Reviewing the review

On a more positive note, credit does need to be given to the ‘new’ CASA officers that led the most recent CASR 21 Design and Production Working Groups and the Small Aircraft Sector – Risk Profile Working Groups. The meetings were professionally run and in accord with the 01/2015 Directive philosophy and were therefore well received by all attendees.

It’s time for a Post Implementation Review (PIR) of the Aviation Safety Regulatory Review (ASRR). The industry at large are wondering how the implementation of the ASRR is tracking. CASA have had the Ministers Statement of Expectations for some time now and indeed long enough for a review of how well the review recommendations have been adopted.

There seems to be general support within the Department of Infrastructure for a review of the Civil Aviation Act 1988. This is welcome news indeed, provided it is a comprehensive review and not just a tidy up. There are some significant legacy millstones that prevent the subordinate legislation from being as useful as it could be.

“Alas, there appears to be a degree of inertia within CASA management.”

As a contracting state to ICAO, Australia is required to have in place a State Safety Program (SSP). The draft SSP 2016 has recently been open for consultation. Whilst the proposed draft text is entirely reasonable, the claims therein should be tested. For example, the SSP states;

‘An important element of a mature system of safety management oversight is agreement between the safety regulator and service providers on the key performance indicators and expected level of performance to be achieved’…

‘Safety oversight based on a SMS approach is underpinned by a philosophy of mutual responsibility and accountability, rather than a more prescriptive approach aimed exclusively at regulatory compliance. This increases the responsibility on service providers who have day-to-day control over the maintenance of a safe operating environment, to focus on safety throughout the organisation’s structures, policies and procedures’.

In reality, many operators already have in place mature Safety Management Systems where, amongst other data, any flight crew fatigue issues are monitored, reported and acted on, if required. However, CASA has not made any effort to obtain/discuss or analyse Fatigue data from operators and yet has introduced draconian legislation (Civil Aviation Order 48.1), that has serious negative fiscal and logistical impacts on several large domestic carriers and the Royal Flying Doctor Service.

How can an increase of almost $3M per year for the Western Section of the RFDS be justified, without firstly analysing the operator’s data?

The first step would be for CASA to recognise the empirical evidence gathered and monitored over the years that clearly demonstrate how operators have successfully been managing the risk of fatigue. Perhaps this is a question more appropriately for the CASA Board, which is thankfully represented by experienced industry people?

Good news from Air Services Australia as they plan a 15% reduction in costs. Given that all their operating revenue comes from the aviation industry, can we look forward to most of those savings being passed on?