There is one aspect of every aviation organization that is used daily but is often overlooked - your company's operating manuals. It can be argued that you are constantly revising your manuals and they are not overlooked, but when you think about it, what condition are they really in?

14 CFR Part 121.133 requires that each certificate holder prepare and keep current manuals for the use and guidance of flight, ground operations, and management personnel in conducting its operations. This is done when an operator initially applies for a certificate. How long has it been since your manuals were originally produced and approved? Think how much has changed within that time: Not only within your own organization, but also in terms of regulations and industry best practices. Over the years your manuals may have been updated, fixed, revised, and modified; but chances are your manuals are out of date and not in sync with the latest regulations, ATOS SAIs or company procedures. JDA has supported many operators and reviewed lots of manuals. Some of the common problems we see are:

1. Incorrect regulatory references

The regulations are constantly being updated. 14 CFR Part 121.135(b)(3) requires that reference to the appropriate regulations be contained within your manuals. If you break down the regulations into their letter and number subparts, you are looking at hundreds upon hundreds of regulatory references in your manuals. How often have your manuals been updated to reflect these changes? How many incorrect or out-of-date references exist within your manuals?

2. References to programs or aircraft that are no longer in the organization

As companies grow and evolve, they migrate to new software or company programs, transition out older model aircraft, etc. When this happens the manuals must be updated to reflect the current state of the organization. The problem is it is difficult to find all those references within thousands of pages of manual content. A search and replace can catch many of them, but there are always those few references that get missed. This causes confusion when a procedure refers to a program or aircraft that no longer exists.

3. Missing or incorrect procedures

Number two and three are closely related. As the company brings in new programs and aircraft, procedures need to be updated or added. This may not always happen, or if it does happen, it's generally piecemeal within the manual. 14 CFR Part 12.135(a)(1) requires that the manuals "Include instructions and information necessary to allow the personnel concerned to perform their duties and responsibilities with a high degree of safety." It's difficult to comply with this rule when your manual contains missing or incorrect procedures.

4. Mismatched content

Content is often duplicated multiple times through an organization's manual set. More often than not when content is updated, only pieces of it are updated. Sections may be inadvertently missed when the manual set is updated. This becomes confusing to employees and the regulators. It becomes a question of which content is correct and which is incorrect.

5. Lack of Safety Management System (SMS) and Air Transportation Oversight System (ATOS) (121 operators) Integration

SMS is going to become a regulatory requirement within the next 3-5 years. For 121 operators, and most likely 135 and 145 operators in the future, ATOS conformance is very important as a reference to how the ATOS Safety Attribute Inspection (SAI) must be clearly delineated in your FAA approved manuals. How is your organization incorporating these programs into your manuals? An operator will never have a proper SMS until it is fully integrated into their operations and either included in their operating manuals or documented in a separate SMS manual. A 121 operator will find it very difficult to conform with ATOS without having the five ATOS SAI tenants (procedures, controls, interfaces, process measures, and responsibility and authority) written into their system. Neither SMS or ATOS can be easily incorporated into your manual system without a thorough review of your current manual set (gap analysis) and a manual revision plan. How are you meeting your SMS and, if applicable, ATOS needs?

Bounce these five common problems against your own manuals and you may start to realize that your manuals aren't in the condition you thought. But there is no need to fret, it's fixable but requires careful planning and the right resources. Updating your manuals involves an in-depth look at your organization including the structure, programs, operations, goals, and FAA requirements. Fortunately JDA has decades of experience assessing and revising manuals so you can continue with your day-to-day responsibilities of operating your organization without having to dedicate valuable in-house resources full time to revising and updating your manuals. The end product will be a fully compliant manual suite that references/links with the regulations, conforms with ATOS and has all the System Safety and SMS components documented.


Positive Safety Culture Checklist

Are you 100% certain that your organization can check these attributes?

• Effective Communication
• Learning Organization
• Safety Focus and Priority
• Good External Reputation
• Committed Resources
• Participation & Involvement
• Management Commitment & Visibility
• Productivity & Safety Balance
• Training
• Good Working Environment
• Job Satisfaction
• Competent and Experienced Workforce

Or, is your organization like many where:

• Sometimes it is necessary to take chances to get a job done.
• Sometimes it is necessary to turn a blind eye when safety rules are broken.
• Our leaders say "Safety First," but they don't really mean it.
• Management in my plant is not committed to safety.
• Most accidents are caused by carelessness.
• Employees that make mistakes are punished.