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Archives for June 2015

Zen and the Art of Safety Management: Head-on crash of ideologies at the CAA

SMS: Like Buddhism, it’s a way of life, not a box-ticking dogma

SMS: Like Buddhism, it’s a way of life, not a box-ticking dogma

Adopting the concept of SMS (or System for Safety Management, as the NZ CAA prefers to call it) is a long overdue move by the Authority (or any industry, for that matter). It should be commended. The aims and principles have many benefits, not only to aviation, but to society as a whole.

I fully embrace the concept, but cannot claim to be an expert. SMS reflects the way I have been brought up to think, in the military and civilian worlds. In the military environment, people can end up hurt – or dead – very quickly, in any number of new and inventive ways.

This is also possibly one of the reasons why I have found myself in conflict with the “let’s not fix it if it’s not broken” and “let’s wait until it happens before we make any changes” brigade. It usually involves me being accused of having an over-developed imagination – which, of course, is an assessment I can’t argue with.

Unfortunately, not all members of this brigade exist outside the group that regulates on behalf of those who partake in aviation. I have a recording of one such CAA ‘staffer’ telling me in no uncertain terms that I ‘can’t keep raising safety concerns’ and that ‘35 years ago things were busier, so we would just have to live with it’. This individual would no doubt be one of those tasked with making subjective assessments regarding operators’ SMS policies and procedures.

GAA has often reminded the CAA of the principles behind Just Culture. Unfortunately, I suspect the Authority has not yet learned how not to alienate its customers.

I’m sure the guys who spent years drafting this proposed rule have the right intentions and have honestly done the best they can. I applaud their efforts for what must have been a colossal undertaking. But then they went and shot themselves in the collective foot by announcing that all submissions had to be in by 19 June.

At the SMS seminar I attended, there was a fair level of cynicism among the audience. Although supporting the concept of SMS, their overriding theme seemed to be: “Who in the CAA is competent and capable of making assessments of what are essentially very subjective operator processes, in an objective manner?”

Chatting with attendees over lunch merely confirmed this feeling, with the overall opinion being: “This is the way it’s going to happen, get on with it” and “Oh! by the way, you have less than ten days to get any submissions into us” (seven days after the last seminar date).

I believe that the CAA has not fully appreciated that the concept of SMS is a hearts, minds and attitude process. It is much akin to Buddhism, which is a way of life (performance-based) as opposed to the ‘compliant’, tick-the-box check-list of most other religions’ scripture and dogma.

Yes, the CAA will be very happy to charge out audits at $285/hr whilst its people try to learn the ropes of this new and (to some of its staff) alien concept.

One of the documents I found at the seminar, written by a consultant, stated that even more consultants would be generated along the way and that the SMS process may be reduced to a check-list, procedure-based audit, for the convenience of the auditor, that would completely miss the whole concept of SMS thinking.

It was also heartening to note, in the documentation, an admission that not all regulatory authorities are ‘performing’ within a Generative environment – suggesting that some operate within the Bureaucratic or even Pathological model.

And that is one of the major sticking points. How can the CAA audit what is essentially something conceptual by using the same thinking paradigm that may be responsible for the problems in the first place? QA systems (QMS) will still be there, quantifiable and measurable. So too would be the records of identified risks and threats required by SMS. But how do you measure the way someone proactively thinks and potentially acts on that information? It is not impossible, but it is very unlikely to be measurable at an audit.

The CAA seems oblivious to the high number of aviators (professional as well as private) who are disengaged with anything that emanates from Asteron House.

Ford took its customers for granted with the unspeakably ugly Edsel - and then suffered the biggest marketing flop in history

Ford took its customers for granted with the unspeakably ugly Edsel – and then suffered the biggest marketing flop in history

It comes down to something like this: a company could have a brilliant product. However, if that company evidently lacks credibility, honesty and integrity, plus a fair and just after-sales service, then the product will remain on the shelf, unsold.

If the CAA was serious about making significant headway in ‘selling’ its products, it would have to address the above issues. Many companies send questionnaires to their customers, to discover what they think of their products, staff and service. Successful companies listen, and provide the goods and services the client wants – not what the company has to sell!

Any organisation that is so poorly regarded by those it represents or regulates (and the CAA must be aware of this) should be honest enough to face the truth. I wouldn’t mind chipping in (above what I already fork out) for the CAA to hire a good PR consultant and win the hearts and minds of the disaffected – provided the Authority was transparent (warts and all) and its staff were held to the high standards they expect from us. Then, and only then, would the CAA gain credibility.

I have great admiration and support for those hard-working, helpful, forward-thinking CAA people who radiate integrity. There are many of them within the Authority. I just hope that they don’t get demoralised and leave.

Accepting all that, it must be difficult for a politically appointed director of any organisation to make any real, effective change without first clearing out obsolete baggage that no longer fits the vision or is fit for purpose.

Could this signal the beginning of the end for PPL medicals?

One cure for painful fees: Scrap the PPL medical entirely

One cure for painful fees: Scrap the PPL medical entirely

The UK CAA is considering the removal of PPL medicals – and our CAA is keeping a close watch.

The UK authority has worked with a number of aviation medical experts to develop a consultation on medical requirements for some private pilots which aims to make them more realistic and reduce bureaucracy. (No changes are proposed for pilots with commercial licences.)

It proposes that the only medical requirement for UK private pilot licence and national private pilot licence holders will be to hold a current DVLA Group 1 Ordinary Driving Licence (ODL). Existing medical options (for example, a UK declaration with GP counter-signature) will remain available. The proposal will bring cost and time savings for pilots and, in most cases, remove the need for General Practitioner (GP) or Authorised Medical Examiner involvement.

New Zealand CAA Director Graeme Harris told the GAA: “I was aware of the UK work in this space, which we are watching carefully.

Graeme Harris: "...less convinced that we have it right for the PPL"

Graeme Harris: “…less convinced that we have it right for the PPL”

“For some time, I have been questioning what the appropriate medical certification standard is for the NZ/ICAO PPL (versus the NZ Recreational Pilot Licence and various pilot certificates administered by Part 149 Aviation Recreation Organisations). I am happy with the standard applied in the CPL/ATPL sphere because there is a reasonable element of international consistency applied (although it isn’t perfect) but am less convinced that we have it right for the PPL.

“Circumstances and societal risk tolerances change over time and in any case we should review all regulatory settings from time to time.

“We started looking at the issue formally a few months ago and currently have an ‘Issues Assessment Paper’ under development. Once completed, that paper will be considered and the outcome from that process will determine whether we proceed to a full policy project on the topic.

“While I don’t want to pre-judge the outcome of that process, I think it highly likely that we will indeed kick off a full policy project on the issue in the next financial year (starting 1 July 2015). Any such project would involve consultation with the aviation sector and broader society to get the benefit of their views and risk tolerance.”

Currently, UK pilots with an NPPL licence are required to comply with DVLA group 1 or 2 standards and have their self-declaration of fitness countersigned by their GP. Holders of a UK PPL currently need an EU class 2 medical or the NPPL medical requirements if they only use the privileges of an NPPL licence.

The proposal is based on a study of the risks associated with GA flying and comparing it to other recreational activities such as horse-riding or canoeing. The consultation also reviews the causes of light aircraft accidents and the likelihood of these being triggered by a pilot being medically incapacitated. The risk to third parties is considered and the regulatory approach taken by the Federal Aviation Administration in the USA, which mirrors the UK proposal, is also reviewed.

A variety of options are proposed and the CAA is seeking views through the consultation which closes next month. The information received will be used to determine how to take this proposal forward. You can see the consultation here.

Transfer of C of A aircraft to a permit to fly

The UK CAA has also issued guidance to formalise the existing process on how to transfer aircraft from a National Certificate of Airworthiness to a Permit to Fly. This guidance will benefit those owners who can make use of the reduced level of airworthiness assurance associated with the maintenance regimes and the potentially greater accessibility to spare parts for Permit to Fly aircraft.

GA Programme Manager Rachel Gardner said: “The new PPL syllabus, consultation on medical requirements and guidance for aircraft owners are the latest steps in our work to improve things for the GA community and make regulation of GA more proportionate and evidence-based.”

The FAA is also under pressure to relax medical standards for a PPL.

AOPA in the USA is hoping for some movement on the relaxation of third class aviation medical requirements “in the next few weeks,” according to a report recorded for AOPA Live. Jim Coon, AOPA’s senior vice president of government affairs, told the programme that medical reform remains AOPA’s top priority. “This is an issue we are working on every day,” said Coon. “We know how important it is to members and to the future of general aviation, so we will keep pursuing reform through every means available to us.” Coon said there now bills before the Senate and House to introduce the measure and it’s also possible it could be added to another bill or as part of the coming FAA reauthorisation for funding, which runs out on 30 September.

Under the proposal, no medical would be required for private pilots flying aircraft less than 6000 lbs in gross weight, VFR and IFR, with up to five passengers, at 250 knots or less. More than a year ago, the FAA drafted a proposed rule that would have been much more restrictive and the Department of Transportation has stalled that proposal. Earlier this year, AOPA decided to pursue the legislative route toward medical reform and although there has been some activity there has been no action. “We share our members’ frustration with how long it is taking to get this done, but we are not giving up,” Coon said. “In fact, we’re more determined than ever to get pilots the relief they need from this outdated and costly requirement, and we’ll do whatever it takes to make it happen.”