Ground handling is often overlooked within Business Aviation, notes Mario Pierobon, even though ultimate responsibility for contracted services rests with the operator. What are the basic checks you can make to ensure your service provider complies with the requirements?
Business Aviation hubs normally do not have the same level of traffic as the large international airports used by the Scheduled Airlines. Denser activity naturally poses a higher risk of collision between ground support equipment and aircraft. Nevertheless, even on quieter ramps the safety of flight can be compromised when ground service providers operate with a limited focus on the quality and safety of the service they render.
This mind-set can especially be a problem for business aircraft operating into developing countries with relatively undeveloped oversight regimes.
It’s actually a regulatory requirement for air operators themselves to verify that contracted activities conform to applicable law – e.g. EASA’s AIR OPS organizational requirements [ORO.GEN.205] call for operators to ensure that when contracting or purchasing any part of their activity, the contracted or purchased service or product conforms to the applicable requirement.
Further, when an operator contracts any part of its activity to an organization that is not itself certified or authorized in accordance with EASA to carry out that activity, the contracted organization is required to work under the approval of the operator.
Thus, the air operator must also ensure that the competent authority is given access to the contracted organization, to determine continued compliance with the applicable requirements.
Ground handling and ground de-icing/anti-icing are specifically detailed in regulatory guidance materials to ORO.GEN.205 as activities that operators may decide to contract to external organizations and thus subject to scrutiny by the air operator as contracted activities.
The key point to understand is that the ultimate responsibility for aircraft ground handling services provided by external organizations remains with the air operator.
Under its safety management system the air operator is responsible for ensuring all contracted activities, including ground handling services, are subject to hazard identification, risk management and compliance monitoring.
In the case of a contracted organization itself being certified or authorized to carry out the contracted activities (e.g. when an air operator flies to a destination where the ground handling company contracted operates under the AOC of an air operator based at the given destination), the operator’s compliance monitoring function should at least check that the approval effectively covers the contracted activities and that it’s still valid.
In addition to legal considerations, best practices call for the air operator, regardless of the regulatory environment, to provide sufficient oversight to ensure safety.
Ascertaining Safety Standards
An IS-BAH registration is one way for air operators to ascertain that the ground handling services they purchase are of a safe standard. The International Standard for Business Aircraft Handling (IS-BAH) is a set of global industry best practices for Business Aviation ground handlers featuring at its core a safety management system (SMS), and is meant to provide standardization to handlers and operators around the world to meet SMS requirements.
An IS-BAH registration provides evidence that the handling company has an SMS in place (i.e. that it actively manages safety hazards, and that it meets selective quality and safety standards). The IS-BAH registration should simplify audit redundancy and specifically the need for operators to continuously audit third-party ground service providers.
It should be noted, however, that for the time being there are only a limited number of organizations providing business aircraft handling services with an IS-BAH registration. It will take time before the IS-BAH program achieves the critical mass whereby a significant network of IS-BAH-registered business aircraft handling companies is developed.
In the meantime the only option is for operators to continue to subject third parties to compliance monitoring.
While it may be impractical to audit an organization whose services are needed only occasionally, an effort should be made to monitor the agents whose services are known to be needed on a recurrent basis.
Aircraft ground handling is notorious for having limited prescriptive regulatory requirements. Nevertheless an air operator should expect that its third-party handlers perform hazard identification and safety risk assessments and that the results of these are incorporated into operating procedures.
The compliance monitoring function should look into operating practices and training programs (which must be documented) and verify that they are subject to continuous improvements covering the whole scope of aircraft handling; that they are documented to a sufficient extent to be unequivocally interpreted by the personnel who implement them; and that they lend themselves to be tailored to the air operator’s request should the air operator need peculiar ground service specifications.