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Case Study

Virgin Airlines Australia – self-insurance licence preparation

Completed 2018


Virgin Airlines Australia had joined the Comcare scheme, the national work health and safety and workers’ compensation scheme. One of the requirements of the scheme was to pass a Comcare Audit against the National Self Insurer OHS Audit Tool (NAT Cth).

The Challenge

Balancing the requirements of the more standard NAT Cth safety audit tool with the extra layer of safety requirements applying to aviation – and those of the Civil Aviation Safety Authority (CASA) in particular – was a challenge Virgin opted to engage Verus to guide them through.

Multiple overlaps between the Virgin Work Health and Safety Management System (WHSMS) and the airline Safety Management System (SMS) added to the challenge, and had the potential to cause a misunderstanding of responsibilities. A clear understanding of the overlaps in the systems needed to be identified.

Also compounding the challenge was the fact that the scope of the licence Virgin was seeking included various entities associated with their airline operations (for example, the ground crew as a separate business entity). Virgin therefore needed to understand the extent to which their newly designed WHSMS had been implemented across the entities, as well as what processes were working or not working.

Project Goals

  • Understand the various safety management system requirements for both health and safety and airline safety, then align these to the national audit tool.
  • Complete a pre-licence audit to:
    • identify any gaps in the systems’ information against NAT Cth requirements.
    • identify any areas where implementation was lacking and establish why this had occurred.
  • Complete the audit for the various entities in locations across Australia, including Western Australia, New South Wales, Queensland and Victoria, within a set timeframe.
  • Provide insights to Virgin on how to meet self-insurance requirements given the additional layers of safety complexity.

The Insight

We were able to apply our depth of experience with planning and delivering major audit programs as well as self-insurance requirements to provide the jargon-free guidance that Virgin needed as they were embarking on their journey.

Our experienced auditors used their shared understanding of NAT Cth for consistency in findings and reporting coupled with strong experience in multi-business self-insurance programs and industries with heavy regulatory compliance, to provide a range of detailed, tailored insights for Virgin.

The Solution

  • Delivered a multi-state audit project that addressed all businesses within the scope of the proposed self-insurance licence.
  • Developed a strict project management framework for the audit to ensure work was completed with sufficient time for Virgin to make improvements before their Comcare audit.
  • Used simple language and clearly identified non-conforming criteria.
  • Identified the overlap of the airline SMS and the WHS system to allow Virgin to assess and nominate a single process moving forward.
  • In-depth consultation with the Virgin Safety Team to identify which action would provide the greatest impact in the time available.
  • Coordinated a number of project managers concurrently.