IOSA Guidance For Safety Monitoring Under COVID-19: Edition 5 - 05 May 2021
IOSA Guidance For Safety Monitoring Under COVID-19: Edition 5 - 05 May 2021
under COVID-19
Edition 5 – 05 May 2021
1 – IOSA Guidance for Safety Monitoring under COVID-19 Edition 5 – May 2021
DISCLAIMER.
The information contained in this publication is subject to
constant review in the light of changing government
requirements and regulations.
No subscriber or other reader should act on the basis of any
such information without referring to applicable laws and
regulations and/or without taking appropriate professional
advice.
Although every effort has been made to ensure accuracy, the
International Air Transport Association shall not be held
responsible for any loss or damage caused by errors,
omissions, misprints or misinterpretation of the contents
hereof. Furthermore, the International Air Transport
Association expressly disclaims any and all liability to any
person or entity, whether a purchaser of this publication or not,
in respect of anything done or omitted, and the consequences
of anything done or omitted, by any such person or entity in
reliance on the contents of this publication.
© International Air Transport Association. All Rights Reserved.
No part of this publication may be reproduced, recast,
reformatted or transmitted in any form by any means, electronic
or mechanical, including photocopying, recording or any
information storage and retrieval system, without the prior
written permission from:
Senior Vice President
Safety and Flight Operations
International Air Transport Association
800 Place Victoria
P.O. Box 113
Montreal, Quebec
CANADA H4Z 1M1
2 – IOSA Guidance for Safety Monitoring under COVID-19 Edition 5 – May 2021
Table of Contents
Revision Record ........................................................................................................................................................................ 4
Revision Table ........................................................................................................................................................................... 4
1. Introduction ....................................................................................................................................................................... 5
2. Monitoring of Internal Operations and Maintenance Functions ................................................................... 5
2.1 General ....................................................................................................................................................................... 5
2.2 Operations under COVID-19.............................................................................................................................. 5
2.2.1. Monitoring Compliance with COVID-19 Relevant Requirements ..................................................... 5
2.2.2 Conventional Onsite Audits .............................................................................................................................. 6
2.2.3 Remote Audit ......................................................................................................................................................... 6
2.2.4 Risk Assessment of Active Operations to Ensure Conformity with IOSA Requirements......... 7
2.2.5 CCRD/ICAO Targeted Exemptions (TE) ....................................................................................................... 7
2.3 Limited Operations ................................................................................................................................................ 8
2.4 No Operations.......................................................................................................................................................... 8
2.5 Return to Normal Operations ............................................................................................................................. 9
3. Monitoring External Service Providers & Other Airlines ................................................................................... 9
3.1 Monitoring Service Providers ............................................................................................................................ 9
3.1.1 General ..................................................................................................................................................................... 9
3.1.2 ISAGO Program ..................................................................................................................................................... 9
3.1.3 IATA Audit Pools ................................................................................................................................................ 10
3.1.4 Other Methods for Monitoring External Service Providers ............................................................... 11
4. Codeshare & Wet-Lease Partner Safety Monitoring ...................................................................................... 12
4.1 Introduction ........................................................................................................................................................... 12
4.2 Operational & Safety Information Exchange between Airlines .......................................................... 12
4.3 Performance/Risk Based Monitoring of Partner Airlines ..................................................................... 13
4.3.1 Introduction ......................................................................................................................................................... 13
4.3.2 Review of operational and safety information ........................................................................................ 14
4.3.3 Establishing a partner airline risk profile................................................................................................... 15
5. Safety Assurance during COVID-19 ..................................................................................................................... 16
5.1 General .................................................................................................................................................................... 16
5.2 Emerging Risks to Monitor During COVID-19 .......................................................................................... 16
3 – IOSA Guidance for Safety Monitoring under COVID-19 Edition 5 – May 2021
Revision Record
Symbol Meaning
Addition
Amendment
Deletion
Revision Table
Edition Issue Date Chapter Description
4 – IOSA Guidance for Safety Monitoring under COVID-19 Edition 5 – May 2021
1. Introduction
During this unprecedented COVID-19 crisis, airlines around the world have been cancelling flights,
temporarily suspending operations and/or continuing with limited resources. Considering the
abnormal conditions under which operations currently take place, the effective and flexible monitoring
of quality, compliance, and safety management systems carry significant importance.
This document provides guidance to airlines on how to effectively manage quality, compliance and
safety monitoring during the COVID-19 crisis.
The recommendations provided herein are to be considered as a baseline for best practices. All
airlines should also follow regulations and guidance issued by their applicable authorities.
IATA will continuously improve and update this guidance in alignment with IOSA program policies.
Airlines are facing challenges in monitoring their operations. The following procedures are applicable
to the monitoring of internal operations and maintenance functions addressing risk assessment,
evaluation, auditing, and other acceptable methods to ensure compliance with all applicable regulatory
requirements and IOSA Standards and Recommended Practices.
The following summarizes the recommendations for the monitoring of the operations conducted
under COVID-19 measures, if the operations become limited or inactive or if the operations are
suspended.
Aviation authorities, as well as industry organizations such as IATA, are issuing new regulations,
guidance and/or alleviations to existing regulations concerning the management of the operations
affected by the COVID-19 crisis. Airlines should review the issued health and operational safety
requirements and adjust their procedures accordingly.
In this context, within the IOSA Standards Manual (ISM) Edition 13, ORG 3.2.2 states: “The Operator
shall have a process to identify changes within or external to the organization that have the potential
5 – IOSA Guidance for Safety Monitoring under COVID-19 Edition 5 – May 2021
to affect the level of safety risks associated with aircraft operations, and to manage risks that may
arise from or are affected by such changes in accordance with ORG 3.1.1 and ORG 3.1.2.”
Considering the above provision, airlines should ensure risk management is applied to any changes
introduced through new health and occupational safety requirements that have the potential to affect
the established operational processes, procedures, products, equipment and/or services. Also, risk
management should be applied to any organizational and operational changes imposed due to the
COVID-19 crisis.
IATA is closely monitoring developments related to this crisis, in coordination with the World Health
Organization (WHO) Secretariat, International Civil Aviation Organization (ICAO), and the US Centers
for Disease Control and Prevention (CDC).
Resources and guidance for airlines and other travel professionals can be found at
https://www.iata.org/en/programs/safety/health/diseases/.
If the current conditions allow onsite audits for the assessment of internal operations and maintenance
functions to be performed, airlines should perform such audits in accordance with processes and
procedures defined in their applicable manuals.
Airlines should also ensure relevant requirements and guidance related to operations during COVID-
19 such as social distancing rules, use of protective equipment, etc., are followed by the auditors and
auditee while the audit is being performed. Refer to the WHO site for relevant information.
If the current condition does not allow internal onsite audits to be performed, airlines may decide to
perform remote audits as an alternative method. Main processes and procedures relevant to such
method should be documented.
The following should be considered for the different phases of the audit process:
Audit Planning
• Detailed audit plan that includes scheduled calls and persons to be interviewed
• Internet connection and reliable communication equipment availability
• Documentation access (cloud server, file sharing platform, documentation software etc.)
• IT solutions for video conferencing and document sharing etc.
• Requesting a cross-reference list to enable an efficient remote assessment
• Determining the methodology and techniques to be used for assessing the records remotely
• Identifying the personnel to be interviewed
• Scheduling test sessions to review the quality of the video and audio and connectivity issues
as required.
Documentation Audit
• Reviewing the cross-reference list, when applicable.
• Assessing the documentation prior to the start of the remote audit
6 – IOSA Guidance for Safety Monitoring under COVID-19 Edition 5 – May 2021
• Validating documentation assessment results during the remote calls and interviews
• Analyzing the previous audit results and other information as applicable
Implementation Audit
• Assessing records and evidences provided through cloud storage or shared server, live
sharing of screens or any other acceptable methods
• Observing records and evidences through shared files or screens
• Uploading records and evidences into an auditing software
• Interviewing management and operational personnel through video conference tools
• Observing the operation through live video broadcasting
• Increasing sampling size whenever possible, to compensate for the lack of direct observation
of operations
2.2.4 Risk Assessment of Active Operations to Ensure Conformity with IOSA Requirements
If an airline is unable to perform onsite or remote audits due to a lack of resources or unavailability of
operational and/or management personnel, an assessment should be made to identify the risk levels
regarding the compliance with IOSA Standards and Recommended Practices (ISARPs).
As operations are performed under abnormal conditions, concerns regarding complying with each
ISARP should be determined and risks of not complying should be identified as follows:
• Provisions with immediate concerns requiring mitigation may be determined as high risk;
• Provisions with significant concerns requiring monitoring may be determined as medium risk;
• Provisions with minimal or no concerns may be determined as low risk
Risk of not complying should be identified for short term (0-30 days), medium term (30-90 days) and
long term (90-120 days).
Mitigating actions and monitoring methods should be established to include but are not limited to:
• Actions to ensure conformity for the high-risk provisions;
• Self-assessment by operational departments;
• Assessment of the reports and feedback from station manager/personnel, flight crew and any
other operational personnel; and any other acceptable methods.
Mitigating actions should be recorded and tracked.
IATA prepared a template for airlines to assist in the risk assessment of active operations. Here is the
link to the Risk Assessment Tool for ISARP Compliance.
In 2020, ICAO introduced COVID Contingency Related Differences (CCRD) subsystem in the existing
ICAO Electronic Filing of Differences (EFOD) system. The purpose was to capture any differences from
ICAO Standards on certification and licensing that may arise from mitigation measures due to the
COVID-19 pandemic.
7 – IOSA Guidance for Safety Monitoring under COVID-19 Edition 5 – May 2021
As of 1 April 2021, Targeted Exemptions (TE) system has been launched, replacing the CCRD system
with a three-months transition period. States that have issued alleviations through the CCRD system
are encouraged to return to normal operations as soon as possible, and if circumstances do not allow
them to do so, to enter their targeted exemptions into the TE system.
In comparison to CCRD, Targeted Exemptions (TE) are tightly scoped and time limited State-issued
exemptions to a specified subset of Standards, granted as a result of the COVID-19 pandemic.
If an activity related to an ISARP is subject to ICAO targeted exemptions, this should also be
considered when risk assessment is performed. IATA highly recommends that the following ISARPs
relevant to ICAO SARPs subject to Targeted Exemptions (TE) system are determined as high risk:
• FLT 3.3.4 - Medical Certificate currency (ICAO Annex 1 1.2.5.2)
• FLT 3.3.7 - Recency-of-experience (ICAO Annex 6 Part I 9.4.1.1 & 9.4.2.1)
• FLT 3.3.10 - Route qualification (ICAO Annex 6 Part I 9.4.3.5)
• FLT 2.3.2 - Pilot Proficiency Check (ICAO Annex 6 Part I 9.4.4.1)
The further detailed information is accessible through the following links:
• For CCRD please see:
https://www.icao.int/safety/COVID-19OPS/Pages/ccrd.aspx
• For TE (Targeted Exemption) please see:
https://www.icao.int/safety/OPS/OPS-Normal/Pages/Targeted-Exemptions.aspx
If any part of the operations became inactive due to the crisis, for example if the airline temporarily
suspended its passenger transport operations, it should adjust its quality assurance or compliance
monitoring program and audit plan and postpone relevant audits.
Before the inactive operations restart, airlines should consider one, or a combination of the following
monitoring methods:
• Conducting risk assessment of the operations’ compliance with requirements as defined in
3.2.4;
• Conducting remote assessment(s) before the inactive operation restarts as defined in 3.2.3;
• Collecting and analyzing the self-assessments performed by the relevant departments before
the inactive operation restarts;
• Any other acceptable method.
2.4 No Operations
If an IOSA registered airline temporarily ceased their operations and is unable to undergo or complete
a Registration Renewal Audit prior to the current expiration date, it may submit a claim of Extenuating
Circumstances for Audit Conduct in accordance with the procedures laid down in IPM Temporary
Appendix 6.10.1. Please refer to the IPM Temporary Appendix here.
If the airline’s entire operation is temporarily inactive due to the crisis or governmental measures, then
monitoring is important to anticipate and prepare for the operation restart. Before the operational
8 – IOSA Guidance for Safety Monitoring under COVID-19 Edition 5 – May 2021
restart, the airline should ensure necessary measures are in place and consider one or more of the
following monitoring methods:
• Conducting risk assessment(s) of operations’ compliance with the requirements as defined in
3.2.4;
• Conducting remote assessment(s) before the inactive operation restarts as defined in 3.2.3;
• Collecting and analyzing the self-assessment(s) performed by the relevant operational
department(s) before the inactive operation restarts;
• Any other acceptable method.
Before and when the Operator restarts its operations, internal monitoring activities laid down in this
document should consider all exemptions granted by the authorities and all new types of operations
such as transport of cargo in passenger aircraft.
Also, monitoring of key organizational changes (e.g. changes in operational personnel, management
personnel, post holders, safety and quality personnel) and their effect are essential before returning
to normal operations.
Additionally, Operators should revise the quality assurance / compliance monitoring program to
ensure areas with higher risks are prioritized. This should include the operational areas to monitor
during COVID-19 listed in Ch 5.2. This could be performed through the procedures described in 3.2.4
Risk Assessment of Active Operations to Ensure Conformity with IOSA Requirements.
3.1.1 General
Similar to internal monitoring activities, airlines are likely to face difficulties and challenges in the
monitoring of their service providers during this COVID-19 crisis. Thus, the following illustration
summarizes the recommendations intended to provide assistance with the monitoring of external
service providers.
IATA's Safety Audit for Ground Operations (ISAGO) program offers airlines several benefits when used
as part of the monitoring of ground operations safety. The program is recognized as an acceptable
9 – IOSA Guidance for Safety Monitoring under COVID-19 Edition 5 – May 2021
means of conformance with the IOSA requirements related to risk management and oversight of such
outsourced arrangements.
ISAGO is particularly beneficial for an airline that as a result of the COVID-19 crisis found itself with
depleted auditing resources, requiring new ground service providers or seeking a ground service
provider at a new destination. ISAGO also promotes the use of the IATA Ground Operations Manual
(IGOM) and other IATA reference documentation in the development of operational procedures by
ground service providers to achieve conformity with the ISAGO standards. ISAGO is the only program
that requires a ground service provider to have a safety management system equal to that required of
an airline, and demonstrably assists the development of a better safety culture.
Airlines that enter an ISAGO Airline Membership Agreement receive unlimited access to the ISAGO
Registry that hosts over 500 ISAGO Audit Reports and other valuable information on ground service
providers at over 250 airports worldwide. ISAGO Audit Reports cover corporate safety audits of all
ISAGO Registered ground service providers and the audit of at least one of their station operations.
During the COVID-19 crisis, ground service providers that are not able to conduct ISAGO Registration
renewal audits or unable to close an audit are required to submit to IATA an extenuating circumstances
questionnaire that provides information on maintaining safety. The submitted questionnaires are also
only available from the ISAGO Registry.
Here is the link to the ISAGO website for more details. If you are interested in gaining access to the
ISAGO Registry, ISAGO Audit Reports and questionnaires, please contact the ISAGO team at
isago@iata.org.
10 – IOSA Guidance for Safety Monitoring under COVID-19 Edition 5 – May 2021
covered via desktop audits. If required, airlines may consider to be part of the pools to reduce the
workload and costs. Here is the link to the IDQP website for more details.
Among others, the airline may also use the following methods for monitoring external service
providers:
• Use of self-assessment checklists, questionnaires, and postal audits;
• Systematic review & risk assessment of reported hazards and/or occurrences;
• Assessment of performance reports;
• Ongoing assessment of the reporting and feedback from the station manager/personnel, flight
crew and any other operational personnel;
• If conditions allow, perform onsite or remote audits and inspections; and
• Any other acceptable monitoring method.
11 – IOSA Guidance for Safety Monitoring under COVID-19 Edition 5 – May 2021
4. Codeshare & Wet-Lease Partner Safety Monitoring
4.1 Introduction
In many jurisdictions, airlines are required to monitor and continuously assess their codeshare/wet-
lease partner’s (‘partner airline’ or ‘partner’) ongoing compliance with ICAO standards. To comply with
this requirement, airlines have been utilizing the IATA Operational Safety Audit (IOSA).
In addition to the above assurance of partner airlines through IOSA, airlines also continuously monitor
their partners during the two-year IOSA registration cycle. This may include audits and inspections,
reviewing the partner airline’s internal monitoring activities, exchanging checklists/questionnaires as
well as monitoring operational and safety information as outlined in the following chapter.
In this guidance, IATA outlines best practices and recommendations on monitoring codeshare and wet
lease partners.
Monitoring activities are dependent on the steady flow of up-to-date operational and safety
information. It includes, for instance, operational information on codeshare/wet-lease flights,
organizational changes or fleet changes of the partner airline.
The following table outlines examples of the operational and safety information that could be
exchanged between partners or that could be acquired through other sources.
AOC information (area and type of operations, special authorizations and etc.)
12 – IOSA Guidance for Safety Monitoring under COVID-19 Edition 5 – May 2021
Information type Remark
Other Information on high-level financial status and stability of the partner airline
Table 1.1 – Operational and safety information exchange (Cont’d)
Operational and safety information can be obtained through the IOSA Program, partner airlines
audits/inspections, checklists & questionnaires and last but not least documentation sharing and
communication channels established between partner airlines.
4.3.1 Introduction
“The risk-based oversight is a way of performing oversight, where planning is driven by the
combination of risk profile and safety performance; and execution focuses on the management of
risks, besides ensuring compliance.”1 We recommend airlines to apply performance/risk-based
approach for monitoring their partner airlines.
The following goals could be achieved with performance/risk-based monitoring of codeshare/wet-
lease partners:
• Identifying risk profile of a partner airline to determine and understand the scale, depth and
complexity of the monitoring activity.
• Identifying and managing focus areas of a partner airline.
• Efficient and effective utilization of the limited audit resources on higher risk areas.
• Increasing the effectiveness of the monitoring activities with a deeper assessment of higher
risk areas.
1
"Practices for risk-based oversight"; Edition 1, published by EASA 22 November 2016
13 – IOSA Guidance for Safety Monitoring under COVID-19 Edition 5 – May 2021
4.3.2 Review of operational and safety information
General
Airlines should review collected operational and safety related information to identify hazards and
perform risk assessment and mitigation processes in accordance with their SMS. This may also
include setting performance measures related with partner airline operations. The analysis of
information listed in Table 1.1 is useful to identify such hazards and associated risks.
Certain information such as type of operations, organizational changes or financial status of the
partner airline may be collected as an input for establishing a risk profile. On the other hand, others
may require further investigation and or information. For example, if an airline informs its partner on a
significant incident, the partner airline may ask for mitigating actions or corrective actions performed
related with the incident.
14 – IOSA Guidance for Safety Monitoring under COVID-19 Edition 5 – May 2021
Note: The questionnaire does not represent a third-party assessment and therefore, does not replace
an IOSA Audit Report.
A partner airline risk profile can be represented with a risk rating generated from various risk elements
specific to codeshare/wet-lease operations. Risk elements of a partner airline are inherent to the
nature, size and complexity of the operations and should be based on collected information as
mentioned above.
Monitoring activities should be determined in accordance with the risk profile of the partner airline. For
instance, a partner airline with a high aggregated risk rating should be monitored more meticulously to
include risk-based audits/inspections or any other monitoring activities.
Airlines should focus on the high-risk areas of their partner airlines and request for mitigating actions
as mentioned above.
15 – IOSA Guidance for Safety Monitoring under COVID-19 Edition 5 – May 2021
5. Safety Assurance during COVID-19
5.1 General
Identifying hazards, managing and monitoring associated safety risks are critical for the successful
management of the crisis and the restart of operations.
In accordance with IOSA Standard ORG 3.4.1, the airline’s safety monitoring activities shall include the
assessment of the management system to ensure the organization is identifying hazards to operations
and assessing the effectiveness of safety risk controls.
This chapter provides guidance on how to manage safety risks and monitor the process within the
scope of safety assurance activity during COVID-19 crisis.
16 – IOSA Guidance for Safety Monitoring under COVID-19 Edition 5 – May 2021
• Humanitarian flights for evacuation and repatriation;
• CCRD or Targeted Exemptions granted to operational personnel (e.g. validity of medical
certificates), personnel medical certifications expiration, when applicable and required;
• Documentation and database updates may not have been applied;
• Outdated or inconsistent information in aeronautical information and flight plans.
Please see IATA Guidance for flight operations during and post pandemic.
Please see IATA Guidance for cabin operations during & post-pandemic.
Please see Guidance for the transport of cargo and mail on aircraft configured for the carriage of
passengers.
17 – IOSA Guidance for Safety Monitoring under COVID-19 Edition 5 – May 2021
Please see IATA Guidance for Managing Pilot Training & Licensing during COVID.
Most common hazards, risks and mitigation actions are also provided in IATA guidance documents
published. Here is the link to the IATA Safety website for the relevant guidance documents.
https://www.iata.org/en/programs/safety/
18 – IOSA Guidance for Safety Monitoring under COVID-19 Edition 5 – May 2021