[Peetwo]

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

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...

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. 

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&..

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:

The Panel recommends that:

1. 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.
   
   
2. 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): 

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):

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:

1. the legislative framework
   
2. safety oversight arrangements
   
3. SMS requirements for service providers
   
4. performance indicators for improvement in areas of safety concerns
   
5. accident and incident investigation management
   
6. 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):

 ..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:  

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':

...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.

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...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... - Yep thought so...
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:

...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...
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!
MTF...P2