[Peetwo]

Joining dots, making dashes on Aussie SSP??? -   

Ferryman: "..The Senate XI have not, as yet, used the powerful SSP as a means of winning the championship; not too much opposition so far to test it against - but despite it's 'wet lettuce' appearance; it is a handy tool - if needed (hint)..."

PAIN/IOS audit of Australia's SSP (ICAO Annex 19) 

Before we get started note that of the original ICAO eight critical elements of a USOAP Safety Audit, 'Accident Investigation' has I believe taken over the previously listed 'resolution of safety concerns' critical element. The reason ICAO have changed the element reflects the introduction (2012) of Annex 19 and the importance ICAO places on the State AAI, according to Annex 13, to the integrity and compliance of an effective State Safety Program (SSP). 

vs

Over on the Estimates thread "K" has finished commentating (for now) on the SSP Cup - The State Safety Program cup – Round one. This commentary has brought about a fascinating situation where Harfwit has unwittingly (no surprises there ) provided a perfect test case to review the effectiveness and veracity of Murky's newly minted, ICAO Annex 19 defined, State Safety Program.  

To begin, Chapter 3, section 3.2 of Murky's SSP sets out the guidelines and risk mitigation strategies intended to be put in place to ensure the integrity and effectiveness of the SSP:

..Safety performance measurement and monitoring are the means by which the safety performance of the aviation system is described and evaluated. Through analysis of safety data and information, areas of emerging risk can be highlighted and this information used to inform decisions regarding making appropriate safety interventions and the subsequent assessment of effectiveness of those interventions.

A number of high-level safety performance (Tier1) indicators have been identified as markers for monitoring the State's aviation safety performance. These indicators consist of measures of adverse safety outcomes (accidents and fatal accidents) according to operational sector and relative to the level of activity within that sector (exposure)...

All basic meat & potatoes for checks & balances of an SMS. However that is where it suddenly diverges from the 'tried & true' to the bizarre world of bureaucratic academia and legal weasels:

..Recognising the limited ability of these indicators to aid in the proactive identification of emerging risks, CASA has expanded on this set of indicators.


CASA has adopted a tiered approach to the development of indicators to describe safety at three different levels within the aviation system (refer Figure 2).

This approach allows CASA to capture the role of, and relationship between, the activities of the authorisation holder and the regulator in contributing to adverse safety outcomes. It also provides greater insight into the nature of those conditions that underlie potential adverse safety outcomes.

Safety Performance Indicators (Tier1, 2 and 3) are being developed to align with the key risk areas for CASA and the different sectors of the aviation industry...

 
Saving the best to last (as referred to above), Figure 2 is a true work of art in spin and bureaucratic obfuscation:

 (P2 - Somewhat strangely, there are some remarkable similarities to the Dr 'Ghost-Who-Walks' beyond Reason thought bubble diagram, for why the Lockhart River tragedy occurred)
WTD??   

 Fortunately, after that load of bollocks, Murky does bring us back to ICAO Annex 19 ToRs, although the part in bold red is very questionable at this point in time:

Acceptable Level of Safety Performance (ALoSP)


An ALoSP requires the State to consider the effectiveness of the following four components:

• the State's implementation of the SSP;
  
• service providers’ implementation of SMS;
  
• the management of aviation safety risk and associated Safety Performance Indicators; and
  
• implementation of ICAO SARPs by the State.
  

Australia examines each of these elements through its aviation safety system.

Universal Safety Oversight Audit Programme Continuous monitoring approach


Australia undertakes a systematic, coordinated national approach to managing aviation safety.

The results of the last ICAO Universal Safety Oversight Audit Programme (USOAP) review of Australia's safety system, in 2008 support this. Since the 2008 audit, the USOAP has evolved to a Continuous Monitoring Approach programme.

Australia's full USOAP report, including updates on Australia's corrective action plan, is available from ICAO's public website.

  
Personally I can think of much documented evidence that would refute that Australia, 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.)

However the one effectiveness indicating component we're interested examining in finer detail is bullet point two: service providers’ implementation of SMS;

Which brings me back to some references I provided for "K" in his Senate Estimates SSP cup posts:

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. 
Also included in SSP para 2.2 is a short paragraph outlining CASA's oversight obligations of a State service provider's SMS:

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.) 

All of which provides another opportunity to argue the case for the Rev Forsyth to review the implementation progress of the ASRR:  

Time for the Rev Forsyth to review the review

In particular:

Ps Very soon PAIN & associates will be continuing with the SSP (ICAO Annex 19) review and how it relates to the so called Department action on ASRR recommendations 1 & 2: References -

PAIN/IOS audit of Australia's SSP (ICAO Annex 19) 

Report of the Aviation Safety Regulation Review PDF: 1598 KB

Just saying and standing by for incoming -

MTF...P2