Mount Non-compliance & upcoming ICAO/FAA audit?

Mount Non-compliance & upcoming ICAO/FAA audit? - Printable Version

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RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Kharon - 10-24-2016

Catch of the match.

P2 at short leg, takes the catch of the match. Low, fast and disguised, at screaming speed. Few would even attempt it; of those many would have dropped it.

P2 - "Personally I can’t think of much documented evidence that would support that Australia’s claim, as a signatory State to ICAO, is anywhere near an acceptable standard of effectiveness in regards to the ALoSP four components.(E.g. Bullet point four - implementation of ICAO SARPs by the State. - I would say that 3000+ notified differences to the SARPs are a good indicator that our aviation safety bureaucracy is totally ineffective with this component.)

The BRB ‘heavy mob’ have just about completed their ‘reading’ of the last Estimates session; serious (no lampshades) indaba scheduled soon and it will be an interesting session. ICAO compliance has the top listing of a three item agenda. Early indications are that the other two items will be deferred – for another day. I can see why:-

The SSP is ‘live’ and ICAO will be paying some attention to how the various signatory States fulfil their obligations. Without doubt, the level of ‘work-shopped’ spin and word weasel magic contained in SSP will be at an all time high, from all nations. That is to be expected, the state agencies moving carefully to protect the States interests and limit liability. In the bureaucratic world, a little ducking and weaving around the peripheries is the expected ‘norm’. But what of the ‘spirit and intent’, the stuff men of good will rely on. There are two options for those people; either say to ICAO, look, we believe this is a load of old cobblers and cannot support it: or, take a hold of the thing, see the logic, applauded the ‘spirit’ and run with ‘the intent’.

The Australian approach is, in the opinion of many, ‘cynical’. Gods know there is enough evidence to support that claim. Seen as too gutless to say “No thank you” and not interested enough to embrace. Many claim, with sound reason, Australia is blatantly dishonest in it’s dealings with ICAO; simply paying lip service to the edicts and doing just enough to maintain the ranking and membership. CASA being a prime example; over 3000 carefully constructed differences; ATSB massaged ‘investigation’ and manipulated reporting statistics to obtain the 90 something % rating: ASA teetering on the brink of the abyss. All the silo’s connected, by subterranean tunnels to the back door of the DoIT. It’s a ‘mud-guard’ shiny on top, covered with shite underneath.

The unfolding ASA debacle presents a perfect opportunity to test the SSP. If Qantas or ‘Pie-in-the-Sky Airways’ were to shed 25% of their workforce; under ‘dodgy’ circumstances, what do you imagine would happen – Safety case examination? Absolutely. If the Tax office or the AG or DMR or AMSA were earning a Billion a year; from the public purse, from a gifted monopoly and went ‘broke’, sacking 25% of their workforce; what would the government of the day do? Moreover, what would the press do?

Well the AG has moved; the ANAO has moved and is going back for a less ‘restricted’ look-see; the Senate has moved and intending to move again; in short, there is a fair bit of interest in the ‘financial’ debacle ASA has generated. But what of the ‘Safety-case’?

The ASA monopoly is an essential supporting pillar of public safety. There exists an ICAO requirement for a SSP; there is a SSP live and legal on the books. Why has this not been ‘activated’? If it were to be activated, who is to run the ‘case’? DoIT? Don’t make me laugh. CASA? Oh please, stop before I become hysterical. ATSB? No more, I beg you, it’s starting to hurt. “What about the minister?” shouts the crowd. That’s it for me; the men in white jackets are arriving.

Hold the tranquiliser dart; I’ll sit here a while, at Mount Non Compliance base camp with GD and P2; have a brew and contemplate how best we may scale the ugly, dirty, dangerous, departmentally manufactured mountain. Aye, ‘tis indeed a monster.

Toot – toot.

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Gobbledock - 10-24-2016

Mountaineer Kharon said;

"Hold the tranquiliser dart; I’ll sit here a while, at Mount Non Compliance base camp with GD and P2; have a brew and contemplate how best we may scale the ugly, dirty, dangerous, departmentally manufactured mountain. Aye, ‘tis indeed a monster".

We will need some robust Sherpers for that task Mr Ferryman. Probably Mike Smith for starters. He can then bring some additional Sherpers along to assist him because the backpacks are extremely heavy as they presently contain;
- DCM's and payouts for Sir An(g)us, Dr Voodoo, Hoody, Pumpkin Head and an assortment of hangers on
- Hair products and a selfie stick for Dazzling Darren, the sexual Demi- god and male model of politics
- Buckets, spades, shovels and a Bobcat to remove the decades of elephant pooh dumped in the departments of aviation government oversight
- A couple of cases of that 'fuck off spray' is coming along for us to use against the endless spin doctors, shonks, liars and arse lickers who will be attacking us on our journey to the peak!

It is a long trip to the top of Mt non-compliance, having to cross; 'Skull gorge', 'pony pooh peak', 'obsfucation ridge','big R ravene' and even the 'half man half baked ice field' to get where we need to go. But at least we are headed in the opposite direction to 'Camp Flyingfiend' which is located on the southern flank of the mountain near 'Bollocks creek'. Our little overnight safe haven at 'Camp IOS' contains shelf loads (not shelf ware) of Guinness, cigars, warm blankets and a dart board. Should be a real hoot. Just hope Thorny and P7 dont mind looking after the houseboat while we are away?

And P2, this time bring your long-johns please, no spooning allowed on this trip, Hoody isn't coming along.

Hoot Hoot

Hoot -hoot indeed. Tim Tam for your play liunch and a big smile to go with it. Chuckle chuckele. "K".

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Kharon - 10-25-2016

Note to Quartermaster.

All good stuff to lug up the mountain GD, but, is it enough. Do we need to awaken the sleeping dragon of public interest? That particular dragon has little interest in ‘matters aeronautical’, it slumbers behind a curtain of the finest trance inducing material, spun from mystique and woven by the best dream makers into a soporific, sound deadening barrier. But money; ah well, money, now that is a different stimulus.

Value for money is thing every fool in the market place understands. Being ripped off is a common or garden experience. But this understanding is reserved for relatively small amounts, mere millions; filtered off by the cart load. But how many would understand the really big, clever larceny of three government departments? CASA has burned what, $300, 000,000 just on ‘regulatory reform’, not to mention the ‘other’ huge sums happily gifted in order to prevent ‘ministerial’ responsibility; or, the huge sums invested in ‘Inquiry’ and ‘review’, royal commissions and ‘investigations’. Those monies alone would settle the national debt.

Then there’s ASA; billions upon billions; down the Swanee and more scheduled to follow it – and for what? When they have chewed through a mere 1.6 billion for the ‘One Sky’ scam, will Qantas be able to avoid the horrendous cost associated with ‘holding’ and ‘speed reduction’ or even be able to run on time, every time. No Sir, they will not; same old, same old, but they now need to recover the cost of installing all the new equipment needed to ‘comply’. Shareholders just don’t seem to grasp that all of this must be paid for – which means a reduced dividend. Passengers don’t seem to get it, these ‘costs’ are built into their ticket price and included in their tax; double dipping.

The staggering cost of ‘aviation safety’ is one of the greatest rip-offs ever developed and nurtured. So to begin our journey to the foot of MNC, we are going to need to awaken the dragon of public opinion to clear the pathway through Sleepy Hollow. Or, find a way around it; which does not remove the problems and leaves us another item to carry; dynamite – to start an avalanche from the snow covered slopes of MNC.

We can sit here at base camp and wait for Smithy, he may have some good ideas. I hear ‘Wingnut’ is a useful man on a tough climb; when the mood moves him; perhaps it’s worth sending one of the carrier pigeons off with a polite note – asking for ideas, if not assistance. You never know the answer until you ask the question – and it may preserve the ‘Fuck-off’ spray for later.

Toot – duck – toot; that is one ugly mountain.

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Gobbledock - 10-25-2016

The mental rape of the fare paying public by the cricket umpires

Let the game continue. Day 3

Sadly the public, yes that is you dear taxpayers, suffer from cognitive dissonance. In laymen's terms it is the feeling of uncomfortable tension which comes from holding two conflicting thoughts in the mind at the same time.

For example; many of you know you are being ripped off blindly by the government and it's bogus taxes, fees and revenue milking scams that bleed your pockets endlessly, yet you somehow think it is necessary and appropriate. You believe and know that road safety is important and is a serious matter, yet you also know that a camouflaged speed camera or Inspector Plod hiding behind a gum tree at the bottom of a hill in a non-populated area does SFA for road safety! Enter cognitive dissonance.

No difference when it comes to the 'mystique of aviation'. Most people have some type of fear of flying. It takes the form of butterfly's in the tummy every time you drive to the airport, sometimes you get the squirts before boarding your flight, for some it is a mild sweat and the trembles, for others there is a need for Valium and a strong Scotch, some go to counselling, and others turn off the TV for a month prior to flying so that they don't stumble across an Air Crash Investigators episode showing an inverted nose-diving 737 about to impact the ground at a speed faster than a bullet from which not even your teeth will be found! So you blindly accept the CAsA safety rhetoric, squillions of your dollars spent on executive sojourns to Montreal and other desirable holiday destinations, you accept expensive airfares due to ASA's outrageous airline charges for 'safe airspace travel' managed by a blue suit/purple tie wearing pompous bell-end of an individual, because you suffer from cognitive dissonance (and probably a bit of Stockholm syndrome as well). You accept CAsA's plea for more money and swallow the bearded Gibson's crafted statements as to why ADSB is such a 'must', and why people like Dick Smith are just noise makers trying to undermine CAsA who are the 'font of all things safety'. In an act reminiscent of Linda Lovelace you swallow every word the handsome Minister expels regarding the safety of the fare paying public and how everything the government does is for the good of the human race, and without gagging may I add. Enter cognitive dissonance.

The government knows your fears. So they trot out some 'trusted folk' to ease that fear and play on your emotional side. A dapper looking Minister who appears to be in touch with your inner self. Captain of the team. A proud AVM Skidmore and Sir Anus Houston, proud military men who built incredible careers based upon leadership. Great co-Captains. Horsehit! Greasy government pole climbers who achieved nothing of merit other than wearing down their taste buds by licking Ministers and politicians arseholes and making them cleaner than a doctors sterile surgery. But the public needs these figure heads to remove any doubt about their fear about safety, their concerns about the unknown, their not understanding the 'mystique of aviation'. Enter cognitive dissonance.

Perhaps the 'mystique of aviation' should be exchanged of the 'psychology of aviation'? Either way it is a cash cow for the Government, abused and manipulated to fulfil their financial lusts and reap in the almighty dollar. We aren't talking conspiracy theories here, chemtrails or alien mind control. No, we are talking good old fashioned high level psychological smoke and mirrors which, as history has proven, easily captures the unwary sheeple who wander around in their Alice in Wonderland shoes clicking them every time the Matrix is exposed.

Not long to go now before Australians are accepting and fully embracing of the 'American way of life' - fast food existence, Presidential reality show, trillions of dollars in debt, and a house full of politicians with Botox and dyed hair treating their country like it is some kind of Hollywood fake production. I believe we are halfway there.

"Safe mind masturbation for all"

P2 - Gobbles sensational post, definitely one for the AP archives... Big Grin

The AP bonus (trough fund) cheque for 5 cents and a complimentary key (valid for a year) for the TimTam cupboard is in the mail... Wink

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Peetwo - 10-31-2016

To SSP or not to SSP - that is the question? Dodgy

(10-30-2016, 08:30 AM)Peetwo Wrote: Airservices scuttlebutt hot off the Press -

..Ferryman here's your argument in two lines, from ATCO (> 10yrs) & CA President Mr McRoberts, that the SSP should now be activated...

"We haven't seen any of the safety work that's being done to justify this being a safe course of action"

&..

"Airservices say they've done it all but we haven't seen any."

So what say you now Wingnut Comardy & Electric Blue Harfwit?? Show us your fully transparent safety case through the ASA SMS and the consequential audit/review by CASA, according to the requirements Chapter 2 section 2.2 of the SSP.

Mr Comardy in case your luxuriating beside a five star pool, here's a handy QR from the Mount NCN thread...

Quote:2.2 Safety management system obligations

Australia has introduced the requirement for the implementation of SMS in certain sectors of the aviation industry. CASA has introduced the requirement for the following civil aviation service providers to implement SMS:
...Air Operators—Civil Aviation Orders (CAO) 82.3 and CAO 82.5 require both high capacity and low capacity RPT operators to establish and maintain appropriate operations with a sound and effective management structure that uses an SMS approved by CASA....

...Air Traffic Service Providers—CASR Part 172 provides that an air traffic service provider must have, and put into effect, an SMS that includes the policies, procedures, and practices necessary to provide the air traffic services covered by its approval safely...

...Aerodrome Rescue and Fire Fighting Services (ARFFS)—CASR Subpart 139.H provides that the ARFFS provider must have an SMS consistent with the requirements in the Manual of Standards, including the policies, procedures and practices necessary to provide the service safely...

...Aeronautical telecommunication and radionavigation service providers – CASR Subpart 171.C requires service providers to have SMS processes in place to assess...

These requirements recognise the relevant ICAO SARPs outlined in ICAO Annex 19, Safety Management, and the safety benefits to be gained by the effective establishment by industry of an SMS. Where appropriate this requirement will be extended to additional sections of the industry.

CASA provides a range of support for the implementation of a SMS and continues to develop and review the guidance material to assist industry with their SMS.

More information on Australia's adoption of SMS can be found on CASA's website.

Links to more information about requirements for civil aviation service providers SMS implementation is at Appendix F.

&..

Service providers’ safety performance

An important element of a mature system of safety management oversight is agreement between the safety regulator and service providers on the key performance indicators and expected level of performance to be achieved. In the Australian safety regulatory system this level of performance is in part judged by how the service provider delivers against its SMS, therefore oversight of a SMS is included in CASA's audit programme for the operators who are mandated to have a SMS.

(P2 - It would/should be safe to assume that there would also be significant organisational developments within a service provider, such as 900 odd redundancies, which 'should' automatically red flag a need for CASA to facilitate a special audit process.)

From the Rev Forsyth report:

Quote:The Panel recommends that:

The Australian Government develops the State Safety Program into a strategic plan for Australia’s aviation safety system, under the leadership of the Aviation Policy Group, and uses it as the foundation for rationalising and improving coordination mechanisms.

The Department of Infrastructure and Regional Development plays a stronger policy role in the State Safety Program.

The reasoning behind R1 & R2 by Forsyth and his two esteemed international compadres is outlined in para 2.6.5 of the ASRR (pg 22-24):

Quote:2.6.5 Potential for a stronger and more visible policy role

It is the Panel’s view that the Department should perform a greater role in promoting and developing the aviation industry, and can provide greater policy leadership across the portfolio’s agencies. As discussed in Chapter 3, the Panel recommends the existing Aviation Policy Group (APG)23 be reinvigorated and given oversight of the SSP as the foundation for rationalising and improving interagency coordination. The Panel also recommends that the Department play a greater policy leadership role under this new arrangement.

A common theme in public submissions to the Review was the need for CASA to play a role in promoting the aviation industry, particularly GA. The Panel is of the view that it is not appropriate for CASA, as the independent safety regulator, to be responsible for promoting the industry or developing industry policy; this role is the responsibility of the Department.

In the Panel’s view, the Department has not always demonstrated sufficient policy leadership in aviation. A number of issues emerged during the Panel’s deliberations where policy outcomes fell short of their potential. While many factors contribute to policy decisions, as the responsible department of state and chair of the policy coordination mechanisms across the portfolio (as discussed in Chapter 3), the Department should bear responsibility for delivering sound and effective policy direction in pursuit of a safe, secure and sustainable aviation industry in Australia.

The Panel’s consultations identified a number of areas in which better policy outcomes could have been achieved:

Aviation security: While Australia has adopted a number of aviation security policies and regulations that differ from ICAO Standards, Australia meets or exceeds all of the requirements under Annex 17. For example, all persons seeking unescorted access to the airside area of a security controlled airport must have undergone background checking, while ICAO Standards only require background checking for access to Security Restricted Areas. The Panel noted that many aviation security policies and regulations appear to have been adopted without due regard to the burden they impose on the aviation industry, and that the same security outcomes could often be achieved with less impost. The specific issue of Aviation Security Identification Cards (ASICs), which have a disproportionate impact on private pilots, is discussed further in section 6.2. As the agency responsible for aviation security regulation, the Department needs to deliver a security framework that is more responsive to industry, and needs to engage industry more in the delivery of that framework.

Protection of airport flight paths and operations: While noting the significant work undertaken in the past four years through the National Airports Safeguarding Framework, the Panel considers that the protection of airport flight paths and operations from the encroachment of on- and off-airport developments is becoming an urgent policy issue. There is an emerging risk to the long-term viability of Australia’s existing aviation infrastructure. The issues are complex, crossing jurisdictions and levels of government, meaning that no single agency is able to deliver the required outcomes. However, as the agency responsible for on-airport planning issues at the 21 federally leased airports, and as the lead agency on aviation and airport issues, the Department must take a policy leadership role to ensure that the future viability of airport infrastructure is not compromised by poor planning and land-use decisions.

Aviation rescue and firefighting: In Australia, the requirement for aviation rescue and firefighting (ARFF) services is triggered when an airport receives 350,000 passenger movements in a year. While the service levels provided in Australia match ICAO requirements for certain airport categories,24 this threshold trigger is unique to Australia. The Panel understands there are a range of different perspectives among Australian Government agencies on whether the trigger should be changed, or if a range of graduated services should be adopted. Because the matter requires a clear policy judgement, the Panel would expect the Department to take the lead in providing policy guidance to the regulator and service provider.

Military air traffic control of civil aircraft: As recently noted by the ATSB,25 the number of ‘loss of separation’ incidents involving civil aircraft in military airspace in Australia is disproportionately high. Air Traffic Control (ATC) services provided by Defence are not regulated by CASA, and the ATSB recommended CASA’s oversight role in this area be reviewed. To effectively deal with the ATSB’s recommendations, the Department should take a leadership role, including negotiating with the Department of Defence. As a portfolio-wide policy issue, the Department must identify and implement an acceptable policy position to help ensure the safety of the travelling public in military airspace.

On top of keeping with the Department/State commitments of the slowly evolving ICAO Annex 19, supposedly the latest edition of the SSP incorporates addressing both recommendations 1 & 2 of the ASRR. However I would suggest that besides some clever shifting of words the latest SSP (May 2016 version) is largely unchanged in principle and methodology from Murky's original SSP.
These were the observations that the Forsyth panel made on the original M&M SSP version & the 2012 update (P2 - Note the part in bold and especially the bit underlined):

Quote:3.1.1 State Safety Program

In accordance with ICAO requirements, Australia published its first SSP in January 2011, approved by the then Minister for Infrastructure and Transport. The SSP was updated in April 2012. Australia’s SSP is updated as required to reflect any significant changes in policy or regulations. The SSP is a public document, available on the Department’s website.37

The SSP addresses key elements in Australia’s aviation safety system, including:

the legislative framework

safety oversight arrangements

SMS requirements for service providers

performance indicators for improvement in areas of safety concerns

accident and incident investigation management

promotion of aviation safety.

　
Australia’s SSP outlines how aviation safety in Australia is managed, with an emphasis on using safety systems. It also provides a framework for the continuous improvement of aviation safety by establishing how the various elements of Australia’s safety system are integrated. The SSP identifies and describes current arrangements and outlines the continuing steps required to respond to future safety challenges.

The Department chairs a State Safety Program Cross-Agency Team (SSP-CAT), made up of representatives of all agencies involved in Australia’s safety regulatory system. The SSP-CAT was responsible for developing the SSP document and is responsible for its ongoing maintenance, together with monitoring and reporting the implementation of the SSP and aviation safety-related indicators. From consultations with the Department, the Panel understands that the SSP-CAT does not meet frequently, but conducts most of its work out of session, and that it focuses on the maintenance of the SSP document itself. According to the Department, the SSP is subject to an annual review, and reviews may be initiated by the SSP-CAT on an ad-hoc basis. No formal reporting is undertaken by agencies tasked with responsibilities or specific safety actions under the SSP.

When Australia’s SSP was first produced, the current safety framework was already in place and the SSP was essentially written to describe the pre-existing structures. This approach may have limited the strategic direction of the SSP because it describes what is, rather than what should be in place. Publication of the SSP satisfied Australia’s initial obligations under ICAO’s Global Aviation Safety Plan (GASP). Full implementation of the SSP framework is required by 2022, and several aspects require further development, such as the articulation of an Acceptable Level of Safety under the SSP.

"..it describes what is, rather than what should be in place.."

I know that it is still early days but at this stage I would argue that the above statement by the Rev Forsyth is very much still the current status quo. This is clearly highlighted by two issues that were brought to our attention in the latest Estimates round:

1) the Airservices dodgy, non-transparent safety case for the redundancy of 900 non-essential staff at ASA and;
2) the ARFF rationalisation (bullet point 3 above):

Quote: ..In Australia, the requirement for aviation rescue and firefighting (ARFF) services is triggered when an airport receives 350,000 passenger movements in a year. While the service levels provided in Australia match ICAO requirements for certain airport categories,24 this threshold trigger is unique to Australia. The Panel understands there are a range of different perspectives among Australian Government agencies on whether the trigger should be changed, or if a range of graduated services should be adopted. Because the matter requires a clear policy judgement, the Panel would expect the Department to take the lead in providing policy guidance to the regulator and service provider...

The ARFF trigger point issue, for some strange reason, was enthusiastically engaged in by the department. Here is a link and blurb for the completed Departmental report that was referred to in Senate Estimates:

Quote:Aerodrome Rescue and Fire Fighting Services (ARFFS) Regulatory Policy Review

As announced in the Australian Government's response to the Aviation Safety Regulation Review, the Department of Infrastructure and Regional Development, (the Department), in consultation with Airservices Australia (Airservices) and the Civil Aviation Safety Authority (CASA) is examining a range of potential improvements to the efficiency and clarity of ARFFS requirements, including the use of risk assessments.

On 18 December 2015, the Department released a regulatory policy review consultation paper that considered future arrangements in relation to the provision of ARFFS at Australian airports. Public and industry comments on the paper have now closed.

ARFFS Regulatory policy paper: DOCX: 6975 KB PDF: 373 KB

Read this load of spin and weasel words from M&M's 'Executive Summary':

Quote:...The preferred approach to determining when ARFFS should be required to be provided at an airport involves the use of a trigger to require the Civil Aviation Safety Authority (CASA) to conduct a risk assessment for the particular location. The outcome of this assessment would then ultimately determine whether ARFFS is required to be provided at the location and the level of ARFFS categorisation. This would be consistent with CASA’s risk review role in other areas, such as airspace classification.

Such a risk review would consider a range of airport activity, air navigation and geographical considerations, examples of which are included in this report.
It is proposed that two measures be used as the trigger for the requirement for a risk review by CASA - the receipt of scheduled international air services and the number of passengers passing through the airport during a 12 month period.

Unlike the current arrangements, where the receipt of scheduled international air services acts as a hard trigger for the provision of ARFFS, undertaking a risk review would provide flexibility to potentially determine that at certain locations (for example those with low passenger numbers and very few international movements) an ARFFS is not required.

In relation to passenger numbers, it is proposed that the trigger be set at a threshold of reaching 500,000 passenger movements over a rolling 12 month period.

This proposed increase in the threshold from the current 350,000 passenger level reflects the fact that overall activity and passenger numbers have increased significantly since the existing passenger threshold was adopted...

...It is proposed that disestablishment of an ARFFS at a location be considered when passenger numbers fall below 400,000 and remain below this level for a 12 month period, through the preparation and consideration of a risk review by CASA.

This approach would provide a sufficient buffer between the threshold levels to prevent a cycle of establishment, disestablishment and establishment, due to seasonal or relatively small fluctuations in total passenger numbers over a 12 month period.

...It is proposed that the regulatory framework be updated to provide that where a “fire fighting related service” is provided at an airport that is not required to have an ARFFS, that service is not considered an “ARFFS” within the meaning of the CASR. Therefore this service will not be subject to the regulatory framework or regulation by CASA.

This would ensure the boundaries of CASA’s regulatory role are well defined while at the same time creating greater flexibility for the provision of “fire fighting related services” at airports that are not required to have a regulated ARFFS...

Clear as mud... Huh

- Yep thought so... Big Grin

However this is where I again saw a bizarre disconnect, referring to the top of the page in brown, remembering that the actual SSP service provider for ARFFS in Australia is still currently Airservices Australia:

Quote:...Aerodrome Rescue and Fire Fighting Services (ARFFS)—CASR Subpart 139.H provides that the ARFFS provider must have an SMS consistent with the requirements in the Manual of Standards, including the policies, procedures and practices necessary to provide the service safely...

You would have thought that it would be reasonable to assume (ASS-out of-U-ME) that the ASA SMS (within the context of the SSP) should be robust enough to incorporate such things as trigger points for risk assessments (for/against) having this emergency service at government leased airports... Huh

However you will notice how cleverly M&M flip-flops the responsibility and supposedly liability for who decides the threshold for what used to be an automatically provided emergency service - FDS! Dodgy

MTF...P2

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Kharon - 11-01-2016

Of Puddings; and, the proof therein.

Cheers P2; it is a long grind to winnow out the grist. But ‘twas in a worthy cause, the research clearly defines one man’s vision of how Australia views ICAO compliance; lip service, escape clauses and a gold plated platform, writ in weasel words, to ease the minds of ministers, baffle the public and sate the ICAO appetite for ticks in boxes.

It all depends on your ‘point-of-view’. For an idiot like Chester it is, categorically, manna from heaven. Look back to Pel-Air, never a catspaw of breeze on the ministers calm pond; never a rumpled brow at the ICAO table; not a hint of apology from CASA or a whiff of remorse from ATSB. None required – they all acted within the sturdy protection of ‘the system’.

That the ‘safety system’ is designed to protect government and agencies; not the travelling public is of no concern. Not even a Senate committee of good men and true could shake the foundations of ‘the system’ and the Iron Wrong simply shrugged off such trivialities as Senate recommendations, ministerial directives and the ASRR.

So, from the PoV of those in the system, it works just fine and all is dandy. Even if ; gods forbid, the unthinkable happened, the time it would take, the process to be worked through and the multitude of escape hatches would preclude any meaningful changes even then. It will take something we simply have not got to change this; a minister with balls, brains and a backbone. A narcissist, with the brain power of a well trained racing rabbit, the backbone of a jell-fish and as much interest in rocking anyone’s boat as a drowning man has in water, will not ‘order’ the SSP shelf-wear to be dusted off and used. Even then, ‘the system’ is a rigged game and the cycle continues – ad infinitum – only it will cost more now. Which suits everyone in ‘the system’ just fine.

So all is well at Sleepy Hollow and likely to remain that way for the foreseeable future. "As it was in the beginning is now and ever shall be" etc.

Selah.

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Peetwo - 11-01-2016

[Image: deceive-inveigle-obfuscate.jpg]

Q/ Has the Forsyth ASRR panel been deceived?

In recent days in the course of some PAIN research, I have been revisiting large parts of the Forsyth report. While trawling through the ASRR report I discovered a very disturbing discrepancy, one which seems to point towards the good Rev Forsyth and his esteemed international panel being accidentally misled.

The following is taken from page 13-14 chapter 1 of the ASRR report:

Quote:1.3.6 2008 ICAO Universal Safety Oversight Audit Programme

In February 2008, Australia’s aviation safety system was reviewed against ICAO’s global Standards. The audit identified a need to improve Australia’s capacity to retain technical expertise within the safety regulator. The report noted a need for more formal training programs for inspectors.

Figure 3 shows that ICAO’s Universal Safety Oversight Audit Programme (USOAP) audit of Australia’s safety system found the level of effective implementation of ICAO’s Standards and Recommended Practices (SARPs) was above the global average. However, in the areas of legislation, licensing, operations and airworthiness, Australia’s implementation was slightly less than other leading jurisdictions such as Canada, the United States (US), the United Kingdom (UK) and New Zealand. Australia was only benchmarked as having a higher level of effective implementation than its counterparts for accident investigation.

Dear Rev Forsyth et.al - Figure 3 above does not in anyway reflect the true FAA/ICAO USOAP findings in regards to effective implementation of the 8 critical elements of an ICAO USOAP audit. The actual graphic depiction from the 2008 ICAO USOAP audit is correctly represented on page 84 of the audit report:

Quote:

The graphic the ASRR report depicts is taken from the adopted (2010) ICAO Continuous Monitoring Approach. The CMA is a fundamental part of the integration of the ICAO Annex 19 and effective implementation of a State SSP:

Quote:In 2010, the 37th Session of the Assembly adopted Resolution A37-5, affirming that the evolution of USOAP to the CMA should continue to be a top priority for ICAO to ensure that information on the safety performance of Member States is provided to other Member States and to the travelling public on an ongoing basis. This vital improvement to international aviation safety required the participation and support of all Member States, particularly during the two-year transition period (2011 - 2012) while the tools and guidance required for USOAP CMA were developed.

As of January 2013, USOAP CMA is fully launched and its processes and tools are constantly reviewed to enable a more information-driven, risk-based and result-oriented approach. The objectives of the CMA include: monitoring States' safety oversight systems using a web-based platform — the "Online Framework" (OLF); validating States' progress through various on-site and off-site validation activities; and continuing to assess the effectiveness and sustainability of States' safety oversight systems through audits. With the CMA, the USOAP has gained in cost-effectiveness, dynamicity and flexibility (with the introduction of activities of limited scope).

The USOAP CMA will continue to evolve in the next few years, in order to support State's efforts in implementing a State Safety Programme (SSP). ICAO initially published in 2014 "new Protocol Questions (PQs) on safety management" to be used for audits and other continuous monitoring activities conducted under the Universal Safety Oversight Audit Programme (USOAP) Continuous Monitoring Approach (CMA). These PQs are being used to conduct voluntary and confidential assessments of SSP implementation at the request of ICAO member States. In July 2017, amended SSP-related PQs will be published by ICAO to reflect Amendment 1 of Annex 19, the 4th edition of the SMM and lessons learned to date. Although Amendment 1 to Annex 19 does not become applicable until November 2019, select States will be approached by ICAO with a view to performing audits including the amended SSP-related PQs in 2018 and 2019 on a voluntary but non confidential basis. As of 2020, ICAO will perform audits using the amended SSP-related PQs on the States which will meet the criteria to be established by ICAO, in line with the GASP.

You can see that the ASRR graphic, for Australia at least, can be exactly replicated in the ICAO safety audit information webpage:

Quote:

MTF...P2

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Kharon - 11-03-2016

As to the question -“Was it a ‘Cock-up’ or ‘Conspiracy’, M’lud?"

Looks very clear to me P2. I guess the question is, was it accidental or deliberate?

Two options here – ‘Cock-up’ or ‘Conspiracy’.

Shall we, in trust, examine the case for a ‘Cock-up’. A report must be prepared, for the Rev. Forsyth and his boys are coming for tea and biscuits. There exists a mountain of paperwork and some of it will be used as part of the exercise, so a junior is ‘tasked’ (as they like to say) to find some pretty pictures to add to the Rev’s file and a ‘wrong’ graph finds it’s way into the file pile. An error; which even in the best managed organization can occur. So, the ‘file’ is now compiled at low pay grade level and kicked up the food chain for editing and tweeking by the next level and the ‘error’ is not spotted – it happens – no doubt about it. Even so; by the time our ‘file’ has been through all the stages it must go through, having been ‘signed off’ (as they like to say) at each stage; it is ready for the Forsyth review panel. How many desks has this document crossed? How many of those sat at those desks spotted the ‘error’? Of those, how many were aware that there was an ‘error’ in the graphic data? Of those who did, who was the one who made a conscious decision to leave it stand? Who ‘signed off’ on the data to be presented to the Forsyth review?

Shirley; not everyone of these highly paid ‘experts’ failed to spot the ‘error’.

I say “If that is the truth M’lud, then there is a case of gross incompetence to be answered here; if not incompetence, then it is something much more sinister”. “I hesitate to use words like intent, fraud, conspiracy and cover up; although they do hover around the periphery of this ‘error’; furthermore, neither Forsyth or his team spotted the ‘error’ which is understandable, if not completely excusable”.

What it does prove, beyond any reasonable doubt, is that people don’t ‘read’ things; they skim through a glossy, carefully prepared brief and skip past the details. As we all know children; ‘tis in the detail the devil resides.

Aye well; too late now, and anyway; the ASRR has been consigned to the dusty archives; filed and forgotten, next to the SSC file; just flea bites, on the arse of the great elephant.

Toot toot.

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Peetwo - 11-07-2016

M&M and the three Stooges - The envy of the World?? Big Grin

Referring to the bollocks graphic handed to the Rev Forsyth's panel and supposedly representing the 'outstanding' results from the 2008 ICAO USOAP audit of Australia..

[Image: USOAP-fraud.jpg]

..it can be seen that besides excelling (almost 100%) in AAI, along with the USA we are clearly the role model for those ICAO States seeking guidance for perfect implementation of SARPs listed critical element 'Organisation'... Dodgy

Here is the ASRR comparison & comments on 'organisation' in comparison to other leading aviation safety nations:

Quote:..Around the world, governments have adopted different organisational structures to regulate their civil aviation sectors. Australia has a decentralised system, with an independent aviation safety regulator, an independent accident investigator, and an independent air navigation service provider, with other aviation matters overseen by other agencies. This structure is in the minority internationally, although broadly similar to the UK, New Zealand and Singapore. Many other countries, including China, France, the United Arab Emirates and Indonesia, have a single agency responsible for all aviation matters. Other countries, such as the US and Canada, apply approaches in between these two models, with an aviation safety regulator reporting to government through the national transport department...

..As a result of this decentralised structure, the functions typically associated with a country’s aviation authority are, in Australia, split across a number of different entities, as detailed in Table 2. The roles and responsibilities of each entity are set out in Australia’s State Safety Program (SSP), first released in 2011 in accordance with ICAO requirements. Australia’s SSP is discussed in more detail in section 3.1.1.

In the Panel’s view, the structure of Australia’s aviation safety regulatory system is sound. While a number of issues have been identified in how the system operates, significant structural change is not warranted.

So not hugely critical but excellence no... Rolleyes

However we have to remember that the ASRR graphic actually depicts the self-assessment of individual States through the developing CMA process based on a 'Performance Based' SMS ideology, which as part of the process sources State safety information through the representative protocol questions (RPQs):

Quote:The Evolution of a Performance Based System

The findings of the USOAP results’ analysis demonstrate that establishing strong safety oversight systems is a necessary first step to ensure the successful transition to improved safety management. Therefore, safety strategies must have the ability to consider the varying maturity levels of State’s safety oversight systems. States that have not yet implemented the eight critical elements of a safety oversight system effectively must first resolve these deficiencies and develop a sound foundation upon which to build their State Safety Programmes. Only those States having mature safety oversight systems will be able to realize the benefits associated with safety management principles, and achieve further reductions in their accident rates.

Representative Protocol Questions

ICAO safety experts analysed further the identified relationship between USOAP results and safety performance based on accident rates. The in-depth analysis led to the identification of a representative sub-set of protocol questions (RPQs), notably 114 out of 975 in total, which maintained the high correlation factor between the LEI percentage and the accident rate. This is an important finding as it will allow States to better focus their resources and safety improvement efforts and realize the desired reduction of accident rates in a timely and more efficient manner.

&..

Quote:The PQs are developed by the ICAO Secretariat and used for the verification of State's compliance to ICAO Standards and Recommended Practices (SARPS). The PQs enable auditing against the critical elements of a safety oversight system and provide guidance to the auditors on what evidence should be requested and reviewed. They also can be used by States to conduct internal audits.

Here is a link for the RPQs: List of Representative Protocol Questions

Now here is your chance, referring to the 114 RPQs if you put yourself as the 'auditor' of M&M's department and the three Stooges - i.e. CASA, ASA & ATSB - taking the RPQs in a tick-a-box survey of compliance, how do you think we would sit in 'Organisation' compliance with the ICAO SARPs.

Notes - Remember that according to the latest version of the M&M SSP:

a) ASA are a 'service provider' and therefore their SMS is supposedly oversighted by CAsA;
b) CASA have primary responsibility for oversight of the SSP;
c) The ATSB primary function is as the Annex 13 AAI and their secondary function is as the archivist of the Annex 19 defined safety investigation, concerns & issues database.

Also remember that in referring to the 114 RPQs you will also have to cross reference the applicable Australian ICAO SARP notified differences in order to appropriately tick or cross the boxes - Big Grin

Here is a QR link for the over 3000 Australian notified differences to ICAO: H67/16

Have fun... Big Grin

MTF...P2

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Kharon - 11-09-2016

“Irony is wasted on the stupid”

Oscar Wilde once said “Irony is wasted on the stupid”. But the ‘irony’ of the present situation is too delicious to let it slide away, unnoticed. To really ‘get it’ you must first read the ‘Winter newsletter’ from the RAAA – and the latest from AMROBA. Cannane and Davis in full flow, canny, logical, astute and undeniably correct. These inestimable gentlemen represent many organisations which are ‘compliant’ with not only the rules, but the edicts and policy (whims) of the ‘regulator’.

Compliance is a big deal; non compliance a death sentence. Even a minor infraction can lead to all manner of expensive trouble – if CASA decides to make it so. Compliance has become an almost manic obsession on both sides of the line, vast amounts of time, money and effort are invested by industry to ensure that not only are they ‘compliant’ but seen to be compliant; indeed ‘compliance’ has become a small industry in itself.

The irony? We’ll start with the questions.
Who is seen to be, but is not compliant with the ICAO?
Who is seen to be, but is not compliant with ministerial edict to reform?
Who is seen to be, but not compliant with the Senate recommendations for reform?
Who is not remotely compliant with the Forsyth recommendations?

In short, in a highly ‘compliant’ industry – the “R” regulator is not only ‘non-compliant’ but spends a great deal of time, effort and money appearing to be compliant, while doing exactly as pleases them best. There are now three fairly serious triggers to launch an investigation and report under the new State Safety Program (SSP). Australia signed up for this as an ICAO ‘compliant’ state; the ASA situation is (IMO) serious; the false radio traffic situation has the potential to be lethal; on a smaller, but no less important scale, controls for the UAV increase have been neglected. But you watch and see what CASA do about any of these things and their obligations to comply with the SSP. As an act of kindness, I’ll not take your bets, keep your money for a rainy day.

"In Paris they just simply opened their eyes and stared when we spoke to them in French! We never did succeed in making those idiots understand their own language.” Mark Twain.

Aye, Australia is compliant – 3000 differences with ICAO prove the pudding.

Toot toot.

Quote:P2 - "From the Horse's mouth...

..All of this is history but at a meeting at the end of May with the now Department of Infrastructure and Transport, CASA and members of The Australian Aviation Associations Forum (TAAAF), the Department and CASA made it clear that they were not bound by the recommendations of the ASRR report.

In a breathtaking, bureaucratic sleight-of-hand which would have had Sir Humphrey Appleby beaming with pride, the Dept and CASA stressed to TAAAF members ‘that it is the Government’s response to the ASRR recommendations that is being implemented and not the exact wording of text used by the Panel in the ASRR Report’.

In other words there is no intention from Government of being guided by the ASRR report itself or of seeking to satisfy the intent of the Report’s recommendations.

The Department also said that any review of the ASRR report implementation would take place after it was completed and would be carried out by an independent person, being not any of the original members of the ASRR panel.

It is clear that the bureaucrats have no intention of attempting to realise the objectives of the report and have simply turned this into a box ticking exercise...

So we get some more dots confirmed on the sorry ASRR timeline of embuggerance ..UDB? - No; pretty much business as usual for Murky, Comardy and his CAsA-phyte muppets ...

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Peetwo - 11-16-2016

[Image: slide_2.jpg]

SSP test case No1. - Harfwit's accelerate (me) program.

Yesterday the QON index was released and within the QON there was a large component to ASA addressing issues such as the ANAO OneSKY audit(s) and Harfwit's 'accelerate' sacking program. The answers to these QON will be very relevant to the next BRB SMS committee, which has recently been tasked with reviewing the ASA debacle as a test safety case for Murky's newly minted SSP... Wink

The BRB review will also assess whether Murky's department has considered the concerns of industry groups that were consulted on the original DRAFT of the SSP; or as is normally the case did M&M and his minions merely pay lip-service to those Alphabet groups concerns.

BRB example references RAAA submission:

Quote:II. RAAA Response to the Draft State Safety Programme

The Regional Aviation Association of Australia (RAAA) finds no significant issues with the Policy Statement as it is written. However we have serious concerns about the delta between the proposed situation and reality. The RAAA can cite numerous examples, but recognise most should be addressed in a separate forum to this submission. Therefore this submission will only identify high level concerns.

Policy statement paragraphs 3 and 9 claim that sound assessment of risks and service provider’s safety performance indicators are used to guide the regulatory development approach.

Just one example of where this policy is not applied is in the philosophical design approach to Civil Aviation Order 48.1. The current version is out of step with sound assessment of the actual risk faced by many mature Australian operators, and not based on empirical evidence in the Australian context.

Policy statement paragraph 6 claims that recognition of Australia’s safety regulatory system will ensure that Australia has a competitive aviation industry.

An increased focus is required in this area. Particular emphasis should be given to Bilateral Agreements with international service providers, particularly in the aviation maintenance sphere. The industry has agreed with the international harmonisation route on the basis that our regulations would be recognised and Australian operators could enjoy the associated obvious benefits. However the efforts and results from CASA in this regard are disappointing to date, despite numerous and costly investments in international face to face meetings.

Policy statement paragraph 10 claims that the appropriate personnel will be appointed to discharge their responsibilities competently.

Whilst sufficient financial and human resources have been allocated within areas of CASA, certain staff do not have the proper technical, people management, financial skills or appropriate industry experience to discharge their safety oversight and management responsibilities competently.

One final issue of significance that must be documented at this time is the disappointing lack of progress on the implementation of the Aviation Safety Regulation Review (ASRR). Page 8 of the draft State Safety Programme refers to the ‘Aviation Policy Group (APG) monitoring the progress of the delivery of the SSP and the SSP gives effect to the Aviation Safety Regulatory Review (ASRR) recommendations’. The RAAA has serious concerns on the lack of progress and the lack of visibility and surety that the policy intent of the recommendations has been correctly understood by CASA. A Post Implementation Review by mid-year to ensure the correct application is required.

III. CONCLUSION

The RAAA is grateful for the opportunity to provide our views for the Department of Infrastructure and Regional Development’s Draft State Safety Programme. If you would like further information about the items contained in this submission, or clarification on any of the points we make, the RAAA would be more than happy to assist.

AAAA SSP DRAFT submission:

Quote:In summary, AAAA’s primary concerns are:
 The document does not establish or recognise a partnership with industry that
underpins the program and the effective delivery of aviation safety.
 There is no recognition of consultative or other structures that might provide
industry with a clear role or pathway in assisting government and its agencies in
improving aviation safety or the SSP, or how industry can interact with or make
inputs to APG / AIG etc.
 While AAAA understands the various requirements for ICAO compliance that
drive the content and structure of the SSP, it should also be viewed as a key and
long-lasting document that will help drive domestic aviation policy settings as
well as international compliance.
 There remains a ‘delink’ between the very worthy principles espoused under the
Policy Statement - which AAAA supports - and their non-implementation by
agencies - especially CASA.
 The welcome attempt by the SSP to embed risk management as a key
consideration for regulation is hollow when compared to CASA regulatory
outcomes. AAAA strongly endorses CASA DAS Directive 01/15 - but it is not
being applied to recently introduced, problematic regulations such as CASR Part
61 or CAO 48.1. The CASA approach is still not risk-based and is still not
informed by a coherent classification of operations philosophy that gives the
highest priority to passenger carrying operations.
In particular, the application of a classification of operations policy that results in a
strong focus on passenger carrying operations, thereby permitting more creative -
even safer - approaches to the regulation of general aviation and private
operations, has not been in place for at least 10 years, and CASA continues to
struggle with the practical implementation of such a policy. Clearer details on
how this is proposed to be turned from a broad policy statement in the SSP into
practical actions by agencies would be welcome.
 There is a ‘delink’ between the Policy Statement regarding ‘active and ongoing
engagement of industry’ and the fact that a number of agencies - ATSB, BITRE
and even the Department have no formal consultative mechanisms with industry,
perhaps other than the Ministerial Aviation Industry Advisory Council and the
more recently formed GA Action Group. In CASA, the SCC remains in
suspension, waiting for a decision on a new mechanism that has been
recommended by an SCC working group on the issue.
 There is a ‘delink’ between the SSP statements regarding the focus on SMS
approach to safety (eg page 13 of the draft), and the ongoing CASA approach to
focusing on mainly ‘compliance’ issues. This combines with CASA’s inability to
construct and implement a classification of operations policy that determines the
resources it expends on aerial work surveillance and audit, for example. In turn,
this results in the SSP describing a system focus that is simply not evident in dayto-
day interactions with CASA field staff.
 There remains a lack of CASA commitment to surrendering power over some
sectors, despite CASA Sector Risk Profiles identifying industry led programs as
making a significant contribution to risk reduction. AAAA programs including
AIMS, the Chief Pilots Course, Standard Operations Manual, Professional Pilot
Program etc are all identified in the SRP as being valuable programs. However,
CASA is struggling with recognition of these programs and is requiring significant
additional resource expenditure by industry before it will recognise programs it
has already accepted as reducing risk. It is ridiculous that AAAA has been
required to submit a formal paper to CASA on the safety benefits of the AIMS
program, arguing that having an SMS is superior to not having an SMS - and even
quoting CASA own words on this issue when they introduced mandatory SMS for
RPT back to them. There is need for a stronger direction to agencies to honour the
pathways identified in the SSP.

And BRB Senate Estimates QON reference 'accelerate program':
CASA - QON 141-142:

Quote:Senator XENOPHON: Okay, so these are questions I could properly put towards Airservices, and I will. But my understanding is that Airservices is required to provide a risk assessment to CASA arising out of organisational change. Is that the case?

Mr Tiede: That is correct.

Senator XENOPHON: Have they done this in this case?

Mr Tiede: They have.

Senator XENOPHON: Are you able to provide us with a copy of that risk assessment?

Mr Tiede: I do not have it with me, but yes.

[b]Senator XENOPHON: Can you provide details to this committee of the information that has been requested, including any emails, correspondence, notes or other documentation as to the flow of information between CASA and Airservices Australia about this organisational change.
[/b]

Mr Tiede: We will be able to do that—not right now.

[b][b]Senator XENOPHON: I realise that. I am asking you to take it on notice. [/b]

[/b]So the BRB will eventually (probably the day before next Estimates - ) get a copy of the Harfwit risk assessment and any other applicable documentation and/or correspondence between ASA and CASA.

ASA - QON 146-148:

Quote:E.g. QON 148
...Senator STERLE: That is good. Could you give us a list by area of the work-level descriptors for the changed roles?

Mr Harfield: What they are? We can provide that. That might take a little bit longer than tomorrow. As a result we are still in the middle of the process and finalising those over the next two weeks. So we can provide them after 24 October, if that is okay.

Senator STERLE: That is fine. And work functions that will be ceased or done differently?

Mr Harfield: That have changed? We can provide that.

Senator STERLE: All right. Can you provide the total number of staff who have been moved from enterprise agreements to individual contracts over the last 24 months?

Mr Harfield: Yes, we can provide that.

Senator STERLE: There are the ones you are talking about now—and if there are any further ones planned for the next 24 months.

Mr Harfield: If I can just clarify so I get this correct: we were not talking about people who have applied for roles before this change who have then—

Senator STERLE: No, I am aware we have not.

Mr Harfield: So it is in regard to the change—on the areas that we have proposed. We can do that. We chose the same answer to the previous questions you have just asked.

Senator STERLE: Okay, so that will alleviate my concerns—

Mr Harfield: The information you have already asked for will cover that.

Senator STERLE: Okay, and perhaps you could include their position title, years of service and date of transmission of industrial agreements and on to contracts for us.

Mr Harfield: We can do that.

ASA - QON 150 - 154:

Quote:Eg. QON 153
Senator XENOPHON: Right. Would it not therefore be logical, or reasonable, that given the magnitude of the change there would be a risk assessment provided to CASA arising out of the organisational change?

Mr Harfield: A risk assessment associated with the areas that CASA are interested in. There is not a risk assessment handed to CASA for all of the risks associated with the entire organisation—

Senator XENOPHON: So what areas are CASA interested in?

Mr Harfield: The effects on our air traffic services; our engineering and aerotechnical area, our air traffic services training area, our procedures design area and our aeronautical information management, as well as aviation risk and flight—

Senator XENOPHON: I just want to race through this. Thank you for that. If there is any—

Mr Harfield: We can provide this information—

Senator XENOPHON: Get me a list. But I want to understand what triggers a risk assessment, because I am concerned about the information I have—that the risk assessment was not carried out to CASA as some considered it ought to have been. In other words: who determines whether there should be a risk assessment, given the magnitude of these changes? Is it your call, or does CASA tell you what they want?

Mr Harfield: No, we have a safety management system that determines it. For each particular change, we make a determination through what we call a safety case determination. We go through that to determine what the magnitude of the change is for the area affected, as well as what the significance is. That will then tell us what level of safety work is to be done. We have also completed what is called a safety plan, which details all the safety work that has to be undertaken through a particular change. We can provide that to you.

Senator XENOPHON: If you could provide all those documents to the committee, that would be useful. My understanding was that CASA had some difficulty getting this information. Was any concern expressed to Airservices by CASA about any difficulties in getting this information—a risk assessment of these organisational changes?

Mr Harfield: I am aware of a couple of instances where certain requests were made and there had to be a discussion about what exact information was required, but there has been no withholding of information or cases of information not provided.

Senator XENOPHON: Could you provide copies of those documents or that interchange? That might put in context the concerns that have been expressed to me. My understanding is that, in the first round of redundancies, there were 240 redundancies in ANS—could you help me with the acronyms?

Hmm...very forthcoming was our match fit Electric Blue Harfwit - certainly be a lot for the BRB to chew on when that lot of AQON comes back... Rolleyes

MTF...P2

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Gobbledock - 11-16-2016

Of making airports great again

This one sort of snuck in below the ILS so to speak, back in September. Australian Airports Association release.

They have completed a study which indicates that regional airports are underfunded by around $180m per year. That has a flow-down affect on a stifled aviation economy, loss of productivity, strangulation of businesses and increase in safety risks.
Release;

http://www.airports.asn.au/web/dev/uploads/others/AAA%20Media%20Release%20-%20Regional%20Airport%20Infrastructure%20Report%20(30%20September%202016).pdf

Article by Herr Bingers;

http://www.theaustralian.com.au/business/aviation/regional-airports-under-strain-acil-aallen-report-for-aaa/news-story/e95d864f60135d044b5212865ccabae4

So it's no real surprise when you see that;
- The big airports are a monopoly, a rort, a gouge, and been flogged off by government.
- The smaller regionals are being strangled by compliance, old infrastructure, many are Council owned (and local Government couldn't fix a pothole properly let alone manage an airport), and they simply don't have enough coin rolling in through the door.
- While tools like Malcolm 'Goldman Sachs' Turnbull look after big business and award $50b submarine contracts, our airports are turning to shit. Government has priorities you say? Yeah right.

Shit airports. Shit roads. Shit highways. Shit schools. Everything infrastructure wise in this country is becoming antiquated, buggered, use and abused, suffers from piss-poor future planning, and on top of that ends up in a ministerial portfolio in which the people with oversight are normally nothing more than trough dwellers who have sucked and bribed their way into Government, or spent years knifing, plotting and destroying and manipulating others so they can get their own ringside seat at the trough. Neither they nor their minions know SFA about the portfolio, have no technical or industry skill in that particular area of business, and then people wonder why everything has turned to shit!

Tick Tock

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Kharon - 11-17-2016

The big book of none answers.

N.B. This is a repeated post - learned it from DDDD, saves time.

P2 ...”makes you want to vomit because it is pure unadulterated bollocks...”

Not just wanted to – bloody well near did. New rule – I ain’t going to read any more ministerial responses to serious reports. Not worth the time, effort or aggravation. So ducking predictable; there must be a big file some where for idiot Polly’s. The big book of PC none answers. Published as ‘How to tell lies, do nothing and get away with it’.

Minion – “Minister, Sir; sorry to interrupt your stylist, but the peasants are revolting”.

Minister - (languid like) “Yes, they are; (yawn) what is it this time?

Minion – “That airport crowd have produced another report; it is factual and it seems the aerodrome infrastructure is collapsing around the aviation industries ears; its serious I’m afraid”.

Minister – “Look here Minion, I can’t have my stylist disturbed every time there is another aviation crisis; this is a very expensive, sensitive artist here, making sure that every single hair is immaculate, and the tailor is going to be late; I may get photographed later (or do it myself); this is important stuff, my image must be preserved”. (Sigh).

Minion – “ I am aware of that Sir; but, this does seem to require a response; in fact it seems quite urgent, there’s a fair few of ‘em in the lobby and they seem a little irate”.

Minister – (snaps irritated) “Just look in the ducking big book; the airports page is just before assholes; look down the index, find the nearest listed complaint to the latest; go to that page and print out the ‘official’ response; get that to the media people and make sure they use the picture of me looking appropriately concerned; then distribute it”. Got that?. Good, now bugger off – I am really busy here.

Minion – “Yes Sir; Oh, I love it when you get all decisive, may I take your picture for my children?”

Minister – (bored) I suppose so, but make sure you get my best side.

How many more of these say nothing, time buying, trite, work-shopped answers do we have to read through? FFS these clowns are just doing a little as possible, ensuring they rock no boats; biding their time until the next election, making sure that the indecent pension and perks increase. It is absolutely ducking disgusting.

Toot, toot – bloody toot. (This is a recording).

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - thorn bird - 11-17-2016

"How many more of these say nothing, time buying, trite, work-shopped answers do we have to read through? FFS these clowns are just doing a little as possible, ensuring they rock no boats; biding their time until the next election, making sure that the indecent pension and perks increase. It is absolutely ducking disgusting."

That's what they pay the Murky Mandarin the big bucks for, but I have to admit his sound bite ministerial statements are getting to be a bit stale, especially the ones about CASA being the worlds leading regulator, or Australia is the world leader in safety or safety is our number one priority. Jeez these have been used so often, by succeeding ministers they're covered in rust.

Hey Murk's, surely you could polish them up a bit, or dream up some new ones, industry needs a few more laughs.

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Peetwo - 11-17-2016

(11-17-2016, 07:37 AM)Peetwo Wrote:
(11-16-2016, 09:39 PM)Gobbledock Wrote: P2;

"If 4D was actually sincere about the above statement then you would think that he would have responded by accompanying the AAA MR with a presser from his own office?? But for some reason that didn't occur".

Very good pick up P2. Well done. Pollies love positive Pressers. Perhaps he saw that there was a risk he may have to shelve out money, hence his forgoing some PR? Or maybe he was busy at the hair salon that day getting his todger trimmed and primed for another men's urinal selfie shot? And that's about the truth of it isn't it? This der-brain Politician hasn't got a clue. He accepts a report, shakes someone's hand, twerps it out on Twatter (probably along with a photo of his perfect hair and manscaped body), files the report on Barmyboys top shelf under the heading 'More IOS Complaints' and leaves it there to gather dust for the next half a century.

(11-17-2016, 05:31 AM)kharon Wrote: The big book of none answers.

P2 ...”makes you want to vomit because it is pure unadulterated bollocks...”

Not just wanted to – bloody well near did. New rule – I ain’t going to read any more ministerial responses to serious reports. Not worth the time, effort or aggravation. So ducking predictable; there must be a big book, tucked away somewhere for idiot Polly’s. The big book of PC none answers. Published as ‘How to tell lies, do nothing and get away with it’.

Minion – “Minister, Sir; sorry to interrupt your stylist, but the peasants are revolting”.

Minister - (languid like) “Yes, they are; (yawn) what is it this time?

Minion – “That airport crowd have produced another report; it is factual and it seems the aerodrome infrastructure is collapsing around the aviation industries ears; its serious I’m afraid”.

Minister – “Look here Minion, I can’t have my stylist disturbed every time there is another aviation crisis; this is a very expensive, sensitive artist here, making sure that every single hair is immaculate, and the tailor is going to be late; I may get photographed later (or do it myself); this is important stuff, my image must be preserved”. (Sigh).

Minion – “ I am aware of that Sir; but, this does seem to require a response; in fact it seems quite urgent, there’s a fair few of ‘em in the lobby and they seem a little irate”.

Minister – (snaps irritated) “Just look in the ducking big book; the airports page is just before assholes; look down the index, find the nearest listed complaint to the latest; go to that page and print out the ‘official’ response; get that to the media people and make sure they use the picture of me looking appropriately concerned; then distribute it”. Got that?. Good, now bugger off – I am really busy here.

Minion – “Yes Sir; Oh, I love it when you get all decisive, may I take your picture for my children?”

Minister – (bored) I suppose so, but make sure you get my best side.

How many more of these say nothing, time buying, trite, work-shopped answers do we have to read through? FFS these clowns are just doing a little as possible, ensuring they rock no boats; biding their time until the next election, making sure that the indecent pension and perks increase. It is absolutely ducking disgusting.

Toot, toot – bloody toot.

Absolutely spot on GD, TB & Ferryman, except I'd expand on the title somewhat...

...none answers for morally & financially bankrupt governments...

Quote:...Or reference the 89.9 million pot of money the ATSB was given to fund and manage a far too narrowly scoped MH370 SIO search, yet Hoodlum begs poor in the recent ATSB AR:

Quote: The Australian Transport Safety Bureau will scale back its non-fatal accident investigations. (AAP)

The chief commissioner of the Australian Transport Safety Bureau has outlined plans to constrain the scope of non-fatal air investigations.
Source:
AAP
20 Oct 2016 - 11:10 AM UPDATED 20 Oct 2016 - 11:10 AM

The government agency overseeing air safety in Australia says it will have to scale back the number of non-fatal accidents it investigates because of limited resources.

Australian Transport Safety Bureau chief commissioner Greg Hood says his organisation will continue to investigate most accidents and serious incidents involving the travelling public.

But he wants to be more efficient, by becoming more "data-driven".

In so doing, the bureau will be able to more selectively allocate its limited resources to investigating those accidents and incidents that have the greatest potential for improving safety, Mr Hood writes in the ATSB's annual report.

"If there is no obvious public safety benefit to investigating an accident, the ATSB is less likely to conduct a complex, resource-intensive investigation."

Mr Hood says the bureau endeavours to investigate all fatal accidents involving VH-registered powered aircraft in Australia subject to the resources available and what can be learnt from the incident.

"But we will need to carefully consider the resources we allocate to investigations into general aviation fatal accidents and constrain the scope of investigations into non-fatal accidents in this sector," he writes.

There were not many safety benefits in investigating incidents which have obvious contributing factors, such as unauthorised low-level flying or visibly flying into poor weather.

"Instead, educating pilots on the dangers of high-risk activity is where we will refocus our efforts, with an emphasis on using social media."

Mr Hood says technology is already having an influence on his bureau's work, especially given the use of drones.

He notes pizza delivery using the technology is reportedly imminent

However there is a solution to all this that would top up the aviation coffers and do away with the trough feeding parasites. Reference a comment by 'a snivelling, miserable coward' from UK online publication 'the Register':

Quote:
Quote:50 tech jobs to go at AirServices Australia

AirServices Australia is set to axe around 50 jobs across its IT department as part of sweeping cuts that could see 900 positions cut. The cuts are part of the Accelerate program, the ABC reports, and have raised concerns of safety from pilots and AirServices air traffic controllers. AirServices was not immediately available …

Something's not right.

According to an ASA PR droid, "...would only affect back office and technical staff."
Umm, clerical types aside (and they're no less important) but the 'technical staff' are those that keep the stuff running so the controllers can do their jobs.

They say that they're about to pull the plug on 22%
of their existing staff, so either:-

a) ASA management were asleep at the wheel and allowed the staffing to get totally out of hand over the last x years so they are presently severely overstaffed and need to be cut, or
b) There's going to be a significant reduction in service and system reliability if you pull that number of 'support' / tech staff.

Given that of the 4000 employees, 1000 are controllers who are supposedly 'quarantined' from the cuts, this really means that they're cutting 900 from the remaining 3000 employees, or 30% of the remaining staff.

With a great amount of regret, I can foresee services, and therefore safety, being impacted by radar / radio / IT / etc failures which will be put down to "lack of support staff" when it happens (and I suspect it will happen).

Either way, ASA management have some explaining to do.

AC for much the same reason as the previous poster.

Re: Something's not right.
Perhaps they're getting the whole thing ready to be privatized?

ASA and quite a few of its previous incarnations at least as far back as the early '90s have looked at Canada as a similar ATC situation to the one we have here - turn Oz 90° clockwise and you'll see the similarity. Melbourne/Cairns is quite a lot like Vancouver/Ottawa. Most of the high density traffic runs along one rather long edge with lots of nothing elsewhere (sorry, Perth).

Canada turned private in 1996 as Nav Canada, a privately run, not-for-profit corporation. They have gained a great reputation for themselves. This quote is from Forbes.com in Feb this year:-

Nav Canada runs one of the safest systems in the world, and it has won three International Air Transport Association (IATA) Eagle Awards as the world’s best ATC provider. Nav Canada is a “global leader in delivering top-class performance,” says the IATA. Nav Canada has developed new technologies that it exports around the world.
Remember when Australia was a leader in world aviation circles?

The UK turned private in 2000 as NATS, a public-private partnership involving the government (49%) and others. My spies tell me that they don't think much has changed there, despite the privatisation.

If we did go private, we could do worse than look at the Canadian system.

AC as seems to be the tradition here...

But that won't happen too much political risk for poor old Dazzling Dazza & Barnbaby in such ridiculous proposals - FDS...

Expanding on the current theme, via Planetalking today Wink

Quote:ATSB reminds us that cost cutting driven mediocrity is Govt policy
A half baked NBN, a crippled ABC, and an underfunded air safety investigator are examples of ideological neglect of public services

Ben Sandilands

A Greg Hood happy snap from our AAP service.
Commentary

This morning’s kerfuffles in the media over the realisation that the NBN is generating community concerns over its unreliability and pathetic download speeds are just one of the dots to connect when it comes to a breakdown in the standards of public services.
Take this repeat of an SBS story from last month by the aptly named PAIN_NET air safety forum about Australia’s transport safety investigator, the ATSB, having to restrict its scope because of funding cutbacks.

Despite the efforts by the chief commissioner of the ATSB, Greg Hood, to put the best possible construction on the the funding destruction of the agency, there are obvious risks to its charter when it tries to decide prior to an inquiry that there is nothing worthwhile in the causes or circumstances of an accident or incident that would contribute to improved aviation safety outcomes.

In terms of logic, its a course of action that could prove fatally flawed, but the real charter of public bodies in Australia under Labor and its faithful Coalition government successors, is to cut the spending back to levels that will bring them, sweating blood and the discarded talents of terminated experts, to the edge of collapse.

It’s why we have an ABC that can’t correctly pronounce the names of country towns, successfully cue sound and vision on live broadcasts, and has no idea when it is being misled by a PR campaign into spruiking some ridiculous assertions affecting the health or nutrition of its audience. As well as an NBN which is designed specifically to fail to provide world class broadband speeds to users, including bandwidth hungry entrepreneurs or medical services.

This is the ABC that went along with the supermoon hysteria, and refused for hours to acknowledge that Tim Peake wasn’t in fact the first British astronaut, when that honour belonged to the forgotten feminine and apparently lower class Helen Sharman.
(The ABC these days will report anything without checking it seems. None of this ‘truthiness’ is to be tolerated by the increasingly narrow narrow focused national broadcaster in these post-truth times.)

The only thing agile and innovative about the policy settings successive Australian governments have pursued with public service entities, including transport safety bodies, is to discourage or hunt down and ‘kill’ their employment of talented public minded people.

Where will this lead us? To a roll back of pure food acts, the total safety deregulation of the trucking industry (which appears to have been largely achieved), the closure of superfluous publicly owned media, or to a great big stinking and bloody plane crash. This isn’t a Labor V Coalition rant, it’s a real set of questions about public administration settings right across the political spectrum, and the rot has been spreading for years.

In reply Dan Dair asks some valid QON

Quote:Dan Dair
November 17, 2016 at 1:01 pm
Ben,
I thought,
(& I may be completely mistaken in this assumption)
that Australia had a duty to the nation but also to the worldwide aviation community
incorporated into the ‘membership’ of ICAO.?

In order to support its continued membership of this world community,
Australia must comply with its minimum standards.

You have previously noted a number of occasions when the ATSB or CASA have failed to reach these standards.

Lack of public funding for Australias’ presiding authorities is domestic political & electoral issue. What do ‘the people’ actually want to be achieved ‘in their name’.?

However, fulfilling its international treaty obligations is more than a domestic issue, it is surely a legal requirement.?

Without at least a cursory examination of the facts, how can any authoritative body ‘know’ whether something is worthy of investigation.?

How can an authority make that ‘judgement-call’ at all & still comply with international law or protocol.?

Is Australia about to lose its ‘1st world’ status in aviation because of funding-cuts.?
How will Australians react to the international body regarding their nations safety oversight as no-better than central Africa or South America.???

How will the politicians defend or justify themselves, if/when such a downgrading occurred.?

& JW answers the DD honest but naïve QON...

JW (aka James Wilson)
November 17, 2016 at 2:13 pm

Dan,
A bit of background: Australia is a signatory to the Convention on International Civil Aviation, commonly known as the Chicago Convention. The Chicago Convention is given legal effect in Australia by the Air Navigation Act 1920. ICAO issues international standards and recommended practices and procedures under Article 37 of the Chicago Convention and publishes them as Annexes to the Convention. States that are signatories to the Convention are expected to abide by the standards and recommended practices published in the Annexes, however, where a State finds it impracticable to comply, Article 38 of the Convention allows the State to notify ICAO of the difference. The difference is then published as a supplement to the respective Annex.

In short, a country can choose not to follow all of ICAO’s standards and recommended practices, provided it notifies ICAO of the difference. Most countries have various notified differences. Australia has more than most, many of which are northing more than minor changes in definitions or wording, but some of the differences are more contentious.

In the case of Annex 13, contracting States are required to investigate all accidents and serious incidents. However, Australia has notified a difference that it may not institute an investigation into some accidents or serious incidents. The difference states that the decision on “whether a particular domestic accident will be investigated will depend on resources and the likely benefit to future safety, particularly in the general aviation sector”.

Australia has therefore covered its legal requirements by notifying ICAO of the difference. The practical effect of that difference on air safety outcomes in Australia is obviously open to debate.

MTF...P2

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Peetwo - 11-22-2016

Oh FDS just blame it on the pilot - Dodgy

Following up his last highly informative post on an individual State's obligations as a signatory to ICAO, JW (aka James Wilson) follows with an excellent explanation on the ICAO USOAP audit system and how Australia dodged a bullet in the ICAO/FAA 2008 audit:

Quote:JW (aka James Wilson)
November 19, 2016 at 9:49 pm
Dan,

ICAO does not ‘sanction’ Member States, but it does monitor and audit them for compliance with ICAO standards through its Universal Safety Oversight Audit Program (USOAP). A serious deficiency in a State’s safety oversight capability results in the publication of a Significant Safety Concern (SSC), the details of which are made available to the State concerned to help it fix the problem, and to all ICAO Member States so they might take appropriate action to ensure safety. There are currently SSCs in place for Angola, Djibouti, Eritrea, Haiti, Kyrgyzstan and Thailand.

A USOAP audit in 2008 highlighted a number of areas where Australia was not compliant with ICAO standards. Most of those deficiencies were addressed to ICAO’s satisfaction and certainly didn’t result in an SSC, however, one area that was not addressed related to aircraft accident investigations. ICAO recommended that “Australia should provide sufficient funding to the ATSB to allow the investigation of all aircraft accidents and serious incidents in accordance with Australia’s responsibilities under ICAO Annex 13”.

Australia chose to lodge a difference with ICAO, noting that “Australia considers it impractical to investigate all accidents and serious incidents within resources available. In addition to targeting those accidents and incidents that are likely to yield the greatest safety value in accordance with the guidelines quoted above, Australia normally gives priority to investigations of accidents and serious incidents involving regular public transport aircraft (especially with fare-paying passengers) and accidents involving fatalities other than those involving ultralights and sport aviation.”

ICAO gives Member States an Effective Implementation (EI) percentage that measures their compliance in various areas, including legislation, organisation, licensing, operations, airworthiness, accident investigation, air navigation services, and aerodromes. Australia’s overall EI is currently 85.14, vs 91.36 in the USA, 93.63 in the UK, 95.28 in Canada and 83.72 in New Zealand. Australia certainly has room for improvement, but its EI is well above the global average and is vastly better than countries such as Djibouti, which has an EI of just 4.14. In the area of aircraft accident investigation, Australia’s EI is actually 96.97, which is amongst the world’s best and better than Canada (91.58), Great Britain (84.21), New Zealand (68.75) and the USA (82.47). Draw your own conclusions, but perhaps that’s a reflection of ICAO’s methodology rather than Australia’s investigative performance!

Very much related - from off the UP's current thread on the PelAir v KazCasey appeal - credit where credit is due Slats, I believe, firmly nails together several previously un-associated dots... Wink

Quote:slats11 - I wonder what would happen.....

if an operator passed a routine CASA audit in 2008,

and then in 2009 FAA held concerns about CASA's oversight such as "excessive delegation of regulatory functions to carriers", and the FAA was therefore contemplating recommending a downgrade of Australian aviation to category 2 (which would have enormous ramifications),

and then in November 2009 said operator ditched off Norfolk because the plane ran out of fuel and couldn't reach an alternate airport,

and then the subsequent CASA audit in November - December 2009 found numerous deficiencies with the operator which raised questions about the effectiveness of CASA's oversight (and indeed raised questions about the earlier 2008 audit),

and ...... this all happened right at the very time (30 November - 4 December 2009) the FAA were back in Australia to decide whether to recommend whether Australia should be downgraded to category 2,

then I wonder what CASA would do with the post-accident audit.

It must have been a very strange time at CASA - being audited by the FAA at the same time CASA was performing an audit on the Norfolk ditching. Very strange indeed.

https://wikileaks.org/plusd/cables/0...RRA1081_a.html

I must admit I never really joined up those particular dots, to be honest I was probably too disturbed by the needless harm being inflicted on the victims of PelAir, in particular KazCasey & DJ - Sad

However what I found really fascinating and in some ways equally disturbing was the WikiLeaks cable:

Quote:B. CANBERRA 1040 Classified By: Political-Economic Counselor Edgard Kagan, Reasons 1.4 ( b)(d).

1. (C/NF) Summary: The FAA team concluded their audit (reftels) and gave a brief assessment of preliminary findings. While the team recognized improvements on previous shortcomings and commended many areas, a few problems remain. Australian officials seem committed to overcoming the shortcomings before a second and final FAA visit within the next three months, but the possibility of a category downgrade does exist and is being taken seriously. The team outlined the sequence of events going forward and agreed to work closely with Embassy Canberra. End Summary.

2. (C/NF) The FAA team gave a preliminary assessment of their November 30 - December 4 audit to Australian Civil Aviation and Safety Authority (CASA) officials and separately to DCM Dan Clune. The team explained the significant shortcomings, discussed potential scenarios, outlined the sequence of events going forward and agreed to work closely with Embassy Canberra. Problem: --------

3. (C/NF) While the team recognized improvements on previous shortcomings and commended many areas, there remain a few shortcomings, principally a shortage of properly-trained inspectors and excessive delegation of regulatory functions to carriers. Approximate Timeline: ---------------------

4. (C/NF) Based on our conversations with FAA team members, following is a rough sequence of events going forward: -- Two weeks: Informal letter FAA team to CASA (through State/Embassy Canberra) delineating specific areas from their assessment that need to be addressed. This is meant to aid CASA to swiftly focus efforts on overcoming shortcomings. -- 30 days: Formal State front-channel cable with official report of the week-long assessment, constituting official notification from FAA to CASA under ICAO. According to the FAA team, this cable will most likely state that Australia does not/not comply with ICAO standards and indicate that, if the problems are not remedied, it would be downgraded to Category 2. The cable will also request further consultations, which would include a second visit to Australia within 65 days after the first visit. -- 65-90 days: Second visit to Australia, probably by the end of February 2010, by a smaller team. This would be a shorter verification trip which would determine whether or not to recommend a downgrade to Category 2. -- Mid-March 2010: Approximate timeframe when FAA would publish official notice of a Category 2 downgrade, in the event this were to happen. Preventing Worst-Case Scenario -------------------------------

5. (C/NF) A downgrade to Category 2 would be the worst-case scenario, which would entail measures such as freezing Australia-U.S. flight operations to current levels and terminating code-sharing arrangements, such as the one between Qantas and American Airlines. CASA officials are not taking this possibility lightly and seem committed to resolve the shortcomings in order to avoid a downgrade.

6. (C/NF) Comment: FAA team members were extremely satisfied with CASA officials' openness and eagerness to make constructive improvements based on the assessment. FAA Qmake constructive improvements based on the assessment. FAA and CASA clearly have a good working relationship and we will monitor progress toward maintaining Category 1 status. We will also monitor that CASA's efforts enjoy adequate support at the ministerial level as well as from CANBERRA 00001081 002 OF 002 Australia's commercial airlines. BLEICH

One line from the above stood out more than any other because I thought on how much this was still the status quo, if not worse today... Confused

"...principally a shortage of properly-trained inspectors and excessive delegation of regulatory functions to carriers..."

'Carriers' in my opinion is a bit too general and should really include all air service operators, including Airservices Australia and aerial ambulance/emergency service operators like PelAir. However, as the VH-NGA ditching proves again and again, that then leaves option A for dodgy air service providers facing possible CASA embuggerance from an accident/incident:

"There is no problem so complex that it cannot simply be blamed on the pilot."

— Dr Earl Weiner (Reminded of quote by Vref+5 off the UP) - Wink

MTF...P2

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Peetwo - 11-24-2016

JSCT recommends BASA treaty amendments be ratified - Wink

Yesterday the Joint Standing Treaties Committee tabled Report 166 which reviewed...

..Amendment 1 to Revision 1 of the Implementation Procedures for Airworthiness covering Design Approval, Production Activities, Export Airworthiness Approval, Post Design Approval Activities, and Technical Assistance between Authorities under the Agreement on the Promotion of Aviation Safety and Addendum to the Implementation Procedures for Airworthiness between the Government of Australia and the Government of the United States of America...

The following committee conclusion & recommendation was made:

Quote:Conclusion
2.47 The Committee supports the ratification of the treaty actions.

Recommendation 1

2.48 The Committee supports the following two treaty actions and recommends that binding treaty action be taken:
§ Amendment 1 of Revision 1 of the Implementation Procedures for Airworthiness between the Government of Australia and the Government of the United States of America; and
§ the Addendum to the Implementation Procedures for Airworthiness between the Government of Australia and the Government of the United States of America.

However this committee review & report also contained some fairly damning observations of CASA's inadequacies, inefficiencies, lack of expertise in being able to effectively administer and oversight industry. There was also a subtle inference that, despite the ASRR recommendations, there was still a long way to go before CASA is once again trusted and respected by industry... Confused

Quote:Problem: --------3. (C/NF) While the team recognized improvements on previous shortcomings and commended many areas, there remain a few shortcomings, principally a shortage of properly-trained inspectors and excessive delegation of regulatory functions to carriers.

Examples from 2008 ICAO USOAP report: ..CASA’s Human Resources Management Branch has recently established a training policy that makes a commitment to provide initial, on-the-job, recurrent and specialized training to its staff in the area of airworthiness. However, no training programmes have been developed detailing the type of training to be provided to technical staff in each position, including periodic training plans. In general, the training provided to technical staff is insufficient to address the competency requirements for all the technical tasks...

...CASA’s Human Resources Management Branch has been developing a Competency Based Training (CBT) programme for all CASA staff and some courses that underpin this programme have been delivered. However, the existing technical training matrix does not address all the specific training needs of the Airworthiness Engineering Branch (AEB) and its technical staff. In addition, final review and approval of the CBT programme is still pending. Managers of the AEB identify and provide training to their technical staff, including the staff of the field offices, on a yearly basis. However, some specific training has not been provided (i.e. training on human factors) and while on-the-job training is provided, it has not been documented...

It also clear from the committee's OBS that the CASA of today has stubbornly refused to address the concerns of the 2008 ICAO/FAA USOAP audit team:

Quote:Resourcing and demand

2.38 During the public hearing on 2 May, CASA noted that the industry, being aware of the impending changes, had been making increasing numbers of applications for STCs. At the time of the public hearing, CASA stated that it had about 40 applications pending.40

2.39 Concern has been expressed that CASA is not adequately resourced to handle its current workload with regard to applications for STCs:

… it often takes CASA a long time to approve complex STCs and similar modifications. The fundamental reason is that in a small aviation manufacturing country like Australia, CASA cannot hope to attract and retain the calibre and quantity of people required to fulfil the task required. Nor can it afford to do so. These limitations apply equally across the spectrum of CASA’s activities. The problem is exacerbated by the lack of trust between CASA and industry as noted in the ASRR (Aviation Safety Regulation Review), which denies CASA assistance from industry to acquire at least some of the required knowledge.41

2.40 The Committee discussed with CASA witnesses whether the agency has the resources it needs to assess the pending applications in a timely manner. Asked for the specific number of STC applications outstanding for various periods, CASA supplied the following details:
as at 30 April 2016: 18 STC applications outstanding;

as at 30 June 2016: 21 STC applications outstanding; and

as at 15 September 2016: 23 STC applications outstanding.42

2.41 The CASA witnesses argued that the time taken to assess each STC application varied based on the complexity of the application:43

All STC applications are usually assessed and accepted with a response provided to the applicant within 2 to 3 business days. It should be noted that this process relates to the administrative assessment of the application form and initial supporting documentation. Once the STC application is accepted the STC process begins and the time spent on each application will depend on the complexity of the modification, required involvement of CASA officers and the quality of documentation provided by the applicant.44

2.42 In general terms, CASA indicated that at present it has sufficient resources to deal with the additional applications for STCs, but that if the number of applications increased in future, CASA may experience some resource pressure.45

2.43 Under Part 21-J01 v1.0 of the Regulations, CASA has the ability to approve organisations and people to carry out certification work on its behalf.46 According to CASA:

…the model of part 21 – to the maximum extent possible have experts and industry undertake those types of design and approval processes. In terms of our obligations as a regulator, there are some things that we will obviously need to continue to be involved in.47

2.44 In terms of the degree of work done on certification by approved organisations, CASA indicated the about 100 per cent of certifications for minor modifications and minor repairs is done by approved organisations. For more complex work, the certification work would be delegated on a case by case basis to either approved organisations or to CASA itself.48However, there is concern that CASA has not been adequately utilising this avenue for approvals and has been reducing the use of delegations, contributing to the time taken to obtain approvals.49Asked to quantify the number of approved design organisations, CASA said that two organisations have been approved, one is finalising its assessment, one is in the middle of its assessment and three are at the beginning of the process.50

2.45 CASA also advised that as a result of a review of Part 21–J01 of the Regulations, CASA was working with industry advisers to find a workable alternative for general aviation design approvals.51

2.46 The Committee notes that, given the degree of interest from Australian design bureau and manufacturers in obtaining relevant STCs, it will be important for CASA to ensure the STC process proceeds as smoothly and quickly as possible.

MTF...P2

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Peetwo - 12-12-2016

How to: Reconnecting with the real world of Aviation

Not that our mob (government & bureaucracy) want to hear but here is a simple 'how to' redefine our RRP and reform our presently big "R" regulator. Courtesy KC & the AMROBA clan Wink

Quote:2. The Role of CASA is not defined in Legislation

One of the major points that the Aviation Safety Regulatory Review identified was the Civil Aviation Safety Authority was functioning very different from its 10 counterparts that have a place at the ICAO Council. Member States listed in the Council’s Part 1 – States of chief importance in air transport are:Australia, Brazil, Canada, China, France, Germany, Italy, Japan, Russian Federation, United Kingdom and the United States.

The commonality of the other Part 1 members enabling Act, regulations, i.e. standards, that are aligned with the ICAO promulgated international standards and the international standards promulgated by the Federal Aviation Administration of the USA is very comparable, except for Australia. Our ancient Act that was developed in haste back in 1988, does not clearly define CASA’s role or government responsibility under the Convention.

After nearly 30 years, Australian aviation requirements have not been harmonised with these world leading aviation countries, let alone the minimum standards promulgated by ICAO.

Within ICAO, the 191 Member States and a number of global aviation organizations work together to develop international Standards and Recommended Practices (SARPs). These SARPs are the reference for states developing their national civil aviation regulations which are legally enforceable. This is an important aspect: ICAO SARPs are not legally binding by themselves, they form the basis of national regulations which have legal status.

In this way, civil aviation regulations are harmonised all over the world, with slight differences based on the actual implementation in national regulations. These local differences are then reported back to ICAO and published.

So, when the rest of the ICAO member States adopt the ICAO SARPs, do we create very unique and costly requirements that no other country adopts. The world is too small for non-standardisation.

The ICAO Safety Oversight Manual, Part A states:

2.4.8. The aviation industry has the overall responsibility for maintenance of safe, regular and efficient operations, for aviation personnel training and for the manufacture and maintenance of aircraft and aviation equipment.

 Some States may share some of the responsibility for monitoring internal safety standards with other organisations (air traffic and aerodrome service providers, operators, approved maintenance organisations, manufacturers, etc.) that have been found to be reliable and to and to act responsibility.

 The objective of a safe and orderly civil aviation system cannot be attained unless each designated member is prepared to readily accept the implications of policy, including committing the necessary resources to its implementation. Crucial to the confidence that the CAA may place in civil aviation certificate holders and the associated freedom and flexibility it can give is the establishment by the certificate holders of an adequate quality system which must be reviewed and approved by the CAA.

CASA’s predecessors had already shared responsibility with industry participants and were well advanced until inexperience management reversed a couple of generations of gaining confidence and sharing responsibilities. Changes in the last decade to modernise the FARs has seen the shared responsibilities that CASA’s predecessors had implemented to be promulgated in the FARs.

It is time to revert to the proper empowering of the industry participants as was in progress in the past pre CAA/CASA, by adopting the modernisation changes to the FARs.

MTF...P2

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Peetwo - 01-03-2017

A Mike Smith how to on ICAO SSP compliance - Wink

This is one more to add to the Mike Smith CV bid for the CASA CEO position... Wink

Courtesy of NAN via the BN:

Quote:Nigeria Climbs Up in Global Aviation Safety Rating
02.01.2017 at 7:37 pm By NAN Leave a Comment
The Nigerian Civil Aviation Authority (NCAA) on Monday said Nigeria had attained another high level safety rating which placed it among the world leaders in aviation safety.

The NCAA made the announcement in a statement by its General Manager, Public Relations, Sam Adurogboye in Lagos.

The statement stated that the country climbed to Level three State Safety Programme (SSP) Implementation Process, joining countries like the United States of America, United Kingdom and others in the echelon.

Quote:“This categorisation is dependent on the International Civil Aviation Organisation (ICAO), which tracks the SSP implementation process of member-states via its Integrated Safety Trend Analysis and Reporting System (iSTARS).
Member states in tandem, therefore, deploy this platform to undertake Gap Analysis, define their action plans and benchmark their progress.
Only two member states-Australia and Sri Lanka- have achieved full implementation of the SSP according to ICAO records.
Nigeria is striving to achieve Level Four, which is 100 per cent by the end 0f 2017,” it said.

According to the statement, the SSP process is inaugurated in member countries in compliance with the ICAO requirements as contained in Annex 19 on Safety Management.

The statement added that Nigeria’s advanced level had put its SSP implementation process among states that defined an action plan for all non-implemented Gap questions.
It said that Nigeria had completed its Gap Analysis, implemented 43.6 per cent of the required SSP tasks.

Quote:“In addition, the country has developed a detailed action plan for the accomplishment of the outstanding tasks with an established and approved timeline.
In pursuant to this, Nigeria has commenced the implementation of the SSP processes and has achieved several milestones.

These include the completion of the SSP Gap Analysis and the establishment of the Implementation Plan approved by the Director General-General (DG), NCAA.
Other completed SSP tasks are the official authorisation of the DG, NCAA as the Accountable Executive of the SSP and the designation of the NCAA as the Placeholder Organisation of the SSP in Nigeria by the Minister of State (Aviation), Sen. Hadi Sirika,” the statement added.

It said the approval and publication of the State Safety Policy Statement, the Enforcement Policy in an SSP-SMS environment, including Nigeria’s Voluntary and Confidential Reporting System, were among the tasks that have been concluded.

According to the statement, the ICAO Aviation Safety Plan (GASP) has recognised the relevance of establishing and maintaining fundamental safety oversight systems as a prerequisite to the full implementation of an SSP.

“Member-states with robust safety oversight system have been called upon to progress towards full implementation of SSP.

An SSP is an integrated set of regulations and activities aimed at improving aviation safety which will be monitored through Universal Safety Oversight Audit Programme (USOAP) and Continuous Monitoring Approach (CMA) after such a state has achieved an Effective Implementation (EI) of over 60 per cent.

It is required that states that have achieved EI levels of over 60 per cent should endeavour to fully implement SSP by 2019.

Nigeria achieved an EI Level of 67.36 per cent during the immediate past ICAO USOAP Audit in March 2016 which is above world average of 63.54 per cent”

It noted that with the achievement, the NCAA would continue to ensure that air transportation in Nigeria was seamless, safe and secure at all times.

It, therefore, urged airline operators to take advantage of the robust regulation and adhere to all safety regulations contained in the Nigeria Civil Aviation Regulations (Nig.CARs).

I reckon even miniscule DDDD_MNFI could join the dots on that one... Wink

MTF...P2

RE: Mount Non-compliance & upcoming ICAO/FAA audit? - Gobbledock - 01-03-2017

Good to see Nigeria banging away at their processes and jumping ahead of Australia in the safety compliance stakes!!

P2 said;

I reckon even miniscule DDDD_MNFI could join the dots on that one...

The only thing that NFI Chester would know about Nigeria is that; a) they produce fast male athletes with long doodles, and b) Chester was probably scammed by some telephone shonk promising him 10 wives and the Australian Prime Ministership if he quickly wired them $10k!!!