I've seen my fair share of aerodrome manuals. Every audit begins with a review of an aerodrome manual and in my past life as a consultant, I wrote a few as well. Unfortunately, the state of the vast majority of aerodrome manuals I've encountered, including my own, could best be described as "needs improvement". But before we get to the tips, let’s just rehash the aerodrome manual rationale. Why do we have this document?
The easy answer would be to say we have aerodrome manuals because Civil Aviation Safety Regulation (CASR) 139.090 says we must - but that's not a real reason.
To me, there are two purposes to the manual. One, the more obvious, is that the manual is a set of procedures designed to ensure consistency, completeness and to meet the organisation's objectives. The other purpose is closely tied to the aerodrome certificate. The aerodrome manual serves as the "contract" between the certificate holder and the regulator. The certificate was granted, in a large part, because CASA considered the policies and procedures contained in the manual acceptable.
When the manual doesn't match reality, we got a problem. So, let's try and fix that...
By carrying out a manual review. Conducting a periodic review is a great idea. It’s not a mandatory regulatory requirement. It’s simply a great idea. If you want to make it a stellar idea - make a review a documented procedure in the manual itself. That's not to say that you need not update the manual as required (as per CASR 139.105) but a regular, comprehensive, structured review will help regardless of how "on top of it" you are.
Now that you're convinced of how good an idea this is (you are, aren't you?), here are five things you should think about when conducting your brilliant idea review.
1. Look for Changes
A lot of things change - people come and go, phone carriers are switched, critical aircraft and their operators and even government legislation and regulation. On every page look for things that are likely to change and check that they are still correct. And I mean check - call numbers and speak to people, visit websites and go watch the regular traffic for a week.
One of the more subtle changes in "recent" memory was the move from the Bureau of Air Safety Investigation and Part 2A of the Air Navigation Act 1920 to the Australian Transport Safety Bureau and the Transport Safety Investigation Act 2003. That's right, 2003. It’s been almost 8 years but I still spot the odd reference. What is even more subtle though is that many manuals simply replaced the titles of the acts and not the actual details in the manual. The powers granted to the ATSB were not the same as for the BASI. More than a "find & replace" is often required.
2. Who's who in the Zoo?
This one is more than just updating names. This is more about positions and responsibilities. Firstly, I often advise that aerodrome manuals refrain from using actual names of people anywhere other than in the master contact list. That way, when people do change, only one page needs amending. Now, which titles to use?
You could use the actual titles people hold within the organisation or you could use aerodrome specific titles. At many aerodromes, the aerodrome manager or the aerodrome reporting officer are not employed as an aerodrome manager etc. They are mostly likely the director, engineering services or works supervisor or even sanitation technician. On top of that, now consider that the one person may fill numerous roles at the aerodrome.
I don't have a definitive opinion on this one. Both could work if the approach is applied consistently and supported by external processes if needed. The main considerations to be made are qualification, future-proofing and clarity.
If you use non-aerodrome position titles consider how to comply with the training requirements contained in CASR Part 139. If the parks attendant is the aerodrome reporting officer is having completed an ARO course a requirement of that position, is it in the position description. If not, how will the human resources department know that the next parks attendant needs such a qualification?
By clarity, I mean that when you use aerodrome specific titles, do the words in the document make sense. This example I see often - the council CEO is named the aerodrome manager in the aerodrome manual, the council is named the safety officer in the aerodrome safety management system document and then the document says that the safety officer has a direct line of communication to the aerodrome manager. Well, of course he does, they are one and the same person! This tells me, as an auditor, that the aerodrome operator is relying on template documents too much and has probably not actually read their own procedures.
3. Do as it Says or Say as You Do
CASR 139.145 requires the aerodrome operator to follow its own procedures. Therefore if you are doing something or failing to do something in contravention of your own manual, you are in contravention of the regulations regardless of whether your action otherwise meet the rest of CASR Part 139 etc.
This means that if your manual says that airside drivers must wear a pink tutu and they don't, then you are failing to meet your regulatory obligations. Alright, that one's silly. Let's say your manual says you will inspect the aerodrome each weekday at 0600 but you only do it on the three days that an airline service operates and you do it at 0900. You are meeting the requirements of CASR 139.225. But by failing to operate in accordance with the manual on this count, it casts doubt on your application of the rest of the manual.
Its not all doom and gloom, just make sure that what you do and what the manual says you do are the same thing and they both meet the requirements contained in CASR Part 139 and the Manual of Standards Part 139. To do this you can either change what you are doing to align with the manual or change the manual to align with what you’re doing. It’s your manual after all.
4. Think Processes
When reviewing the manual, look to see that the entire process is laid out. Think about the who, what, where, when & how. Also think about record-keeping - remember: if it ain't recorded, it didn't happen! This doesn't mean that the simplest activity needs pages of how-to's. There is nothing wrong with keeping it simple.
Think about the following:
- Responsibility - Who is responsible for this process and what is the level of their responsibility? Do they actually do the procedure or do they ensure that it is done?
- Mandatory - Use the words "shall", "must", "is to" or "will" for mandatory procedures and "should", "can" or "may" for recommended actions.
- Detail - Consider less detail where procedures are covered by well-documented standardised training. For example - there is no need to include mandatory radio transmission phraseology in the manual because everyone using a radio has received training in accordance with Civil Aviation Regulation 83 (right?).
- Records - How are records created? Forms, logbook, database etc. and where are they to be found, say, during a CASA audit? For how long will they be kept?
5. Document Control
Now that you're ready to make some amendments, please consider some of these document control best-practices. Employing these will help manual holders identify the currency of their documents and identify the changes that were actually made.
- Dates - Most manuals are riddled with dates - one on the cover page, the checklist of current pages, every page footer. You need to make sure that they are consistent. Depending on how your electronic document is arranged this may necessitate the amendment of sections at a time and may require the introductory section to be completely updated every time as well.
- Mark-up - Black lines in the margins or even bold text on the actual changes helps readers to identify what actually changed. There is nothing more boring than receiving a manual amendment consisting of a ten-page section where only two words were amended yet the whole section had to be read word for word with its predecessor to find the changes.
Well, that's enough ranting out of me. I'll be at my desk tomorrow awaiting your latest manual amendments with bated breath.
* I'm actually in the field at the moment with a pretty poor internet connection, so I can't put in all the links I wanted to put into this post. When I get back to town, I'll update this post with appropriate links