[Peetwo]

FRMS and St Commode's history of pilot association embuggerance?? - 

For the benefit (HINT) of the EAL (Editor At Large) -   

Reference:

No interim report? Plus St Commode's last 'up yours' Senators?

Also from the 'Additional Documents' webpage possibly (hopefully) the last 'spin and bollocks' correspondence to the committee from the much maligned St Commode (note that this was posted weeks after the 20 November public hearing - ??? )...  :

---

---

Well we know where the committee concern emanated from don't we?  

From the AFAP 20/20 submission 44:

Composition of the Aviation Safety Advisory Panel

62. The Aviation Safety Advisory Panel (ASAP) is the primary advisory body through which CASA
directs its engagement with industry and seeks input on current and future regulatory and
associated policy approaches. The ASAP has never had a representative on it from a member
based association.

63. Professional pilots are a unique group of aviation stakeholdersin that the result of nearly all safety decisions flow through the aviation system to us. We, as an association of professional pilot
representatives, are uniquely able to observe and collate where consistencies and deficiencies
collect in the aviation system. Other front line professionals may also be able to do the same
however professional pilots, more so than others, receive the outcomes of these other groups,
and are at the final point of control in the aviation decision making process. The AFAP is the key
representative organisation for GA pilots and would be best placed to contribute to the ASAP.

64. A consultative panel in the medical sector for example, similar in purpose to that of the ASAP,
would not exclude doctors. Yet in aviation, the voice of professional pilots is not welcomed by
CASA in the ASAP.

And from the AIPA submission 28:

Aviation Safety Advisory Panel

Earlier, we referred to the ASAP in the context of getting the regulatory balance right.
The ASAP20 was formed as a consequence of the recommendation of the ASRR to
review the SCC as the previous consultative mechanism. The ToRs for the ASAP
state, inter alia:

The purpose of the Aviation Safety Advisory Panel (ASAP) is to provide the
CEO/Director of Aviation Safety (DAS) with informed, objective high-level advice
from the aviation community on current, emerging and potential issues that have,
or may have, significant implications for aviation safety and the way the Civil
Aviation Safety Authority (CASA) performs its functions

While the purpose is laudable and, in AIPA’s view, most desirable, we have had
concerns about the implementation of the process since it was first proposed.

The AusALPA member associations found the report of the SCC Working Group on
this new consultative process particularly vexing. In May 2016, AusALPA wrote to the
then-DAS and advised him, in part:

We note that, to a surprising extent, it is blatantly self-serving in regard to the
influence of the Working Group members and, consequently, contains some
fundamental flaws.

In particular, AusALPA is concerned that the proposed DAS Advisory Panel
represents a particularly unbalanced concentration of advice.

We strongly recommend that you include our Association as a full member of your
chosen advisory mechanism, noting that full membership appropriately reflects
both our consistent safety and technical contributions and the true characteristics
of membership of both the recommended ASTRA and FAA advisory models.

Given the wider publication of the Working Group advice, AusALPA believes that it
is important to correct some key factual errors and selective research, as well as to
note the unjustified but apparently philosophical bias against workforce
representative associations demonstrated by a number of the Working Group
members.

This latter sentiment often arises in our dealings with government on aviation matters,
particularly among those who are intellectually incapable or unwilling to accept that
representative bodies such as our member associations operate quite separately in the
safety and industrial arenas.

Continuing refusal to engage with Australia’s pilots is a matter that must be addressed,
since we remain a valuable source of independent, experienced and unbiased safety
advice.

Our engagement with the Parliament, through this and other Committees, and
executive government on matters of aviation safety is not as industrial forums and
never has been. Critically, AusALPA has no legal standing or role in any Federal or
State industrial framework. Ironically, the often preferred source of advice is from
those in the commercial sector who act unashamedly in their own best interests,
particularly in the industrial arena. In that context, the key point we made to the then-
DAS was:

Importantly, we think it is critical that you recognise that the proposed membership
of your advisory group are all representatives with vested commercial and
economic interests whose safety activities are rarely characterised as timely, let
alone proactive, and therefore lacks balance. In particular, you should be very alert
to the fact that management representatives of operators do not, and cannot,
represent the views of their pilot workforces – that is the very reason that both
IATA21 and IFALPA co-exist.

Subsequently, the then-DAS invited AusALPA to be a full member of the DAP.
However, in reforming the DAP as the ASAP, the current DAS has reverted to
excluding the policy advice of Australia’s professional pilots. Despite several ASAP
renewal opportunities, the current DAS has ensured that the ASAP is entirely
populated with vested commercial interests. This is consistent with his entrenched
aversion to associations such as ours and despite our singular focus on safety and
technical matters. In the absence of the informed input from pilots who actually fly the
aircraft and conduct the operations that CASA is regulating, the ASAP is predominantly
an special interest economic rather than safety advisory panel.

AIPA suggests that it would be most appropriate for the Committee to consider making
a recommendation that the Government should seek more balanced advice, both for
the Minister and for the DAS, on aviation safety policy. There can be no balance when
the voice of the last line of defence, Australia’s pilots, is suppressed.

To give some historical context to the apparent animosity, disdain and disregard that St Commode and the Iron Ring have for the professional pilot associations please to following archived AP posts...

FAA IASA audit, FRMS & an 'inconvenient ditching'?

FRMS & the timeline of regulatory embuggerance 

https://auntypru.com/the-return-of-the-s...-assassin/

https://www.aipa.org.au/media/1118/13-11...ao-481.pdf

Our Concerns

Part 48 of the Civil Aviation Orders was produced in the 1950s. There have been few
amendments since. The provisions are not based on science. The empirical basis of Part 48
led to some unsafe outcomes, the most obvious example of which are the provisions for
augmented crews, i.e., the addition of a third pilot to allow long range international operations
across many time zones. These rules will survive until December 2016.

Around 1990, an attempt was made to make CAO Part 48 more flexible to meet the demands of
the operators. Standard Industry Exemptions (SIEs) were invented that, while modelled on a
semi-scientific British system, ignored such science as was available and in many scenarios
produced even more unsafe outcomes than did Part 48. These SIEs will also survive until
December 2016.

AIPA acknowledges that the new rules, Civil Aviation Order 48.1 Instrument 2013 (the
“Instrument”) are, in many ways, a significant improvement on the previous rules. However,
they still allow certain operations that reflect the commercial bias embedded in the SIEs rather
than the science.

Fatigue risk is regulated because the world-wide experience is that the commercial interest of
operators will trade off a high risk of a fatigue-related accident for a short term commercial
advantage. Australia is no different and the clear evidence has been identified by the
Parliament on several occasions.

AIPA is a fervent supporter of FRMS. We applaud the introduction by CASA of “operator
obligations” as a means to impose some FRMS processes on those operators who choose to
operate only under the prescriptive rules set out in the Instrument. But we are concerned by
two aspects of the Instrument:

• The lack of transparency about what CASA will accept under an “approved FRMS”; and
• The prescriptive rules that will inevitably form the basis of the FRMS rule sets.

Hmmm...more to follow me thinks? P2