Our urgent SMS to the CAA: In this case, Safety manages a poor second

30 July 2013 / by Des Lines / Consultation, Costs, Governance, Maintenance, Overview, Safety
A "specially designed" SMS logo, made just for you by the CAA

A “specially designed” SMS logo, made just for you by the CAA

The CAA is rolling out SMS seminars around the country. No, this is not about the Short Message Service so beloved of cellphone texters.

In this instance, SMS means Safety Management Systems.

They have fallen out of an ICAO effort which resulted in a new Annex with the number 19. In the May/June Vector magazine on page 8, there are four options on which the CAA wants to hear your views. They are:

♦ Continuation of the status quo

♦ Increased inspections, audits and enforcement

♦ Voluntary implementation of risk management systems

♦ Mandatory implementation of risk management systems.

Perhaps not too surprisingly, the CAA favours the mandatory implementation of a risk management regime, such as a Safety Management System (SMS).

This, in its view, would have the greatest effect on increasing safety, with “associated business benefits”.

However, some strong other views are emerging. They oppose the CAA’s preference for mandatory implementation.

Here’s one from Pat Scotter, BA FRAeS, retired Boeing 747 Captain and Flight Instructor, well-qualified LAME, Authorised Inspector and Aviation engineering examiner. He’s sent it as an open letter to The Director.

Safety doesn’t come first in aviation!

Before you arrange to have my “Fit and Proper Person” status revoked, let me explain.

Safety can’t come first in any activity. If it did, we wouldn’t do anything.

The need for sound economic performance and the need to remain competitive must come first. This is particularly so in international dealings.

In aviation, we have layer upon layer of procedures and requirements which purportedly reduce risk and hence improve flight safety.

♦ We have CAA Rules

♦ We have Expositions and Procedures Manuals

♦ We have Quality Assurance Systems

♦ We have internal and external auditing of activities

♦ We have OSH Regulations

♦ We have Mandatory Incident reporting

♦ We have the “Fit and Proper Person” nonsense

♦ We have Dangerous Goods Regulations

and so on.

Every few years, some new safety paradigm surfaces. The flavour of the month is SMS (Safety Management Systems).

The test of any new safety system is simple. Accidents and incidents from the past must be re-examined and these questions asked:

♦ How many of these incidents and accidents would not have occurred had the new system been in place?

and

♦ Will the new system make any real difference in future, and at what cost?

I believe it imperative that these tests be applied to any new proposal intended to enhance flight safety.

I tire of the absurd “If you think safety is expensive, try having an accident” rhetoric. This comes from the “Safety comes first” brigade. These people have difficulty accepting that accidents and incidents will not be eliminated, no matter how much is spent on safety programmes.

We are in the age of immaculate paperwork, where managers are afraid of challenging anything which is claimed to improve flight safety.

Risk identification and risk management skills are the basis for flight safety.

Serious flying accidents are almost always a result of some sort of inappropriate pilot behaviour, some of which doesn’t respond to education. In my view, we need to work harder in addressing this area, not in introducing yet another layer of paperwork.

We must remember that life is a hell of a risk, and we are lucky if we get out of it alive!

Pat Scotter

The first problem: data security and protection

Any SMS or risk-based system has at its heart data and data collection – or reporting. ICAO Annex 19 champions this and the CAA advocates this too.

More data for safety will find little unreasonable opposition; however, the CAA uses safety data for enforcement. This element is not only recognised by ICAO in Annex 19; ICAO has set the balance. But under New Zealand law, there is no balance. Data is discoverable through process such as the OIA (Official Information Act). The security of data is another matter and the recent performance of government departments has been scandalous.

More data for safety analysis is, in the ICAO view, a good move; but the CAA stating “trust us with your data” is, under present circumstances, unacceptable. For example, call to mind the publishing of personal details on the CAA Aircraft Register despite complaints from the Privacy Commissioner and others that the practice breaches the Privacy Act.

We need an iron-clad system of data protection before we need the implementation of the rest of Annex 19 and SMS and risk management.

There are anomalies in the way the CAA currently captures safety data. One is in the use of the CAA Form 605b Operations Statistics. The data collected in this form applies only to certified and special category aircraft. The data for microlight aircraft is not captured. This makes a nonsense of any conclusions the Authority seeks to draw from the data.

The microlight fleet, operating under Part 149, now comprises a very significant percentage of light aircraft flying within New Zealand. They are currently flying an estimated 75,000 to 80,000 hours per year.

Although the CAA’s stated intent is to not require non-commercial organisations to establish an SMS, the CAA has said it “would still adopt a risk management approach to safety regulation for them”. What this risk management approach will be has not been disclosed.

The CAA Act is up for review next year as well, but now is the time for an industry voice to say “keep it voluntary” – and “let’s first witness that the data protection system is secure” before taking the proposed implementation of SMS any further.

One sure step at a time, please.