[Peetwo]

 
SSP test case No1. - Harfwit's accelerate (me) program.

Yesterday the QON index was released and within the QON there was a large component to ASA addressing issues such as the ANAO OneSKY audit(s) and Harfwit's 'accelerate' sacking program. The answers to these QON will be very relevant to the next BRB SMS committee,  which has recently been tasked with reviewing the ASA debacle as a test safety case for Murky's newly minted SSP...  

The BRB review will also assess whether Murky's department has considered the concerns of industry groups that were consulted on the original DRAFT of the SSP; or as is normally the case did M&M and his minions merely pay lip-service to those Alphabet groups concerns.

BRB example references RAAA submission:

II. RAAA Response to the Draft State Safety Programme

The Regional Aviation Association of Australia (RAAA) finds no significant issues with the Policy Statement as it is written. However we have serious concerns about the delta between the proposed situation and reality. The RAAA can cite numerous examples, but recognise most should be addressed in a separate forum to this submission. Therefore this submission will only identify high level concerns.

Policy statement paragraphs 3 and 9 claim that sound assessment of risks and service provider’s safety performance indicators are used to guide the regulatory development approach.

Just one example of where this policy is not applied is in the philosophical design approach to Civil Aviation Order 48.1. The current version is out of step with sound assessment of the actual risk faced by many mature Australian operators, and not based on empirical evidence in the Australian context.

Policy statement paragraph 6 claims that recognition of Australia’s safety regulatory system will ensure that Australia has a competitive aviation industry.

An increased focus is required in this area. Particular emphasis should be given to Bilateral Agreements with international service providers, particularly in the aviation maintenance sphere. The industry has agreed with the international harmonisation route on the basis that our regulations would be recognised and Australian operators could enjoy the associated obvious benefits. However the efforts and results from CASA in this regard are disappointing to date, despite numerous and costly investments in international face to face meetings.

Policy statement paragraph 10 claims that the appropriate personnel will be appointed to discharge their responsibilities competently.

Whilst sufficient financial and human resources have been allocated within areas of CASA, certain staff do not have the proper technical, people management, financial skills or appropriate industry experience to discharge their safety oversight and management responsibilities competently.

One final issue of significance that must be documented at this time is the disappointing lack of progress on the implementation of the Aviation Safety Regulation Review (ASRR). Page 8 of the draft State Safety Programme refers to the ‘Aviation Policy Group (APG) monitoring the progress of the delivery of the SSP and the SSP gives effect to the Aviation Safety Regulatory Review (ASRR) recommendations’. The RAAA has serious concerns on the lack of progress and the lack of visibility and surety that the policy intent of the recommendations has been correctly understood by CASA. A Post Implementation Review by mid-year to ensure the correct application is required.

III. CONCLUSION

The RAAA is grateful for the opportunity to provide our views for the Department of Infrastructure and Regional Development’s Draft State Safety Programme. If you would like further information about the items contained in this submission, or clarification on any of the points we make, the RAAA would be more than happy to assist.

  
AAAA SSP DRAFT submission:

In summary, AAAA’s primary concerns are:
 The document does not establish or recognise a partnership with industry that
underpins the program and the effective delivery of aviation safety.
 There is no recognition of consultative or other structures that might provide
industry with a clear role or pathway in assisting government and its agencies in
improving aviation safety or the SSP, or how industry can interact with or make
inputs to APG / AIG etc.
 While AAAA understands the various requirements for ICAO compliance that
drive the content and structure of the SSP, it should also be viewed as a key and
long-lasting document that will help drive domestic aviation policy settings as
well as international compliance.
 There remains a ‘delink’ between the very worthy principles espoused under the
Policy Statement - which AAAA supports - and their non-implementation by
agencies - especially CASA.
 The welcome attempt by the SSP to embed risk management as a key
consideration for regulation is hollow when compared to CASA regulatory
outcomes. AAAA strongly endorses CASA DAS Directive 01/15 - but it is not
being applied to recently introduced, problematic regulations such as CASR Part
61 or CAO 48.1. The CASA approach is still not risk-based and is still not
informed by a coherent classification of operations philosophy that gives the
highest priority to passenger carrying operations.
In particular, the application of a classification of operations policy that results in a
strong focus on passenger carrying operations, thereby permitting more creative -
even safer - approaches to the regulation of general aviation and private
operations, has not been in place for at least 10 years, and CASA continues to
struggle with the practical implementation of such a policy. Clearer details on
how this is proposed to be turned from a broad policy statement in the SSP into
practical actions by agencies would be welcome.
 There is a ‘delink’ between the Policy Statement regarding ‘active and ongoing
engagement of industry’ and the fact that a number of agencies - ATSB, BITRE
and even the Department have no formal consultative mechanisms with industry,
perhaps other than the Ministerial Aviation Industry Advisory Council and the
more recently formed GA Action Group. In CASA, the SCC remains in
suspension, waiting for a decision on a new mechanism that has been
recommended by an SCC working group on the issue.
 There is a ‘delink’ between the SSP statements regarding the focus on SMS
approach to safety (eg page 13 of the draft), and the ongoing CASA approach to
focusing on mainly ‘compliance’ issues. This combines with CASA’s inability to
construct and implement a classification of operations policy that determines the
resources it expends on aerial work surveillance and audit, for example. In turn,
this results in the SSP describing a system focus that is simply not evident in dayto-
day interactions with CASA field staff.
 There remains a lack of CASA commitment to surrendering power over some
sectors, despite CASA Sector Risk Profiles identifying industry led programs as
making a significant contribution to risk reduction. AAAA programs including
AIMS, the Chief Pilots Course, Standard Operations Manual, Professional Pilot
Program etc are all identified in the SRP as being valuable programs. However,
CASA is struggling with recognition of these programs and is requiring significant
additional resource expenditure by industry before it will recognise programs it
has already accepted as reducing risk. It is ridiculous that AAAA has been
required to submit a formal paper to CASA on the safety benefits of the AIMS
program, arguing that having an SMS is superior to not having an SMS - and even
quoting CASA own words on this issue when they introduced mandatory SMS for
RPT back to them. There is need for a stronger direction to agencies to honour the
pathways identified in the SSP.

 

And BRB Senate Estimates QON reference 'accelerate program':
CASA - QON 141-142:

Senator XENOPHON: Okay, so these are questions I could properly put towards Airservices, and I will. But my understanding is that Airservices is required to provide a risk assessment to CASA arising out of organisational change. Is that the case?

Mr Tiede: That is correct.

Senator XENOPHON: Have they done this in this case?

Mr Tiede: They have.

Senator XENOPHON: Are you able to provide us with a copy of that risk assessment?

Mr Tiede: I do not have it with me, but yes.  

---

[b]Senator XENOPHON: Can you provide details to this committee of the information that has been requested, including any emails, correspondence, notes or other documentation as to the flow of information between CASA and Airservices Australia about this organisational change.
[/b]

Mr Tiede: We will be able to do that—not right now.

[b][b]Senator XENOPHON: I realise that. I am asking you to take it on notice.  [/b]

[/b]So the BRB will eventually (probably the day before next Estimates - ) get a copy of the Harfwit risk assessment and any other applicable documentation and/or correspondence between ASA and CASA. 

ASA - QON 146-148:

E.g. QON 148
...Senator STERLE: That is good. Could you give us a list by area of the work-level descriptors for the changed roles?

Mr Harfield: What they are? We can provide that. That might take a little bit longer than tomorrow. As a result we are still in the middle of the process and finalising those over the next two weeks. So we can provide them after 24 October, if that is okay.

Senator STERLE: That is fine. And work functions that will be ceased or done differently?

Mr Harfield: That have changed? We can provide that.

Senator STERLE: All right. Can you provide the total number of staff who have been moved from enterprise agreements to individual contracts over the last 24 months?

Mr Harfield: Yes, we can provide that.

Senator STERLE: There are the ones you are talking about now—and if there are any further ones planned for the next 24 months.

Mr Harfield: If I can just clarify so I get this correct: we were not talking about people who have applied for roles before this change who have then—

Senator STERLE: No, I am aware we have not.

Mr Harfield: So it is in regard to the change—on the areas that we have proposed. We can do that. We chose the same answer to the previous questions you have just asked.

Senator STERLE: Okay, so that will alleviate my concerns—

Mr Harfield: The information you have already asked for will cover that.

Senator STERLE: Okay, and perhaps you could include their position title, years of service and date of transmission of industrial agreements and on to contracts for us.

Mr Harfield: We can do that.

ASA - QON 150 - 154:

Eg. QON 153
Senator XENOPHON: Right. Would it not therefore be logical, or reasonable, that given the magnitude of the change there would be a risk assessment provided to CASA arising out of the organisational change?

Mr Harfield: A risk assessment associated with the areas that CASA are interested in. There is not a risk assessment handed to CASA for all of the risks associated with the entire organisation—

Senator XENOPHON: So what areas are CASA interested in?

Mr Harfield: The effects on our air traffic services; our engineering and aerotechnical area, our air traffic services training area, our procedures design area and our aeronautical information management, as well as aviation risk and flight—

Senator XENOPHON: I just want to race through this. Thank you for that. If there is any—

Mr Harfield: We can provide this information—

Senator XENOPHON: Get me a list. But I want to understand what triggers a risk assessment, because I am concerned about the information I have—that the risk assessment was not carried out to CASA as some considered it ought to have been. In other words: who determines whether there should be a risk assessment, given the magnitude of these changes? Is it your call, or does CASA tell you what they want?

Mr Harfield: No, we have a safety management system that determines it. For each particular change, we make a determination through what we call a safety case determination. We go through that to determine what the magnitude of the change is for the area affected, as well as what the significance is. That will then tell us what level of safety work is to be done. We have also completed what is called a safety plan, which details all the safety work that has to be undertaken through a particular change. We can provide that to you.

Senator XENOPHON: If you could provide all those documents to the committee, that would be useful. My understanding was that CASA had some difficulty getting this information. Was any concern expressed to Airservices by CASA about any difficulties in getting this information—a risk assessment of these organisational changes?

Mr Harfield: I am aware of a couple of instances where certain requests were made and there had to be a discussion about what exact information was required, but there has been no withholding of information or cases of information not provided.

Senator XENOPHON: Could you provide copies of those documents or that interchange? That might put in context the concerns that have been expressed to me. My understanding is that, in the first round of redundancies, there were 240 redundancies in ANS—could you help me with the acronyms?

Hmm...very forthcoming was our match fit Electric Blue Harfwit - certainly be a lot for the BRB to chew on when that lot of AQON comes back...


MTF...P2