[Peetwo]

AIPA's got a point, but do we really need yet another review?   

Via aipa.org.au :

TIME TO REVIEW AUSTRALIA’S AVIATION SAFETY REGIME

29/03/2019 | Author: Mark Sedgwick

Whenever an airliner accident happens, pilots are constantly asked what they think about the cause and the circumstances. So it’s no surprise that Boeing’s current problems are prompting a lot of discussion.

Fortunately aviation incidents and accidents are rare. In fact, globally they are at historic lows.

According to the Flight Safety Foundation, in 2018 there was one fatal accident for every 2.52 million flights. That’s 15 fatal airliner accidents resulting in 556 fatalities worldwide.

By comparison, our national road toll statistics show that last year it is estimated that 1143 people died on Australian roads.

More than twice as many people died on our roads as were killed in major air accidents worldwide in 2018 and none of those were killed in Australian skies. 

The current level of global aviation safety has not come about by chance. As pilots, we continually strive to be alert for potential errors, to minimise mistakes and eliminate accidents.

The recent accidents involving two new Boeing 737 Max aircraft have focused public attention and concern on how this can happen today, after decades of consistently falling accident rates.

Improvements in safety systems, technology, engine reliability and training for everyone involved in aviation has led to ever increasing improvements in safety margins.

So what needs to be done to further reduce these statistics? Painstaking investigations into these accidents will piece together every detail of the sequence of events that led up to the accident.

Investigators will work to establish where the normal checks and balances designed to prevent such accidents broke down.
But there are important questions which also need to be asked about regulation and oversight, following the 737 Max accidents, in the US and elsewhere.

Following the tragic loss of the Ethiopian Airlines aircraft last month, regulators around the world grounded the 737 Max.
Notably, the US Federal Aviation Administration (FAA) was one of the last to move. Australia’s Civil Aviation Safety Authority (CASA) was among the first.

The FAA, which oversees the regulation of aviation in the US, also has another role, to encourage and develop civil aeronautics, including new aviation technology. There is an inherent conflict between safety regulation and encouraging economic development, which may well have influenced the FAA’s oversight and certification of the 737 Max.

In the US there is now growing concern that the FAA has grown is too close to Boeing and too trusting of the aircraft maker’s internal processes.

It is a matter of concern that the FAA, at a time when the regulator has lost staff and had its resources reduced, may have relied to heavily on Boeing employees to approve the design of the B737 Max.

It should be stressed that these investigations are not yet complete. As pilots, we would reserve judgment on such things until we are more fully informed.

There is no doubt however that aviation regulatory bodies should not become too close to the commercial interests they are supposed to monitor, whether they are airlines, manufacturers or other players in the aviation industry.

In Australia this means our regulator should also be operating at arms-length from commercial entities.

Recently, an amendment was proposed to the Australian Civil Aviation Act to: “consider the economic and cost impact on individuals, businesses and community of the standards.”

However, more oversight of the industry rather than less will be needed should the regulator’s focus on safety be given an overt commercial axis to consider.

The second part of the amendment says: “[CASA must] take into account the differing risks associated with different industry sectors”.

So what will this mean for how CASA assesses the economic impact of safety regulations and policy on larger airlines?

If major airlines are thought to be less risky then do they require less oversight in balancing commercial imperatives versus safety outcomes? Or should CASA have more resources to support this new approach to aviation safety.

One glaring omission from the current Australian safety framework is the absence of operational pilots on the Aviation Safety Advisory Panel that provides CASA with informed, objective advice on current, emerging and potential issues that have, or may have, significant implications for aviation safety.

In recent times, the only pilots sitting on the panel have been representatives of airline and aviation industry management, not operational pilots who are an integral part of aviation safety.

In the light of what we are seeing overseas, it’s time to review this position and appoint independent pilot representatives to the panel that directly advises CASA.

Working pilots are best placed to understand the impacts of policy and regulation on operations and on safety outcomes.
By choosing independent representatives we can ensure that the balance on aviation oversight and policy is maintained.

Now consider this from our former (maybe soon to be current) miniscule for non-aviation: ref - Aviation in Election 2019: 'Dead buried and cremated' - The MOAS strikes again. 

Former miniscule for Non-Aviation Albo the Great White Whale: ...For some in the aviation sector, this bill won't go far enough, and I accept that. But it does take an important step in the right direction. It's a sign of progress in an area where any change must be carefully considered, and that's why it has been the subject of broad support across the sector. For example, Regional Air Express, the airline that services much of regional Australia said in a statement:


"..Regional Express (Rex) welcomes the proposed amendment to the Civil Aviation Act 1998 which requires the Civil Aviation Safety Authority (CASA) to consider the economic and cost impact, in the development and promulgation of aviation safety standards, on individuals, businesses and the community and to take into account the differing risks associated with different aviation sectors..."

In closing, I thank the minister for his cooperation on this issue. The job of transport minister is a difficult one. I hope to be able to experience that again the next time this parliament sits. But, in government or opposition, I would say that I want to work with my counterpart when it comes to transport issues and, in particular, when it comes to aviation safety. That's why we've agreed on just one speaker a side in order to fast-track the passage of this legislation so it can get to the Senate. I commend the legislation to the House. 

Does AIPA seriously think that anything is going to change while pollywaffles of both major parties continue to drink from the Can'tberra MOAS Koolaid fountain? - FDS...



Meanwhile in the real world on the coalface: ref - Mr John Hancox (PDF 44 KB) 

To the Senators

Firstly, I would like to thank you for creating the opportunity to submit my views and real examples of the failings of
Airservices Australia.

I believe That AS is focused on only meeting minimum requirements.

Operational staff have watched with genuine interest the Senate estimates questioning of ARFFS. Staff are as
frustrated as the Senate with the responses to questions and the continued “smoke and mirrors” approach AS
management have taken.
I’m approaching 37 years’ service and haven’t seen AS management this arrogant and deceptive to the real issues.
AS management continue to provide a facade that all is fine, which on face value appears to be the case, however
once you go beyond the shiny brochures and delve into their processes and systems you find gross negligence.

There exists a disconnect between AS management and front-line staff. The business/ARFFS focuses on minimum
requirements which is deemed adequate. How this aligns with AS priorities, strategies or values is questionable.
This corporate mindset compromises operational staff whom never see outcomes delivered for capability and/or
safety. The Government Service Delivery Capability Model surely is not being met in its’ format or intent.

The lack of accountability and reduction in standards clearly identifies a compromised relationship between current
AS management and CASA.
The statements made to the Senate at various times are quite laughable if they weren’t so serious. AS managers
either don’t know the correct answers which they should, or they don’t want to tell the truth.
The statement made to Senate that” changes aren’t budget driven” is quite remarkable. This raises the question
why AS Management won’t tell Senate the real situation, examples below provide an insight.

1. Push for change of threshold for ARFFS to 500 thousand movements: AS were struggling with growth and needed
to stop new stations opening. Hoping to create freeing up of assets particularly fire vehicles and staff. There was no
other plan and the delays to projects and working group findings will now bite the ARFF due to lack of forward
planning. Vehicles remain a concern due to no action being taken in a timely manner. Vehicle 5 replacement
program has been recently reviewed after being shelved for five years from the initial report (have a hard copy of
original report). Nothing has changed. There is still a need to create capacity first for various reasons (particularly at
category nine and ten) then start to replace the rest of fleet in future budgets. The fact ARFF brought the MK7
vehicle back into service when was moth-balled and still haven’t organised replacements against these vehicles
shows something is wrong. A new vehicle takes around two years to get into service from signing of contract; hence
you must be in front of the game very early.

2. Station new builds and renovations have become embarrassing. The cost blowout is common place. Futureproofing
with operational focus isn’t happening correctly. Brisbane’s renovations went from $2.8 million to around
$5.2 million. Brisbane’s new station for the new runway has many issues- recently it was discovered the fire access
road from the station has been removed. Concept of Operations raised many issues which still haven’t been
addressed, as the desk-top scenarios were with old category ten staffing and not the new cross-crewing model. The
positioning of the Fire Station has been debated by operational staff with the project team since day one of project
and continues to fall on deaf ears.

3. Safety critical issues remain caught up in AS systems with fixes not completed in timely manner. Darwin incident is
an example of fixes not being carried out; even when the inquiry states AS were remorseful and Comcare had a PIN.
The DSU paperwork is a good example of a safety issue not being completed and worse still CASA being part of the
failings. Current vehicle safety issues have not been completed with a paper trail over years.

There are many more examples that, if needed, I would be happy to provide or clarify further if requested.

I have tried to keep my submission simple and have used examples that should quickly show what the Senate was
being told hasn’t been factual. I have left CASA failings and examples out of my submission; however, they are a
large part of the current problems and must change to be a real regulator with up to date standards for AS/ARFF to
go forward. CASA standards are well overdue for a full review and rewrite to bring things in line with current
international standards and recommendations.

Thanks again for the opportunity to provide my submission and I am happy to provide further details by any means.

Regards


John Hancox

LAFF. Brisbane

MTF...P2