[Peetwo]

Chasing tales and washing spots - Part II

From the latest word weasel confection from Carmody Capers... :

---

CC said: "...Everyone in aviation can be proud of the new top six safety ranking given to Australia by the International Civil Aviation Organization. The ranking follows the latest International Civil Aviation Organization audit of Australia's aviation safety system, carried out in late 2017. The audit delivered a 95 per cent safety oversight score, which we must now work to maintain. This means Australia currently ranks sixth out of International Civil Aviation Organization member states for effective safety oversight. The International Civil Aviation Organization assesses a nation's safety oversight capabilities by looking at aviation legislation, licensing, operations, civil aviation organisational structures, air navigation and accident investigation. The high ranking demonstrates Australia has a robust aviation safety system supported by public sector agencies with a deep commitment to achieving the best possible safety outcomes. Credit for the ranking also goes to the commitment to safety by the people and organisations who make up Australia's aviation community. It is your day-to-day work, delivering safety during every flight and every aviation activity, that makes Australian skies amongst the safest in the world. Naturally, I am proud of the role the CASA has played in lifting Australia's safety ranking and I thank all staff for their contribution. Tribute also goes to the contributions and efforts of the Department of Infrastructure, Regional Development and Cities, Airservices Australia, the Australian Transport Safety Bureau, the Australia Maritime Safety Authority and the Bureau of Meteorology.

Get more information on the International Civil Aviation Organization's Universal Safety Oversight Audit Programme. ..."

---

Now this makes sense of the 'out of the blue' bollocks propaganda piece from Creedy: Reference - On chasing tales and washing spots

...Australia’s aviation system has been judged one of the world’s safest after an International Civil Aviation Organisation (ICAO) audit ranked it sixth among member states for safety oversight.


The UN-Backed organization audited Australia in 2017 on a range of issues including operations, airworthiness, accident investigations and air navigation services. It gave the nation a safety oversight score of 95 percent, according to the Civil Aviation Safety Authority...

---

...I wonder how much that ICAO rubberstamp 'bollocks' cost us? Not to mention the cost to HVH in wining, dining (plus extra curricular activities), while pulling the wool over the eyes of ICAO (wet lettuce) Thor in the course of his wanderings through the Halls of AAI top-cover experts the ATSB : Mount NCN post #106

Got a feeling my next Aunty task will be to systematically pull apart that complete and utter load of BOLLOCKS -

In the meantime here is a challenge for CC, given our stellar standing in the world of aviation safety administration can we now request that the FAA IASA team come back and doubly reassure the members of the A4ANZ that we are in the stratosphere of Category 1 member States? Come on CC, money where your mouth is mate!!  

Depicted in the Creedy puff piece was this graph of the EI 'effective implementation' of ICAO standards by Australia compared to the global average (below): 


This information was extracted from this interactive ICAO webpage: https://www.icao.int/safety/Pages/USOAP-Results.aspx

Next referring to this comment from CC: "...I am proud of the role the CASA has played in lifting Australia's safety ranking..."

Now if we rewind to this 1/11/2016 Mount NCN thread - Q/ Has the Forsyth ASRR panel been deceived? - you will see that I had copied & pasted the Australian EI graph for 2016:

The average % total for 2016 was 93.65%. Based on the Creedy copied graph this compares  to 93.99% for 2018. If CC believes that a .34 % point lift in Australia's safety ranking is something to be proud of, then I've got a cheap bridge in Sydney Harbour he may be interested in purchasing...

However to be fair to CC (or not - ) when you read the blurb on the ICAO adopted USOAP CMA it becomes obvious that the EI graph is constantly being updated as an individual State reviews or updates and self-assesses through SAAQs, EFOD, CAPs (ref pg 1) and PQs (pg 2):    

---

The USOAP CMA has four components integral to the
continuous monitoring by ICAO of the safety oversight
capabilities of its Member States.

To wit:

1) Safety information is collected through
Member States and various internal and external
stakeholders.

2) This information is analyzed to determine the
safety risk profile of each State.

3) Based on the risk profile, ICAO selects and
prioritizes the States which will receive
corresponding USOAP CMA activities.

4) The results of the USOAP activities lead to
updates of the Effective Implementation (EI)
value of the States on the USOAP CMA online
framework.

---

IMO, despite the CC waffle, this in effect means that the current EI scores are irrelevant to the actual ICAO audit results. This also means that the actual audit report, with the associated recommendations/RCAs, are yet to be released for the State SSP to properly assess and then construct a corrective action plan (CAP).

But don't let me get in the way of the telling of the Carmody Capers fairytale...

Finally another quote from page 2 of the ICAO USOAP CMA flyer:

---

2) Verify the status of the States’ implementation of:

a) Safety-related ICAO Standards and
Recommended Practices (SARPs);

---

This brings me back to this part of my (yet to be replied to -   ) Dear Lachie email/post:

You said:

 
 “…For comments on filing of differences, as per Article 38 of the Convention on International Civil Aviation (the Chicago Convention), of which Australia is a signatory, we file a range of differences with ICAO. Airservices Australia regularly publish these in the Aeronautical Information Publication available on their website.  Australia takes a proactive and conservative approach, updating its differences often and reporting any point of difference to allow operators the information they need to conduct safe operations. 

Due the subjective nature of filing differences, the comparison of numbers of differences is not regularly used as a measure.  State’s safety oversight arrangements at ICAO are benchmarked through an assessment process leading to an effective implementation score.  Australia was assessed in October 2017 by ICAO auditors and while the results are yet to be made public it places Australia in the top 10 States for safety oversight compliance…”  

Comment: I am fully cognisant of the Airservices AIRAC publication but disagree with some of the premises and assumptions that you make in the above paragraphs.
 
To begin here is the link for the latest ASA notified differences AIRAC: http://www.airservicesaustralia.com/aip/...7-h136.pdf
 
I guess it could be argued that the AIP SUP does allow operators the information they need to conduct safe operations ?? However whether that information can be easily disseminated when you consider the many 100s of pages and thousands of notified differences that AIP SUP links to is an entirely different matter.
 
In comparison please refer to the five pages of GEN 1.7 of the Singaporean CAAS AIP:  https://www.caas.gov.sg/docs/default-sou...1feb18.pdf
 
The following is a quote from the KC_ICAO_1 PDF (see above or attached) which we believe summarises why it is that we have such a huge number of notified differences to ICAO and why we think this is a significant safety issue concern:
 
“.. In general, it must be stated that the Australian Civil Aviation Safety Authority (CASA) has an unique approach to ICAO compliance, with record number of ‘notified differences’. Many of the notifications may, at face value, seem insignificant. It is our opinion that the noted differences are structured to support the complex, contradictory, flawed rule set in place. Reform of this rule set has been in train for thirty years, with successive government ministers and directors of civil aviation promising to complete the task ‘within the next three years’. This is an important consideration as it reflects on the operational approach taken to both open reporting of ‘incident’ or event; and, the tangible fear of prosecution. Australia’s Civil Aviation Regulation (CAR) are founded on the ‘criminal code’ and ‘strict liability’; this, standing alone, provides a strong disincentive to openly reporting safety related matters. This attitude is reflected in the government safety bodies approach to ICAO compliance and reporting…”
 
PAIN understands that the department policy is to place very little importance on notified differences being a ‘measure’ on aviation safety standards of ICAO signatory States.
 
Reference: 1.2 Supplementary to submission 1 (PDF 60 KB) 
 

---

Did the Department of Infrastructure and Regional Development collate and analyse the differences lodged with the ICAO by Serbia and Vanuatu when their respective Memoranda of Understanding and proposed Air Services Agreements were being negotiated?
 
No. Air services arrangements provide an economic framework in which airlines can consider serving a market. Differences lodged by States, among other more pertinent kinds of safety-related information, may be taken into account by the Civil Aviation Safety Authority in the assessment of applications for the operation of foreign aircraft into and out of Australia.
 
Regards
Gilon Smith
Director (a/g), Air Services Negotiations
Department of Infrastructure and Regional Development
gilon.smith@infrastructure.gov.au Ph: 02 6274 6634

 
However the above departmental answer to the QON would seem to have been contradicted in the other supplemental submission:  1.1 Supplementary to submission 1 (PDF 78 KB) 
 
“..The process of notification of differences provides a structured way for each State to communicate its aviation rules by measuring itself against the neutral framework of the ICAO standards…”
 

---

Q/ Given this conflict in interpretation of notified differences as a ‘measuring’ stick of aviation standards and the fact that the department was obviously responsible for creating the Serbia/Vanuatu/Australia 10696 notified differences table, for the benefit of the Senate RRAT committee and industry stakeholders, would it not be possible for the department to collate a similar table for say the top 50 ICAO signatory States?
 
Q/ For the benefit of the committee would it be possible (in camera if required) for the department to forward the:
 
a/ 2017 ICAO audit report of the ATSB;
b/ The 2009 FAA IASA audit report of the CASA;
c/ The 7 December 2009 CASA Board minutes;


Finally, considering the positive feedback the department has received from ICAO’s October 2017 audit, would it be possible for the committee to view that report prior to it’s public release? Would it also be possible for the department to suggest that CASA invite the FAA IASA auditors back to audit and compare whether all the 2009 FAA IASA audit findings have been properly and proactively addressed? 

Hmm...(CC & Lachie - ) it is passing strange how the ICAO USOAP CMA system would appear to place significant weight on the importance of an individual State's EI and compliance with the ICAO SARPs as a measure of aviation safety standards...


MTF...P2