Submission #54.
Is indeed a good submission. Once again the highlighting the end result of what is a seriously flawed system.
However, whilst we can see 'result'; the path taken, which allowed that result is IMO not clearly defined, nor does it illuminate the radical elements which allow the great liberties taken in 'operational management' of a flying operation.
A simple, yet clearly defined administrative interference with an operational control safety system may be found in any company library – the 'Operations Manual'.
When the administration seeks to control every aspect of an operation, rather than defining the 'sector risk' matrix and allowing the industry experts to manage those risk elements, the administration involves itself in the minutiae – down to insisting spelling errors be corrected before any form of approval is granted. The purpose of the humble operations manual is to define how compliance and risk management is to be achieved. It is not a document writ specifically for the benefit of the prosecution, And yet it often is turned into such – the dictates of the administrator must be satisfied before approval or acceptance is granted.
There are countless examples where the administration has actively interfered with or influenced company operational tenets; which would be acceptable – provided that should there be a breach or accident, all those, including the administrator were held to account; and, corrections were put put in place to prevent recurrence. A better, safer result is much more desirable than fines, loss of operational approval, or even goal for the operator. Micro management, without responsibility and the endless cycle of 'satisfying' the demands of the administration provide nothing of value to anything other than the safe conviction of those alleged to have committed an offence.
Stand alone 'Sector Risk' analysis removes many of the administrative 'traps'. Allowing the 'experts' in any sector to 'manage' their own risks, without administrative interference would mop up many of the grey areas surrounding operational control and risk assessment. In short, the administration should set the boundaries and leave operational matters to those who know and understand the risk factors. As it stands – CASA have total control of operations but accept no responsibility for their part in demanding a 'preferred method of compliance' – their procedure or process incorporated into a manual which then is cited as part of an accident or incident event. See Ross Air or Pel-Air for ready reference.
“He can switch from one view to another with frightening ease. I think it is a sign of being accustomed to such power that the truth does not matter because you cannot be contradicted.”
Toot – toot.
Is indeed a good submission. Once again the highlighting the end result of what is a seriously flawed system.
However, whilst we can see 'result'; the path taken, which allowed that result is IMO not clearly defined, nor does it illuminate the radical elements which allow the great liberties taken in 'operational management' of a flying operation.
A simple, yet clearly defined administrative interference with an operational control safety system may be found in any company library – the 'Operations Manual'.
When the administration seeks to control every aspect of an operation, rather than defining the 'sector risk' matrix and allowing the industry experts to manage those risk elements, the administration involves itself in the minutiae – down to insisting spelling errors be corrected before any form of approval is granted. The purpose of the humble operations manual is to define how compliance and risk management is to be achieved. It is not a document writ specifically for the benefit of the prosecution, And yet it often is turned into such – the dictates of the administrator must be satisfied before approval or acceptance is granted.
There are countless examples where the administration has actively interfered with or influenced company operational tenets; which would be acceptable – provided that should there be a breach or accident, all those, including the administrator were held to account; and, corrections were put put in place to prevent recurrence. A better, safer result is much more desirable than fines, loss of operational approval, or even goal for the operator. Micro management, without responsibility and the endless cycle of 'satisfying' the demands of the administration provide nothing of value to anything other than the safe conviction of those alleged to have committed an offence.
Stand alone 'Sector Risk' analysis removes many of the administrative 'traps'. Allowing the 'experts' in any sector to 'manage' their own risks, without administrative interference would mop up many of the grey areas surrounding operational control and risk assessment. In short, the administration should set the boundaries and leave operational matters to those who know and understand the risk factors. As it stands – CASA have total control of operations but accept no responsibility for their part in demanding a 'preferred method of compliance' – their procedure or process incorporated into a manual which then is cited as part of an accident or incident event. See Ross Air or Pel-Air for ready reference.
“He can switch from one view to another with frightening ease. I think it is a sign of being accustomed to such power that the truth does not matter because you cannot be contradicted.”
Toot – toot.