[Peetwo]

Aerial App Phil on Murky's SSP -

Phil Hurst and the AAAA crew have been busy in 2016:

Submissions 2016: 

AAAA Submission State Safety Program Feb 2016
197.75 KB
Download


AAAA Submission Productivity Commission Ag Feb 2016
161.43 KB
Download

AAAA Submission CASR Part 138 Feb 2016
187.47 KB
Download

However the reason for being on Murky's thread was because of the AAA SSP submission which was in response to M&M's DRAFT SSP:

Australia's Draft State Safety Programme (SSP) 2016


The Australian Government's response to the Aviation Safety Regulation Review announced the Department of Infrastructure and Regional Development (the Department), in consultation with the aviation safety agencies, will update Australia's SSP to a forward looking, strategic plan for Australia's aviation safety system.

On 4 December 2015, the Department released an updated draft SSP for aviation industry and public comments. The comment period has now closed.

• Australia's Draft State Safety Programme (SSP) 2016: PDF: 696 KB
  
• Aviation Safety Regulation Review
  
• Australia's current SSP
  

 
What impressed me with this submission was the depth of understanding by Phil Hurst and his crew of the philosophy & principles of an effective State SSP according to ICAO Annex 19 SARP.

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 from Appendix 1:

21/ 3.3/CASA - And yet CASA has never assessed its own

regulatory reform program and the complexity of

new regulations such as Part 61 as being a threat to

aviation safety - which they are.


The best that can be said is that despite the disarray

of CASA's regulatory turmoil program, industry

continues to focus on safety, tried and true methods

of safe operation and comprehensive risk

management.


CASA continues to be largely irrelevant to safe

operations, perhaps other than the general

deterrence effect and the occasional action - which

it fails to communicate - against individuals or

certificate holders. In aerial work operations, it

simply does not have current expertise to be

relevant.

24/4.2/CASA It is extraordinary that no mention is made of the

power of CASA supporting and utilising industry

education programs as a delivery mechanism for

relevant safety messages.


Often, CASA has no expertise in highly specialist

areas such as aerial application, and therefore the

best they could do is to partner with AAAA to

support the delivery of safety course and other

training and programs that actually can deliver

relevant information in a highly credible way.

CASA education programs that are poorly

informed, poorly targeted and represent a waste of

money only reinforce the cynicism of industry

towards the relevance of CASA. A good example

was the use of DAMP posters sent to all operators -

regardless of size of operation, number of

employees etc. The fact that CASA is generally

unaware of the existing industry safety programs

and peak body communication channels to

members speaks volumes about the poor

communication strategy CASA pursues.

Well worth a read and if the calibre of other industry responses reflect the AAAA submission then maybe we may actually end with a workable & effective SSP that is fully compliant with the intent of ICAO Annex 19. Although cynically I will be surprised if Murky's crew warmly embrace the AAAA critique...

MTF...P2