AviationAdministration
Global Transition to USOAP CMA2012
12
How it Works
Based on a States’ safety risk profile, ICAO will prioritize and conduct CMA activities
• CMA Activities include:
- Comprehensive Systems Approach (CSA) audit
- Customized safety audit based on specific findings
- ICAO Coordinated Validation Mission (ICVM) to ensure that all data and Finding and Recommendations are addressed
Collection of safey information
Prioritization and conduct of USOAP CMA activities
Federal AviationAdministration
Global Transition to USOAP CMA2012
13
How it Works
After ICAO conducts CMA activities they will update the
LEI and status of SSCs
• Information will be collected through:
- Mandatory Information Requests (MIRs)
- Findings and Recommendations
- Significant Safety Concerns
- Corrective Actions Plans
Update of Lack of effective implementation (LEI) and status of SSCs
Federal AviationAdministration
Global Transition to USOAP CMA2012
14
Overview of State Roles in CMA
•Manages the States’ continuous monitoring program
•Submits and regularly updates relevant CMA reporting documentation (SAAQs, EFODs, Compliance Checklists, CMA Protocols, SSP etc.).
•Implements corrective and mitigation actions in a timely manner to address safety deficiencies, and
•Participates actively in the CMA process.
Federal AviationAdministration
Global Transition to USOAP CMA2012
15
CMA Stakeholders
• ICAO– Technical Cooperation Bureau– Regional Offices– Secretariat Bureaus
• External– International Organizations (IATA, EASA…)– Regional Aviation Safety Groups and Oversight Organizations
• Information sharing is key!– U.S., ICAO, EC, IATA signed a data sharing agreement at the 37th
Assembly.
Federal AviationAdministration
Global Transition to USOAP CMA2012
16
What States can do• States obligation for CMA transition:
– Nominate a National Continuous Monitoring Coordinator
– Sign CMA MOU
– Update Corrective Action Plans
– Update State Aviation Activity Questionnaire
– Validate differences already sent to ICAO under the CSA
Federal AviationAdministration
Global Transition to USOAP CMA2012
17
Challenges for States• The initial validation of differences sent to ICAO can be very time
consuming, especially for States that have not continuously filed differences
• States no longer just file differences but now must submit how they comply with a standard. This may require a new business process
• It may take some time to become familiar with the online framework. ICAO has step by step instructions
• ICAO Regional Offices and Regional Safety Oversight Organizations will have a greater role in validating State submitted data. This may require new business processes but can also provide greater assistance to States.
• States must remain vigilant in keeping online framework current. If States fall behind it may trigger an ICAO audit.
Federal AviationAdministration
Global Transition to USOAP CMA2012
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Roles of RSOOs in CMA• RSOOs can develop collaborative networks
• RSOOs can play an important role assisting States
• RSOOs can help in establishing mandatory and voluntary incident reporting systems
• RSOOs can facilitate the efficient collection, storage, analysis and exchange of safety data and information.
Federal AviationAdministration
Global Transition to USOAP CMA2012
19
United States-Transition to CMA
• Support for CMA
• Transition
• Conclusions
Federal AviationAdministration
Global Transition to USOAP CMA2012
20
Support for CMA
• The United States recognizes that Member States’ sustained support for the transition to CMA is key to moving USOAP to a more efficient and resourceful approach.
• The United States strongly supported the transition to CMA at:– CMA Work Groups and Council meetings– ICAO High Level Safety Conference – ICAO 37th Assembly
Federal AviationAdministration
Global Transition to USOAP CMA2012
Transition
• Global Issues Team briefing LOB’s Feb 2012• ICAO Tools training March 2012
• Compliance Checklist and CAPs updated by July
• Ready for transition December 2012
21
Federal AviationAdministration
Global Transition to USOAP CMA2012
22
US Conclusions on CMA
• The United States is supportive of CMA• Transition to CMA requires extensive updating
and validating• Notification of Compliance requires additional
time and procedures• The SSP is the regulatory foundation that CMA
is built upon• Information sharing is key
Federal AviationAdministration
Global Transition to USOAP CMA2012
Questions?
23
Federal AviationAdministration
Global Transition to USOAP CMA2012
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Transition Timeline for States
2011
• Update CAP• Update SAAQ• Sign CMA
Agreement• CMA/EFOD
Training
2011
• Update CAP• Update SAAQ• Sign CMA
Agreement• CMA/EFOD
Training
2012
• Update CAP• Update SAAQ• Audit protocols
2012
• Update CAP• Update SAAQ• Audit protocols
2013
• Update CAP• Update SAAQ• Audit protocols
2013
• Update CAP• Update SAAQ• Audit protocols
Federal AviationAdministration
Global Transition to USOAP CMA2012
25
Actions for Transition• Sign Memorandum of Understanding with ICAO
– MOU is currently under going approval at the ICAO Council
• Identify a National Continuous Monitoring Coordinator
• Update and Validate– State Aviation Activity Questionnaire (SAAQ)– Differences– Corrective Action Plans
Federal AviationAdministration
Global Transition to USOAP CMA2012
26
Tools of CMA
• State Aviation Activity Questionnaire
• Electronic Filing of Differences
• Corrective Action Plans
• State Safety Program (SSP)
Federal AviationAdministration
Global Transition to USOAP CMA2012
27
Update and Validate
• SAAQ– Updated on a regular basis
• Differences– Differences are updated by response to State Letters
with every amendment– Validating our differences in the EFOD database– Currently reviewing our compliance and differences with
over 10,000 filed SARPS
• Corrective Action Plans – Continuously reviewed and updated
Federal AviationAdministration
Global Transition to USOAP CMA2012
28
Electronic Filing of Differences
• No longer just filing “differences”, now must also file compliance
USOAP CSA USOAP CMA•Level of Implementation
•Text of Difference
•Comments
•If difference exists than cite regulation
•Level of Implementation
•Text of Difference
•Comments
•Cite regulation of compliance or difference
Federal AviationAdministration
Global Transition to USOAP CMA2012
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• United States is updating “compliance”
• During update and validation of EFOD we found 1,000s of SARPS that need to be notified to ICAO
• Assumed that with responses to State Letters and updating EFOD that ICAO had validated all differences
• United States is now validating all differences filed with ICAO
EFOD
Federal AviationAdministration
Global Transition to USOAP CMA2012
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EFOD
Reports on Difference to be Notified to ICAO
Federal AviationAdministration
Global Transition to USOAP CMA2012
31
Corrective Action Plans
• The United States continuously updates the corrective action plans– Now found in the ICAO iSTARS
• If filing a new difference, the U.S. submits information on intent to comply, status of rulemaking, and timeframe of compliance
Federal AviationAdministration
Global Transition to USOAP CMA2012
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State Safety Program
• United States has a mature SSP through policies, procedures and regulations
– FAA Orders- 8000.370, 8000.369, VS 8000.367, 5200.11, 7110.65, 7210.3, 7010.1, 7210.6, 8020.6
– AC 120-92A, AC 150/5200-37, – Notice of Proposed Rulemaking Dockets- 2009-0671, 2010-0997
• Currently formatting to comply with the ICAO framework for an SSP