Standards

Normal Procedures

Eddie sez:

We used to say in some of my Air Force squadrons that the commander sets the objectives, the trainering department trains the operators to achieve the objective, the standards department ensures the trainers are doing a good job by evaluating the operators, and the safety office looks at everything with a big picture perspective to make sure it all works safely. That is oversimplified, of course. But it does illustrate the interconnectedness of everything.

In a large organization you should have an established department that does nothing but ensure the company's standards are being maintained. This encompasses everything from creating the standards (with consultation with management) to checking adherence to the standards at every level.

In a smaller organization the standards department fulfills the same role, but relationships become complicated. The standards department could be one person. That one person will normally have other roles which blur the lines between standards checking and execution. The standards department — even if that is one person — can be better prepared to fill this role by having a complete understanding about why the standards department exists and how it should be doing its job.

Everything here is from the references shown below, with a few comments in an alternate color.

A big picture look at standards through a generic organization chart

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Photo: A notional organization chart showing safety, standards, and quality assurance
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This is one of those exercises we would do at various schools (safety, standards, QC, etc.) which I often thought was a waste of time but later came to realize served to help us realize where we (whomever we were) fit into the big picture. So, especially as civilians where the "chain of command" has less of a rigid meaning, knowing where everyone else fits into the big picture will help us in the standards world know where we fit in.

  • Management.

    It may seem that management sits on top and answers to nobody, but that isn't true. In the words of Bob Dylan, everybody has to serve somebody. But not only does management have a hierarchy above them, management has a two-way relationship with safety and standards. Management sets the objectives and has the most to say about what it is the operators will be doing, but all of that gets tempered by safety and standards.
  • Operators.

    In this context, by operators we mean everyone that does the job. In a flight department, that means crewmembers, mechanics, dispatchers, everyone including the people who cut the grass. In a small flight department, other people on the organization chart are also operators, complicating everything. The chain of command from management is, for the most part, one way. While there is a feedback loop, in the end management gives the orders and the operators carry those orders out.
  • Training.

    The training department takes the direction provided by management and trains the operators to fulfill the organization's objectives. In a smaller organization much of the training role is contracted out and the trainers may appear autonomous. But that isn't true, management can shape the training agreement or simply terminate it and hire a new training department. Even the smallest flight departments should have a person or persons responsible for the local training that the contracted training department cannot handle.
  • Quality Control.

    The QC department might be taken by the standards department in a small organization, but the role is different from standards. The quality control folks are given a set of standards to check and report shortcomings to the people who need to know. This might be the operators but it could as easily be the training or standards department.
  • Safety.

    The safety department has a unique role in that they have two-way communications with management and no formal tie to any other part of the organization. That gives safety officers the ability to observe all facets of the operation and to report directly to management. This also means the safety department has some autonomy and does not receive its marching orders from management. We used to say the boss cannot overrule safety, but that isn't strictly true. The boss can ultimately replace the safety officer so some diplomacy is needed.
  • Standards.

    The standards department is like the safety department in that they have two-way communications with management. Management sets the objectives and has ultimate say on what the standards are, but it is up to the standards department to craft those standards. But unlike the safety department, those in the standards department also have a relationship with everyone else. They not only write the standards, but they check standards adherence and provide a feedback mechanism to let management know when the standards are not serving their intended purpose.

    1. Analyze objectives
    2. Define Everything
    3. Create Standard Operating Procedures (SOPs)
    4. Eliminate Ambiguity
    5. Check Execution
    6. Assure Adherence and Consistency
    7. Learn From Process to Trap Future Errors, Adjust SOPs
    8. Eliminate Procedural Drift
    9. Eliminate the Normalization of Deviance

Last revision:

20170915

1. Analyze Objectives

It is crucial that everyone involved understand that the standards department is acting on behalf of the organization to ensure the organization's objectives are met in accordance with the criteria set within the organization and by those outside the organization.

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Photo: The road to standards, from Eddie's collection
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External constraints on organizational and individual objectives

The organization's objectives

It may seem rather obvious for an organization to state its objectives as the safe transportation of passengers from Point A to Point B but things are rarely so straight forward. In one extreme you have combat military units where the objectives may be to "kill people and break things." At the opposite end of the spectrum you would have an airline where canceling a trip is preferable to flying in moderate turbulence. Whatever the organization's objectives are, the standardization department must be fully supportive.

The objectives of a standardization program

The standardization department's primary objective is to make sure the organization's objectives are met while satisfying any internal and external criteria, such as governmental regulatory restrictions. When satisfying external criteria comes into conflict with internal criteria, it it up to the standardization department to resolve the differences.

Example: When the organization loses sight of safety

There are times when the organization's desire to satisfy customers or demonstrate capability that safety becomes compromised. It is often up to the safety and standardization departments to refocus the organization's leadership.

When I was a standards pilot for a large corporate aviation management company we had a year long project to design an approach into Eagle Airport, Colorado, a mountainous area airport that would lower our minimums and reduce the number of times our business jets had to divert. A highly experienced team of standards pilots worked with the FAA and the primary customers requesting the approach to design and obtain approval for the procedure. Once it was approved by the FAA, the organization directed the standards group to write up the appropriate language to have the procedure adopted into our flight operations manual. This task was handed to me.

The procedure required GPS coordinates be manually entered into aircraft FMS to describe a circuit around and between several mountains and an aggressive turn to final without visual contact with the runway. This was contrary to the guidance in several advisory circulars that prohibited this kind of "build your own approach" methodology. But the advisory circulars allowed for alternate means of compliance and the procedure was approved by our principal operations inspector. I was familiar with the airport and thought the procedure was too risky. The company agreed to convene a meeting at a FlightSafety International facility where our chief pilot, safety officer, and our POI would test fly the procedure. None of them could land the airplane on the first try. The chief pilot said it was the scariest approach he had ever attempted. Though the company had spent a lot of time and money on the special procedure, the program was canceled.

Example: When the objectives require an adjustment to standards

Standard Operating Procedures are usually written with the best of intentions but cannot anticipate every situation. Some form of flexibility is needed, but this flexibility should be written into the standards to avoid abuse.

My first civilian flight department used the industry standard 14-hour duty day limit for a basic flight crew but allowed the pilot in command to waive the limits if he or she thought it safe to do so. This self-approved waiver was rarely used until a change in company leadership required an extraordinarily long trip between Houston, Texas, and Munich, Germany. On our Challenger 604s this meant a fuel stop going east and two going west. The first crew assigned the trip figured it could be done in 14 hours but failed to consider the return leg, which took 16 hours. But the trip was successful and became standard. When I was hired I was told that since every crew thus far had accepted it, we could not tell the customer no. I flew the trip once and upon return refused to ever fly it again. Of course leadership was furious and their fury was directed to me. But once the other pilots heard that I had refused, five others got in line and also refused. Leadership had no choice but to stage crews from that point on.

I've seen this kind of "mission creep" many times before and since. Years later, when we were setting up a new management company, waiver authority was granted only to standards pilots to ensure no individual pilots were making unwise decisions. But this proved unworkable as some standards pilots were more liberal with the authority than others. In effect, we needed to standardize our standards pilots. We classified our deviation requests into major and minor categories and instituted a program where waivers could be given to only one major deviation and to two minor deviations if there wasn't also a major deviation. This worked for a while until we found some standards pilots unwilling to grant major deviations to inexperienced crews. So we added another tier to the decision making process.

2. Define Everything

The need to specify what something means may first appear to be an exercise in creating paperwork. But when you consider an operation of dissimilar aircraft types the need becomes apparent. Crosswind limits, or example, are not always the same. But the need to define everything goes further still. Not everyone has the same background and may have learned the basics under different circumstances. What something means can also change with time, as governments attempt to harmonize with each other and as aviation itself matures.

Example: Aircraft differences

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Photo: Runway grooving, NASA photo
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When is a runway wet? Is it reflective? How deep is the water? Is the runway grooved? Regulatory agencies tend to give manufacturers latitude in these questions and the result is that pilots from different aircraft types may have different answers for the same conditions. More about this: Contaminated Runways.

Example: Regulatory differences

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Photo: VNAV DA(H) in lieu of MDA(H) ball note, from Eddie's notes.
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Even flying the same aircraft, your procedures could differ if you are flying Part 91, Part 121, or Part 135. One operator may not be able to dispatch under some conditions where the other has no restrictions at all. Having the right Letter of Authorization can mean one operator reads an approach plate with different eyes than one who doesn't. More about this: VNAV.

Example: National differences

Can you takeoff from Point A if the weather is below minimums at Point B? In the U.S. the answer depends on if you are operating commercially or not. But even a Part 91 operator will have a different answer in some countries. More about this: Approach Ban.

Example: Differences in pilot backgrounds

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Photo: G450 deice/anti-ice, from Steven Foltz.
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When do you need to deice a wing? What about anti-ice? While the answers may be intuitively obvious for a pilot who grew up flying in the muck the same cannot be said for your new hire who has never left the southwestern United States. If your standards don't specify the obvious, you can end up with pilots who don't appreciate the gravity of their decisions. See Air Florida 90 for an example of two such pilots. More about this: Cold Weather Operations.

3. Create Standard Operating Procedures (SOPs)

The surest way to get everyone to ignore your SOPs is to write them so they cannot be understood in one reading. The best way ensure success is to make sure your SOPs are understandable, memorable, accessible, and enforceable.

The SOP needs to be understandable so as to avoid having the best intentioned operator employ the wrong procedures.

Optimally, the SOP should be easy to remember. But if it is a complicated SOP, written guidance needs to be available where it is needed.

Finally, the SOP needs to be enforceable. It should be a simple matter of checking the process or the output to determine if the SOP was followed or not. Otherwise short cuts will be attempted.

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Photo: Calvin's checklist, from Bill Waterson
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Definition

A Standard Operating Procedure (SOP) is usually defined as a set of step-by-step instructions used by an organization to help its employees to carry out a complex, routine operations. By outlining the SOPs, organizations hope to promote efficiency, quality control, and uniformity of performance. An SOP also reduces miscommunications and the failure to comply with operating standards, industry regulations, and governmental rules.

SOPs can go by other names. A military "Standing Operating Procedure" is an SOP for a particular unit. Some industries have there own names, such as "good clinical practice" or "best practices."

Writing an SOP, step-by-step

I don't think I can offer a definitive guide that will cover a majority of situations, but here are a few steps that should get you headed in the right direction.

  1. Identify the process
  2. that needs standardization, list the things that can go wrong if things are not done correctly as well as the things that can be optimized if they are.

  3. Identify any external constraints
  4. (regulations, rules, or other constraints) that must be followed to keep out of trouble, or should be followed to remove all doubt.

  5. Reach out to current users
  6. of the process and catalog the various procedures in use as well as any feedback about ways to improve. Also ask about which rules and regulations are an impediment to efficiency or safety.

  7. Research industry best practices
  8. to find out if someone else has already devised an SOP that will meet your needs, possibly with a little modification.

  9. Consider the purpose
  10. of the SOP, starting with the reason the SOP is necessary in the first place. Purposes include:

    • To ensure compliance standards are met
    • To maximize production requirements
    • To ensure the procedure has no adverse impact on environment
    • To ensure safety
    • To ensure everything goes according to schedule
    • To prevent failures in manufacturing
    • To be used as training document

  11. Consider the best mode of publication
  12. for your SOP. It could be added to existing manuals, become a manual in themselves, appear as checklists, etc.

  13. Write the SOP
  14. and make sure it covers:

    • Scope and applicability. Who does the SOP apply to and when?
    • Methodology and procedures. How is the SOP implemented? You might consider drawings, photos, and flow charts.
    • Clarification of terminology. Identify acronyms, abbreviations, and all phrases that aren't in common parlance.
    • Health and safety warnings.
    • Equipment and supplies. Complete list of what is needed and when, where to find equipment, standards of equipment, etc.
    • Cautions and interferences. Cover what could go wrong, what to look out for, and what may interfere with the final, ideal product.

  15. Test run your writing
  16. with someone not yet exposed to the new SOP. Ask them to articulate what the SOP means in their own words. If they are unable to do so without your coaching, the SOP should be rewritten with an emphasis on simpler, more conversational writing.

  17. Test run the SOPs
  18. with experienced and highly regarded users, taking care to emphasize that the SOP is in a test period and that their feedback will be used to improve the processes before formally adopted.

  19. Educate SOP users
  20. with instructional videos, handouts, one-on-one training.

A few pointers when writing your SOP

  • Use job titles and/or functions, not peopleĀ¶s name.
  • Use plain English and try to express ideas with fewer words.
  • If a procedure has a number of different steps, use bullets to make that clear.
  • Include all the necessary information to perform the procedure.
  • Include just the facts only.
  • Follow a logical thought process and number all steps to complete the procedure.
  • Have a specific reader in mind. Know the type of person who will be reading the procedure and tailor the writing accordingly.
  • Make a rough flowchart, which provides you with a representation of the whole process before you break it up into procedures or steps of a process.
  • Start each step of the procedure with an action word, e.g. "lift," "take", etc.
  • Use graphics and visuals. These can often be more effective than text.

4. Eliminate Ambiguity

Few endeavors are so heavily laden with jargon as aviation, but fewer still simply assume every bit of that jargon is common knowledge. That is a problem in the world of standardization. But by the time you become a standards pilot, you are probably knee-deep in the jargon and may not even realize it. Standards must be written so as to eliminate any possible confusion.

Taming the "I ASSume" problem

There is a fine line to draw between explaining and defining too much versus not enough. If you go too far, you end up with so much paperwork that your users will be unable to find what they need. If you don't go far enough, your users may make assumptions of their own. Here is what I suggest:

  1. Identify "higher command" directives.
  2. In the Air Force we would start with regulations from the highest levels and work our way down. If the Pentagon said something, we used that as gospel and assumed every level understood that. For example, we didn't have to explain duty day limits, since that was defined at the Air Force level. Working our way down, lower level of commands would fine tune those directives.

    As civilians, we have something similar. We can start with ICAO rules as our top level, understanding that individual countries can make changes. What the ICAO and FAA mandate, we adopt. The difference, however, is that some of these rules are so obscure and complicated that it may be to our advantage to cite the ones the apply explicitly.

  3. Identify aircraft and company specific directives.
  4. Your Airplane Flight Manual will have limitations and procedures that must be followed without exception. Your crews should know these and you shouldn't have to have rules that repeat these. But in some cases you as operators do have some latitude. It may be in your interest to specify exactly how you want it done, removing that flexibility.

  5. Provide a mechanism for resolving ambiguity and other conflicts.
  6. You cannot expect to have answered every possible question with your SOPs and should provide a feedback mechanism for your operators to resolve conflicts efficiently. In some cases, a well thought-out SOP may not work out for every conceivable situation. In these cases there should be a mechanism for permanently or temporarily changing an SOP.

Example: How do you fly a circling approach?

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Photo:
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Let's say you have a destination where the only option for an arrival is a circling approach. Your SOPs should provide your crews with the ability to quickly and efficiently determine if the approach can be flown and if so, how.

  1. The ICAO rules provide weather minimums, procedures, and restrictions for circling approaches, but let's say the approach in question is the LOC DME-E to Pitkin County/Sardy, Aspen, Colorado (KASE). The approach is written under TERPS so you know U.S. procedures will take precedence.
  2. U.S. rules specify the procedures for up to a Category C aircraft down to an MDA of 10,220 feet; a 2,383 foot height above touchdown, a 3 statute mile visiblity minimum. The procedure appears to allow circling to either runway, but not at night.
  3. Your aircraft manufacturer may further constrain you. A Gulfstream GIV or G450, for example, can be classified as Category C or D through an Aircraft Service Change (ASC). With the proper maintenance action, the aircraft may be qualified to fly this approach, provided its actual speed doesn't "bump" it into the next category.

None of these points needs to be specified, since they are already in writing and available to your crews. It may be in your best interest to specify them anyway, making reference to where the actual restrictions are from. But just because the rules say it can be done, doesn't mean you want to give your crews this much latitude. In my flight department, for example, we have company rules that further restrict us:

  1. Departures are authorized Day or Night, provided the minimums on the published departure procedures are met.
  2. Arrivals are authorized Day only.
  3. Circling to Runway 33 is not permitted.

In our case, we limited our Aspen SOP to just three lines, knowing that our crews are familiar with the other restrictions. With other flight departments it may be better to spell some of these external constraints explicitly.

Example: When is a short field landing really a short field landing?

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Photo: C-20A (Gulfstream GIII), Ramstein Air Base, Germany
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The lineage of the first Gulfstreams in the Air Force began with the C-20A. For those of you from this community, these were the first several GIIIs that were little more than GIIs with winglets. These three aircraft lived happily at Andrews under the 89th Military Airlift Wing until they were replaced by six C-20Bs, which were the latest version of the GIII. The C-20As moved to Ramstein Air Base in Germany. Why all of this matters is that some of the rules and procedures from Andrews went to Ramstein.

I first flew the Gulfstreams for the 89th at Andrews where one of our required check ride maneuvers was what we called a "short field landing." That simply meant we wanted to put the airplane down on the runway and meter our braking so as to be stopped within 5,000 feet. It was still a smooth touchdown with smooth braking, but it all had to be done in 5,000 feet.

There was no such requirement in the Germany squadron. I showed up their as the commander and immediately checked out as an aircraft commander, the pilot in command. I was flying to a Dutch military airfield with a young copilot who had lots of experience in the C-141 but was brand new to the Gulfstream. As we entered the traffic pattern another airplane blew some tires on the runway we were planning on using, closing it. Tower offered us the shorter runway, which was 5,000 feet long, our minimum length.

Even though I was the PIC I was in the right seat because we had planned this as the SIC's leg. I asked her if she was comfortable with shortfield landings. What I said was: "Are you okay with a short field landing." What I meant was: "Can you land us smoothly and safely on 5,000 feet of runway or would you rather hold for ten minutes for them to clear off the other runway. I don't mind holding." But what she heard was: "I want you to stop this airplane in as short a distance as possible."

She planted the airplane and fully depressed the brakes, causing the antiskid system to meter the brakes. Unfortunately the metering wasn't even and we headed rapidly to the left. "Off the brakes! Off the brakes!" She released the brakes and other than a bald spot on the tires, we were okay. So whose fault was all this? Mine. The squadron didn't have any term "short field landing" and she had simply interpreted my instructions logically. I assumed our methods at the 89th were understood elsewhere. I was lucky the ambiguous terminology did go further than a little embarrassement.

5. Check Execution

The standards department must be made up of personnel that have the right experience, expertise, and demeanor to carry out the tasks set out by the organization. These standards officers check the organization's execution through audits, written exams, observations, and check rides. The mechanics of these checks will be tailored to the organization. I've provided a general Standards Pilot's Manual as a starting point.

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Photo: Extraterrestrial checkride, Pixar

Click photo for video

An SOP mindset from top to bottom

It is important that the top of any flight organization openly "buys in" to the idea of standard operating procedures and the need for a dedicated flight standards program to establish and monitor those SOPs. In smaller organizations where the top of the flight department is also an operator, that person must not only appear to buy in, but must also "walk the talk." Hypocracy at any management level will be easily detected by those charged with operating on the line.

A team of standards gurus

Even in a flight department of one person, someone needs to be in charge of establishing SOPs, monitoring adherence to those SOPs, and providing a feedback loop to adjust SOPs as necessary. In a larger organization, the person or persons given this task must be selected from only those with the necessary experience and expertise.

Audits

Running a flight department these days can be a complicated business. Between having to meet ICAO, FAA, and company regulations, there are a host of various safety management system, environmental, and other requirements. There should be people assigned to each of these tasks who are subject material experts. It is up to the standards department to become secondary experts to make sure evertyhing is accomplished by the book.

Internal audits can be useful for providing a second set of eyes to what has become common operating practices. I often come in to watch our mechanics doing routine and non-routine maintenance. Our mechanic thought nothing of climbing on top of our airplane's tail to replace an antenna without so much as a safety net. (The tail is 25 feet above the concrete.) He had always been expected to do this solo and thought nothing of it. We convened a "Hazard Identification and Tracking" meeting. We decided that whenever we had anyone on the airplane structure (including the wings) we had to have two people present and we began the procurement process for a fall restraint system. (It is due to be installed later this year.) These kinds of audits often yield tangible results.

Written exams

It may be necessary to administer and grade written exams to prove compliance with various regulatory requirements. There is an art to writing exams and I will take a stab at it here: Standards Pilot's Manual.

Observations / check rides

Even if you are flying under 14 CFR 135, you probably don't get looked at when flying a "live" line mission, one with passengers. We often behave differently on these line trips than in a simulator or during a 299 line check. For the general philosophy behind such an observation, see Line Operation Observations. For the mechanics behind such observations, see: Standards Pilot's Manual.

Day-to-day on the line

Members of the standardization group will probably have day-to-day line responsibilities and will be exposed to line personnel doing their jobs when not officially being examined, as would be true during an audit or observation. It is up to everyone involved to make note of times SOPs were not followed or when SOPs failed to address a situation. The standards group should have a way of soliciting feedback so as to address these situations.

6. Assure Adherence and Consistency

The various Check Execution steps are designed to assure adherence and consistency with standard operating procedures. But these SOPs must be designed properly in the first place.

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Photo: The road to standards, from Eddie's collection
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7. Learn From Process to Trap Future Errors, Adjust SOPs

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8. Eliminate Procedural Drift

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9. Eliminate the Normalization of Deviance

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See Also:

Austro Control Flight Examiners Handbook, Austro Control, Document HB LSA PEL 002 IN, Version 1.0, 2010.