RAA Safety-Training-Compliance Coordinator appointed

[turboplanner]

Can you extend it?

 

 

[fly_tornado]

I can't see any option to modify it, ask a mod or Ian if they can tweak it.

 

 

[DWF]

I suspect that the poll is close to even because people were unsure of exactly what the question was asking.

 

To my mind there are at least 2 interpretations:

 

1. Do you think that RAA should have a STCC?

 

or

 

2. Do you approve of the way the STCC was appointed.

 

I did not vote in the poll because I wanted a bet each way.

 

DWF

 

 

[fly_tornado]

The poll was whether or not you approved of the decision in whole, Myles's payback for a supporting Ed, Ed's interpretation of the constitution power he holds, of what constitutes an emergency and the creation of another paper shuffling position in the interests of safety.

 

 

[Chird65]

I don't vote often on polls as the question is asked, I interpreter it, then my response is used how ever anyone wants.

 

 

[fly_tornado]

The poll never once swung towards approving Ed's decision, take of that what you will.

 

 

[turboplanner]

I suspect that the poll is close to even because people were unsure of exactly what the question was asking.To my mind there are at least 2 interpretations:

 

1. Do you think that RAA should have a STCC?

 

or

 

2. Do you approve of the way the STCC was appointed.

 

I did not vote in the poll because I wanted a bet each way.

 

DWF

Well question 1 would be irrelevant because we now know that a Safety Management System is a compulsory part of the CASA Deed of Agreement, and was required to be in place at least three years ago and requires an SMS Manager (Not sure where the STCC term came from, but the SMS position would involve training)

 

Question 2 we probably know the result of the feeling based on the posts in this thread and the other one.

 

However, we also know that CASA have warned RAA of its non compliance on several occasions over the years, and now appear to have imposed a Sanction ($60,000), or threatened to impose it, and withdrawn it on the basis of the President's immediate action and the person who would be acting as the SMS Manager until September.

 

So there would need to be a question asking people, would they be prepared for this to be reversed and to face a CASA sanction process similar to registrations, but this time relating to Flying School and Pilot compliance rather than aircraft.

 

 

[turboplanner]

The poll never once swung towards approving Ed's decision, take of that what you will.

Yeh, it was swinging yesterday - it had been sitting on 55/45%

 

 

[fly_tornado]

G'day FT.So is SAJF really the "chief volunteer" and leader of the "old-boyz Club"?

 

That would certainly be a revelation.

 

Regards Geoff

I was reffering to Middos allegation that airsick had hacked the spreadsheet on his note book that holds the RAA members detail.

 

 

[Admin]

The poll has been reopened

 

 

[Captain]

I was reffering to Middos allegation that airsick had hacked the spreadsheet on his note book that holds the RAA members detail.

Thanks. A misunderstanding. I'll delete that post & apologies to all.

 

 

[Spriteah]

Well question 1 would be irrelevant because we now know that a Safety Management System is a compulsory part of the CASA Deed of Agreement, and was required to be in place at least three years ago and requires an SMS Manager (Not sure where the STCC term came from, but the SMS position would involve training)Question 2 we probably know the result of the feeling based on the posts in this thread and the other one.

 

However, we also know that CASA have warned RAA of its non compliance on several occasions over the years, and now appear to have imposed a Sanction ($60,000), or threatened to impose it, and withdrawn it on the basis of the President's immediate action and the person who would be acting as the SMS Manager until September.

 

So there would need to be a question asking people, would they be prepared for this to be reversed and to face a CASA sanction process similar to registrations, but this time relating to Flying School and Pilot compliance rather than aircraft.

Question 1: In the deed I see a date of September 2012 for an SMS to be implemented. I might ad this is the date the Deed was signed so impossible to achieve unless there was already one in place. Where and in what document does it state a SMS manager is required? Does it need a specific position or can it be tasked to an individual as the focal? I've heard this comment twice now and researched but not found an answer. Turbs if you can direct me to the source I would be appreciative.

 

Question 2: You would really want to see a high percentage of approval of membership if possible. Not 50%. However it could depend on the issue.

 

Turbs are there threats of CASA sactions? Are they documented? I have been informed that CASA has withheld money before when RA-Aus has not been compliant. Then when they were compliant the money returned. Certainly I do not support being uncompliant. But I do not support kneejerk response to issues that have significant costs to the RA-Aus and might not be the most prudent solution, rushed solutions often turn pear shaped and costs often snowball.

 

Jim Tatlock.

 

 

[turboplanner]

Just pulling it together for you now.

 

 

[motzartmerv]

I have recieved and had time to review the SMS template. A couple of points I would like to make.

 

My initial impression is that the system is reasonably well put together. I feel it was rushed, things like text's and fonts used are very rough and the layout seems a little odd. But the ideas are good. The stystem is not dissimilar to any 'Job site" safety management system ive seen, or company safety policy's etc. In that regard I feel the document could easily be 'bluffed' by some, but it does give a very formal and indepth document that the powers could use as a stick to beat us (CFI's) with should we be found to be non compliant, because you could be found in breach of YOUR OWN recomendations and porcedures so there could be no 'I didnt know that rule" rubbish that we hear so much.

 

So I feel over all the system is a great start. I cant see how any exisiting managment position like 'ops' or admin could possibly monitor the system with anywhere near the degree of oversight it is going to need. So with that in mind its my opinion that a position MUST be created. All the arguments about process and person aside, there is no doubt in my mind that this system would fail without a dedicated person/ persons to run it.

 

The system (sms) adresses only one aspect of the 'problem' in my view. I still feel that this is an attempt to 'cover asses' rather than make actual changes in the stats of accidents and incidents.

 

IMHO we need to do a lot more, at a legislature level. A couple of things I personally would like to see:

 

* The RAA Cross country syllabus have a more extensive requiremnts on fuel planning etc

 

* Raa Cross country syllabus have units on IMC, avoidance planning, rules (VFR), procedures incase of inadvertant entry.

 

* RAA syllabus to involve BIF (hood time)

 

* All RAA CFI's be required to pass the CASA cyber exams for; Aerodynamics, meterology, human factors.

 

* All RAA Senior instructors be required to pass CASA cyber exams for human Factors and Aerodynamics.

 

* All RAA Instructors be required to do 1 hour every 2 years of dual 'spin' training. Obviously in a GA aeroplane.

 

* All Level 1 maintainers maintaining their own aircraft be required to complete a 'basic type course'.

 

Obviously some of these would require changes to the ops manual possibly part 104, but I fee very strongly that the above changes would be a good 'hands on' way to start to adress some issues. Id be happy to explain each of these recommendations, but perhaps not in this thread, its already experiencing full scale deflections in drift..:)

 

 

[drifterdriver]

Your suggestions don't personally effect me too much, but I'd like to know whether GA instructors have a recurring spin training requirement.

 

Nick

 

 

[motzartmerv]

No they dont. But they do have a requirement for issue of the initial rating. The reason I would like to see this is not only to adress the spinning issues, but to adress the 'stalling' issues we have.

 

Instructors that dont get near the deep stall (because they have never done it) are only able to teach mild stalls with wing drops etc. So I feel the student gets a watered down version because the Instructor is too 'afraid' to get too close to the unknown. Im not saying that we should let them spin in RAA aeroplanes, just that an instructor that knows where the limit is, and is comfortable having a student on the controls at the 'edge' will be giving a much more thorough stalling education. (IMHO)

 

 

[turboplanner]

Question 1: In the deed I see a date of September 2012 for an SMS to be implemented. I might ad this is the date the Deed was signed so impossible to achieve unless there was already one in place. Where and in what document does it state a SMS manager is required? Does it need a specific position or can it be tasked to an individual as the focal? I've heard this comment twice now and researched but not found an answer. Turbs if you can direct me to the source I would be appreciative.Question 2: You would really want to see a high percentage of approval of membership if possible. Not 50%. However it could depend on the issue.

 

Turbs are there threats of CASA sactions? Are they documented? I have been informed that CASA has withheld money before when RA-Aus has not been compliant. Then when they were compliant the money returned. Certainly I do not support being uncompliant. But I do not support kneejerk response to issues that have significant costs to the RA-Aus and might not be the most prudent solution, rushed solutions often turn pear shaped and costs often snowball.

 

Jim Tatlock.

Question 1

 

In the CASA Sport Aviation Self-Administration Handbook, published in June 2010 (see this link)

 

http://flysafe.raa.asn.au/regulations/casa_sport_aviation_handbook.pdf

 

On page 26 Item 4 (a) relating to board member responsibilities is says:

 

·Ensure the Organization's SMS framework is current and up to date

 

So we know that RAA board members were supposed to be doing that three years ago at least.

 

Even though you should have this handbook which spells out your responsibilities, it’s quite possible you’ve never seen it, I realise, so you someone may have to ask CASA for copies.

 

Page 11 has information on the Safety Management System (SMS), so we know the obligation RAA’s obligation existed in June 2010.

 

Page 19 refers to the Manager, but is brief.

 

Knowing CASA we know that with 8 hours of search we’ll find the Sport Aviation regulations somewhere, but on page 11 it says “this SMS framework is consistent with ICAO, CASA, FAA etc. so we know the requirements are standardised.

 

The identical dates of signing the deed you refer to and the same date being required for an SMS would be correct. The SMS is required to be in place on day one.

 

So we were in default at June 2010 and we were in default at September 2012 and we are in default now.

 

As for the SMS Manager being a requirement, we can go from Page 11 which confirms the SMS is consistent with CASA, or we can go from the document in the link, where CASA calls up ICAO Document 9859http://www.casa.gov.au/scripts/nc.dll?WCMS:STANDARD::pc=PC_101001

 

This is ICAO document 9859

 

http://www2.icao.int/en/ism/Guidance Materials/SMM_3rd_Ed_Advance_R4_19Oct12_clean.pdf

 

Page 168 says:

 

Establish a key person/officer responsible for the administration and maintenance of the SMS

 

Page 177 has a sample Job Description for a Safety Manager

 

Question 2

 

This is a small sampling, but I would really be looking for less that 20% against to warrant a no confidence or censure motion. Contrary to what people are suggesting here I and many others would walk away with a censure motion, and the needle had been drifting away from it.

 

CASA Sanctions

 

It may well be this festering sore dates back years before 2010. Someone posted here that they had been operating a FIFO airfield with SMS compliance since 2009.

 

From my memory the SMS accreditation swept through industry in the late 1990’s, the most visible sign being fluoro clothing.

 

So I expect CASA would have been agitating for years, and is following on the momentum gained with registration compliance. It may have been a big pain for us, but don’t forget, for the Minister for Transport it’s a big tick with zero non-compliant aircraft getting out of the gate registered.

 

I had come to the conclusion that there would be imminent action of some kind from a couple of trends and my own sources and that’s why when Ed took decisive action and the sanction went away, I backed him 110%.

 

It’s not all over yet though, because FTF’s will be bewildered, there was even a mini debate on here between people who seemed to think and SMS was something that was optional, and didn’t like it, but the latest deadlines are there and nearly a week has gone by.

 

I agree with everyone about the need for due process but even from a starting point of June 2010 I would agree with CASA that RAA has already used up its time in pointless debates about something which is mandatory anyway.

 

Someone plucked a figure out of the air of $200,000 per year, and while that’s probably inaccurate - at 10,000 members that’s $20.00 each.

 

I recall imploring people to check into a $200,000 blow out which caused the last subscription increase of $27.00 and I was howled down on this site and told it was petty cash.

 

 

[turboplanner]

I have recieved and had time to review the SMS template. A couple of points I would like to make.My initial impression is that the system is reasonably well put together. I feel it was rushed, things like text's and fonts used are very rough and the layout seems a little odd. But the ideas are good. The stystem is not dissimilar to any 'Job site" safety management system ive seen, or company safety policy's etc. In that regard I feel the document could easily be 'bluffed' by some, but it does give a very formal and indepth document that the powers could use as a stick to beat us (CFI's) with should we be found to be non compliant, because you could be found in breach of YOUR OWN recomendations and porcedures so there could be no 'I didnt know that rule" rubbish that we hear so much.

So I feel over all the system is a great start. I cant see how any exisiting managment position like 'ops' or admin could possibly monitor the system with anywhere near the degree of oversight it is going to need. So with that in mind its my opinion that a position MUST be created. All the arguments about process and person aside, there is no doubt in my mind that this system would fail without a dedicated person/ persons to run it.

 

The system (sms) adresses only one aspect of the 'problem' in my view. I still feel that this is an attempt to 'cover asses' rather than make actual changes in the stats of accidents and incidents.

 

IMHO we need to do a lot more, at a legislature level. A couple of things I personally would like to see:

 

* The RAA Cross country syllabus have a more extensive requiremnts on fuel planning etc

 

* Raa Cross country syllabus have units on IMC, avoidance planning, rules (VFR), procedures incase of inadvertant entry.

 

* RAA syllabus to involve BIF (hood time)

 

* All RAA CFI's be required to pass the CASA cyber exams for; Aerodynamics, meterology, human factors.

 

* All RAA Senior instructors be required to pass CASA cyber exams for human Factors and Aerodynamics.

 

* All RAA Instructors be required to do 1 hour every 2 years of dual 'spin' training. Obviously in a GA aeroplane.

 

* All Level 1 maintainers maintaining their own aircraft be required to complete a 'basic type course'.

 

Obviously some of these would require changes to the ops manual possibly part 104, but I fee very strongly that the above changes would be a good 'hands on' way to start to adress some issues. Id be happy to explain each of these recommendations, but perhaps not in this thread, its already experiencing full scale deflections in drift..:)

cover ass's comment

 

In the early days, guys wrote big manuals which sounded good, even got secretaries to write them, and then found they didn't cover that body part at all and they were in deep XXXX.

 

If you google safety management systems you'll see comments like"there's no point having a manual on a shelf" and "living the regulations"

 

A good way to start a shell is to walk through the Flying school with a notebook for a whole day (or get a volunteer to follow you) noting everything you do.

 

If you are a good safe operator, that will be the basic part of the manual and you'll be doing nothing you don't normally do, but the plus is that a relieving CFI can walk in, pick up the manual and duplicate your safe operation.

 

the things you would like to see

 

You can write these in, it's your FTF, then these can be recommended to the Safety Manager, he/she can circulate/discuss on a forum and they can become standard, or optional to FTF's.

 

That extends right in to common causes of accidents.

 

Very soon the FTF will be a safer place, the fatalities will go down, the claims will go down and we can all return to coming up with bright ideas for market expansion.

 

 

[Chird65]

IMHO we need to do a lot more, at a legislature level. A couple of things I personally would like to see:

* The RAA Cross country syllabus have a more extensive requiremnts on fuel planning etc

 

* Raa Cross country syllabus have units on IMC, avoidance planning, rules (VFR), procedures incase of inadvertant entry.

 

* RAA syllabus to involve BIF (hood time)

 

* All RAA CFI's be required to pass the CASA cyber exams for; Aerodynamics, meterology, human factors.

 

* All RAA Senior instructors be required to pass CASA cyber exams for human Factors and Aerodynamics.

 

* All RAA Instructors be required to do 1 hour every 2 years of dual 'spin' training. Obviously in a GA aeroplane.

 

* All Level 1 maintainers maintaining their own aircraft be required to complete a 'basic type course'.

 

Obviously some of these would require changes to the ops manual possibly part 104, but I fee very strongly that the above changes would be a good 'hands on' way to start to adress some issues. Id be happy to explain each of these recommendations, but perhaps not in this thread, its already experiencing full scale deflections in drift..:)

Motz,

 

i agree with where you are going but i'd rather see us change our regs rather than force instructors to the extra time and expense of using non RAA paths.

 

 

[drifterdriver]

I used to fly aerobatically for a living and I always thought it was disappointing from a safety aspect that all pilots weren't required to do at least some training in this area. Also an hour or two under the hood would hopefully discourage some of the more adventurous of our members from getting the rush of blood and pressing on into the murk. I believe that at least one current board member would like to see approval for optional BIF training for those that desired it.

 

Nick

 

 

[turboplanner]

Here we go Jim,

 

Another CASA document describing the Safety Manager on Page 05, even a photo of one. When I saw the epaulettes, I immediately thought of Eugene.

 

http://casa.gov.au/wcmswr/_assets/main/sms/download/2012-sms-book2-safety-policy-objectives.pdf

 

 

[facthunter]

The safety manager doesn't have to be full time surely? (Even though it could well be more than that in the RAAus case. How would one check the whole of Australia? ( In a physical sense). Nev

 

 

[motzartmerv]

Chird, yes I know it would get a lot of resistance. But unfortunately we can't do certain things in the raa as you are aware. And remember senior Instructors are already required to pass the ga ppl exam:). The knowledge gained from some of the cpl exams is crucial in any commercial operation as far as I'm concerned. We as instructors are sending pilots solo, in the training area and in navigation flights etc. I think the raa has a duty of care to ensure that people In that position can assess the wx at a commercial level. That's just one example of where my feelings come from.

 

 

[turboplanner]

The safety manager doesn't have to be full time surely? (Even though it could well be more than that in the RAAus case. How would one check the whole of Australia? ( In a physical sense). Nev

Well you've probably answered your own question there. I just provided access to a document which says larger organizations may need more, but once the manuals are done, The Safety Manager could utilise electronic communication, photographics (we're all no very quick to take an Iphone photo of a car accident and send it all around the world in secinds), and the Safety manager can organise audits in many creative ways including a volunteer like yourself to check an FTF compliance with it's manual. A lot of advice could be obtained from companies who went through the set up procedure a few years ago etc. I've done auditing and after the first one you can walk and check very quickly.

 

You also get a very good grasp on who is compliant and auditing themselves well and who the basket cases are within about three audits - it's very educating to see the pattern unfolding.

 

 

[turboplanner]

Sorry, what we've all forgotten is that there already is a Safety-Training manager in place to answer your questions thanks the Ed's fast footwork.

 

I'm sure Myles would be already run off his feet, but a good idea might be to create a more positive thread and involve Myles is making sure the FTF's are set up with workable manuals by the deadline.