RAA Safety-Training-Compliance Coordinator appointed

[turboplanner]

I had a look at the LATEST FAA information this morning, as I mentioned above and you have to comply with way more than one book. Pretty much all you think you'd need is not the same as what the FAA requires.

 

In Australia, the work or several different Government Departments working at different levels on different issues could never be combined into one book, hasn't been in the last 30 years, and is never likely to. In fact the DIT was the first Government Department to switch to living documents, where updates and corrections can be made seamlessly and they did it at my suggestion. That's why you can go on to the DIT website and see the latest version of Australian Design Rule, the latest version of all licensing requirements, where CASA fits in, the Sport Pilot section of CASA, the job descriptions of our board members and so on. No screwing around with books and documents which may be two versions out of date.

 

If I could get them to do nesting diagrammes, and multiple search name lookups we would be at the front of the world.

 

 

[nong]

Good morning Sue,I will follow up the template situation, for the next week work is in the way, however with some careful planning that will not be a problem.

Hazards:- I have a problem with them.

 

One day this was explained to me like this:- This gentleman said facing a cricket ball doing 110 kph is not hazard he loves doing that and I say that is dangerous.

 

It is what we perceive as a hazard. What one deams life threatening and an another calls it childs play. (For me it is the cricket ball story.)

 

So after that bit of woffle it boils down to training and training for scenarios and staying within the envelope.

 

Regards

 

Keith Page

Oh Keith, now I understand. Now I realise I have to TRAIN my students, train them for the likely scenarios and to stay within the envelope. Well, who would have thought.....

Thanks, old mate, for clearing that up.

 

But don't worry, my students will be getting less personal attention soon, as I will be spending the time on your on your beloved SMS paperwork.

 

 

[nong]

This is such a piece of a) cynical, and b) short-sighted commentary, that it hardly beggars commentary. However, lest it be taken as intelligence it needs a response.No system will eliminate willful stupidity. No regulation intended to prevent foreseeable eventualities will succeed in the face of willful non-observance. No amount of peer-pressure good advice will prevent willful disregard. How many experienced aviators were present at Natfly last year when a couple took off at last light - and died shortly thereafter?

 

What an SMS WILL do, is assist in the prevention of accidents resulting from genuine lack of knowledge. By at least reducing the 'unknown' danger factors, aviators have better information on which to base their decisions. Ultimately, the decision to take off, to press on into adverse conditions, to attempt to land, is up to the PIC - but at least, if provided with the best-available information, their choice to take an action is at the least, an informed one.

 

The principle of accessibility to critical information is well-established. For instance, Material Safety Data Sheets are provided for a vast range of products, so that users can be aware of any dangers inherent in using that product. You can argue that this is another version of '****-covering' - but those sheets allow end-users to at least be aware of any risks they take in using the product. You cannot buy a ladder without a placard that says; 'do not step above this height - you may lose your balance' - yet around 20 deaths and over 1,000 injuries a year are related to ladders.

 

Users of ladders are not regarded by society as 'risk-takers'. However - how often do you see a report in the media of a death from a ladder accident? Yet every fatality - or even incident - regarding an aircraft gets media attention.

 

The bottom line is: our activity NEEDS an effective SMS, to demonstrate that we are, as a group, not just aware but pro-active in trying to improve our safety standards. We NEED a demonstrable standard by which the actions of the individual can be judged to be either consistent or inconsistent with a reasonable expressed standard of safety. If you wish to call this '****-covering', you are entitled to so do - but if you want to beable to enjoy the support of the general community for things like saving local airports from developers, then we NEED the '****-covering' of expressed safety standards with which to defend our activities from the prejudice of a community response that we all a pack of death-wish loonies that they don't want near their community.

 

OK, call it '****-covering'. However, without it, we stand a very real chance of having our arses run out of too many towns because 'the local community' doesn't believe we are a safe and reasonable activity in their locale. It isn't just CASA's imperative at work here - it's our survival.

Oscar. Are you paranoid? I can assure you that recreational pilots in my part of Australia are not viewed with suspicion or as being "death-wish loonies". We are welcomed by our aerodrome operator, as is all aviation traffic.

Your suggestion that an SMS will prevent accidents "resulting from a genuine lack of knowledge" or will reduce " 'unknown' danger factors" is lamentably incorrect. In fact, student training is guided by multiple syllabii. The CFI ensures that these syllabii are taught. Also, each student's grasp of required knowledge is tested.

 

It is interesting to note that both myself, and another CFI posting on this thread, broadly share the same professional opinion of the proposed SMS.

 

 

[nong]

Oscar was also a Japanese fighter aircraft (land-based Zero) that couldn't take a hit and came apart easily if hit by allied fire..........LOL.........Maj.................

Maj. The Zero is the Mitsubishi. The Oscar is the Nakajima design. Similar layout though, and at a glance..... You might remember Sid Marshall's Oscar. He kept it at bankstown in the fifties and sixties and later it sat at Jack Davidsons strip at the Oaks.

 

 

[nong]

Information postFor those members who are not familiar with the principles of a SMS, the ICAO SMS Implementation Training Course (which I have attended, prior to introducing a SMS into my organisation) has a reasonable presentation about SMSs. It can be viewed at http://legacy.icao.int/anb/safetymanagement/training/presentations/ICAO SMS M 08 – SMS planning (R013) 09 (E).ppt.

 

It may look like a load of waffle, but if implemented correctly, such a system would provide enormous benefit to our organisation. I have seen firsthand the substantial benefits of a successful system within an aviation organisation.

If it smells like waffle and tastes like waffle......

SMS is likely to be an intolerable burden for a typical small, one or two staff member, RAAus school. It is all very well to spruik on about how you introduced an SMS into your organisation, but you did not state the approx dollar turnover per annum, the number of employees or give a fair breakdown of the dollar cost of compliance.

 

How much extra are you prepared to pay for your training or next BFR? SMS won't be free. The cost to schools will be passed on, plus a margin, plus GST.

 

 

[turboplanner]

In fact, student training is guided by multiple syllabii. The CFI ensures that these syllabii are taught. Also, each student's grasp of required knowledge is tested. It is interesting to note that both myself, and another CFI posting on this thread, broadly share the same professional opinion of the proposed SMS.

On the first three sentences - if only that were true around Australia; the high fatality rate indicates that might not be correct.

 

For the second sentence, I think there might be three of you who have invited some close attention in the future.

 

 

[Teckair]

On the first three sentences - if only that were true around Australia; the high fatality rate indicates that might not be correct.For the second sentence, I think there might be three of you who have invited some close attention in the future.

Yeah great start threatening CFIs now,what does this mean? if you are a CFI you cannot have an opinion? You just have to tow the party line no matter how stupid it is?

 

 

[poteroo]

On the first three sentences - if only that were true around Australia; the high fatality rate indicates that might not be correct.For the second sentence, I think there might be three of you who have invited some close attention in the future.

I think there is only a very tenuous link between the quality and extent of instruction on the accident rate. It's part and parcel of any 'official' report or survey to start looking for scapegoats. The fatality rate probably is better linked to the type of accident, ie low level/high speed, or VFR into IFR etc. As I stated previously, education via a SMS will take time to produce quantifiable outcomes. In the meantime, if pilots were to think more about currency and recurrent training - and heeded their instruction rather than their mates' bar stories - we'd soon improve things. As to whether we'll attract unwelcome scrutiny from the regulators........ well, that's a risk best assumed by we much older and experienced people as we do have standing with them, and we have less long term career 'risk' to worry about.

 

happy days,

 

 

[facthunter]

I would be extremely concerned IF expressing views as to the effectiveness of certain forms of SMS's would bring extra scrutiny upon those who did so.

 

Also, poteroo, since most accidents are not evaluated well, it would be difficult to assert that poor flying skills are, or are not, responsible for accidents. I feel inadequate skills base is responsible for some, and I have strong views on that, but "attitude to risk taking behaviour,"is probably more so. Let's call it the "cowperson?" attitude. Safety is a CULTURE, more than a set of boxes to tick. Nev

 

 

[turboplanner]

Yeah great start threatening CFIs now,what does this mean? if you are a CFI you cannot have an opinion? You just have to tow the party line no matter how stupid it is?

Yes you do, and it's toe the party line, and there's nothing stupid about it - read the documentation you're supposed to have been following for three years.

 

 

[turboplanner]

I think there is only a very tenuous link between the quality and extent of instruction on the accident rate. It's part and parcel of any 'official' report or survey to start looking for scapegoats. The fatality rate probably is better linked to the type of accident, ie low level/high speed, or VFR into IFR etc. As I stated previously, education via a SMS will take time to produce quantifiable outcomes. In the meantime, if pilots were to think more about currency and recurrent training - and heeded their instruction rather than their mates' bar stories - we'd soon improve things. As to whether we'll attract unwelcome scrutiny from the regulators........ well, that's a risk best assumed by we much older and experienced people as we do have standing with them, and we have less long term career 'risk' to worry about. happy days,

The most detailed investigation = the most accurate assessment of causes.

 

The most accurate assessment of causes = the most accurate decision on how to reduce repeats.

 

Categorizing accidents is the best way to start honing in on specific areas to investigate, because patterns start to become obvious.

 

Two examples of categorized accidents and subsequent actions which have saved thousands of Australian lives are:

 

Identifying that in many fatal car accidents the occupants who died were found to have been thrown out of the vehicle. Simply fitting seat belts eliminated those statistics overnight for an immediate reduction in the road toll of around 50%.

 

Identifying that in about half the remaining fatal accidents the driver was drunk. RBT substantially reduced those fatalities.

 

Since the world wide principle of Safety Management Systems is that you write your own, and you live it every day, the opportunity is there to identify recurring fatalities, such as pilots dropping perfectly good aircraft out of the sky, flying into cloud/fog, fuel exhaustions, flying after last light, currency and recurrent training etc.

 

The ideal way of doing this is to have a big statistical, accurate, database but we know this is not going to happen unless ATSB investigate recreational aircraft incidents and accidents. Facthunter always brings up the cost of this, but just at the moment since it appears to have been decided recently that ATSB is to investigate all GA incidents and accidents, that this would discriminate against RA where fatalities now appear to be exceeding GA.

 

This may not happen, but if RA accidents are categorised, there is a clear indication that they could be substantially reduced even with the information which has appeared on this site, because we can still take the reverse of the statistical starting point, and begin by writing obvious causes and solutions into the SMS, and reviewing the statistics, which then, if it is done correctly are likely to come down virtually to the same extend as those accidents examined minutely.

 

I agree with you that very little needs to be done to reduce the statistics.

 

I haven't seen any sign of anyone looking for scapegoats, but I have seen repeated contempt for safety from just a few, and they are the ones who would already have singled themselves out for scrutiny, not the other 97%.

 

 

[Teckair]

Some people are so full of it.

 

 

[flyvulcan]

Let's start with the fact that the requirement for a SMS has been imposed on RAAus. We, as an organisation are now obliged to do so, and in short time. If members feel strongly that such an imposition is not appropriate, then we can get our representatives to commence lobbying to have the requirement rescinded. In the meantime, lets look at how to bring our organisation into compliance as best we can.

 

People have rightly pointed out that for each FTF to implement their own SMS is a significant and onerous undertaking.

 

Perhaps (thinking outside the square here), the organisation as a whole could implement the SMS and do a lot of the hard work associated with the establishment and maintenance of such a system. Then, rather than having each FTF develop and implement their own individual SMS, perhaps each FTF could be considered to be an individual Safety Action Group (SAG) within the overall RAAus SMS. Each FTF would establish their own Hazard Register and report to a centralised Safety Department within RAAus. This would remove the significant burden of manual writing, appointing a Safety Manager/Accountable Person etc from each FTF. There would need to be be a nominated person to head each SAG, so one nominee from each FTF that would be responsible for maintaining the FTFs participation in and maintenance of that FTFs responsibilities within the overall SMS of RAAus.

 

This option is one that will both comply with the intent and aim of a SMS whilst providing minimal stress to each FTF and the organisation as a whole.

 

Ok, I've made a suggestion to help. Perhaps there are other suggestions from more of you that the Board can consider to try to introduce this obligatory system as painlessly as possible, while still complying with the intent of such a system.

 

 

[Oscar]

While the impact of implementing an SMS for individual FTFs is in no way minimal, it is worth considering the offsetting benefits.

 

Demonstrable adherence to an accepted standard of performance is a very significant defence against a legal challenge of negligence. In our litigious society, a provider of goods or services is squarely in the firing line for legal redress of grievance. If no standard of performance is available, then it can come down to the opinion of the Court in the case of a claim that the provider of goods or services failed in anticipating a risk involved and therefore may beheld to be liable for compensation for injuries/death /property loss etc.

 

This is NOT a trivial matter: RAA has recently been involved in a court case because of its lack of adherence to standards that has cost well over one half a million dollars in legal fees alone.

 

The aircraft we all fly, are available to us through the adherence to standards. In the USA, the light aviation manufacturing industry was all but wiped out because of the problems of litigation. I venture to suggest that no RAA FTF can afford to exist if it is 'on its own' in having to prove that it adequately prepared a trainee for all foreseeable risks involved in flying. No insurance company is going to provide professional indemnity insurance for an entirely open-ended risk scenario, so any training would have to depend on the legal validity of a declaration by the trainee that they accept all and any risk of flying, now and in the future. And that, in its turn, would not be worth squat until tested in a Court, that such a declaration absolves the training organisation of all responsibility.

 

The existence of a standard is an explicit statement of the required level of performance - in this case by an FTF. It removes from the FTF the obligation of having to determine and train for situations that it may not have considered likely or even possible. It provides the FTF with the legal defence that, having demonstrably met the required standard, it has discharged its legal obligations to the student.

 

An SMS does not surplant good training. An SMS is absolutely no guarantee that pilots will still not make bad decisions. However, it IS another weapon in the armoury of having us continue to be able to aviate in the RAA-class regime. Do not dismiss its value just because of its cost.

 

 

[Teckair]

Let's start with the fact that the requirement for a SMS has been imposed on RAAus. We, as an organisation are now obliged to do so, and in short time. If members feel strongly that such an imposition is not appropriate, then we can get our representatives to commence lobbying to have the requirement rescinded. In the meantime, lets look at how to bring our organisation into compliance as best we can.People have rightly pointed out that for each FTF to implement their own SMS is a significant and onerous undertaking.

 

Perhaps (thinking outside the square here), the organisation as a whole could implement the SMS and do a lot of the hard work associated with the establishment and maintenance of such a system. Then, rather than having each FTF develop and implement their own individual SMS, perhaps each FTF could be considered to be an individual Safety Action Group (SAG) within the overall RAAus SMS. Each FTF would establish their own Hazard Register and report to a centralised Safety Department within RAAus. This would remove the significant burden of manual writing, appointing a Safety Manager/Accountable Person etc from each FTF. There would need to be be a nominated person to head each SAG, so one nominee from each FTF that would be responsible for maintaining the FTFs participation in and maintenance of that FTFs responsibilities within the overall SMS of RAAus.

 

This option is one that will both comply with the intent and aim of a SMS whilst providing minimal stress to each FTF and the organisation as a whole.

 

Ok, I've made a suggestion to help. Perhaps there are other suggestions from more of you that the Board can consider to try to introduce this obligatory system as painlessly as possible, while still complying with the intent of such a system.

Yep it is recognised that will be the way it will be done by people involved with the implementation process I have been told.

 

 

[turboplanner]

Oscar is on the money FV. The lawsuits should go to the people making the money out of flying, the ones responsible for converting spectators into participants. The lawsuits can only kick in when there has been negligence, so there's no real issue with this.

 

Each FTF should have its SMS, however the way RAA went about it is onerous, and a better way would be for FTF's to return comments on what they have received (other than "I don't want it") and then a central policy be written, with an FTF section where the FTF can write up their unique requirements (e.g. relating to any circuit restriction due to skydivers etc). That way there is a base manual, which shows the FTF owner the basic format, and reduces his task specifically to his operations.

 

Regarding your idea of using the SAG provision, from my reading that fits under the Safety Review Committee, and is more appropriate to the group of people who will need to volunteer for Compliance and Auditing tasks, and that group must be independent of CFI's.

 

 

[facthunter]

The CFI's are right at the coalface so it would be a good idea to get them onside and take heed of their views. IF anyone knows what is going on out there it is them. I would hope a better success level was achieved than with human factors which wasn't done well and is never finished actually as it is always a work in progress.. We talk of a BAD accident record. Is that actually the case? Any accident is a tragedy and we should hope for zero but know it will never be achieved. It gets down to cost and effort and you could drive everybody away from the sport. if things were made outrageously complex . I would like to feel that the effort is not a cynical one of having done something and having it Ticked off and thereby passing the buck to someone down the line. Nev

 

 

[Teckair]

Oscar is on the money FV. The lawsuits should go to the people making the money out of flying, the ones responsible for converting spectators into participants. The lawsuits can only kick in when there has been negligence, so there's no real issue with this.Each FTF should have its SMS, however the way RAA went about it is onerous, and a better way would be for FTF's to return comments on what they have received (other than "I don't want it") and then a central policy be written, with an FTF section where the FTF can write up their unique requirements (e.g. relating to any circuit restriction due to skydivers etc). That way there is a base manual, which shows the FTF owner the basic format, and reduces his task specifically to his operations.

 

Regarding your idea of using the SAG provision, from my reading that fits under the Safety Review Committee, and is more appropriate to the group of people who will need to volunteer for Compliance and Auditing tasks, and that group must be independent of CFI's.

Gee with friends like you and Oscar who needs enemies?

 

 

[flyvulcan]

Turbs et al,

 

Looking at the member and role criteria of SAGs at Para 1.3 of http://legacy.icao.int/anb/safetymanagement/training/presentations/ICAO%20SMS%20M%2008%20–%20SMS%20planning%20(R013)%2009%20(E).ppt, it appears to me appropriate that each FTF could be designated as a SAG within a RAAus SMS.

 

It could be written into the RAAus SMS Manual that each FTF (SAG) would have the responsibility to compile and maintain a Hazard Register applicable to their specific area of operation, and develop/promulgate risk mitigating initiatives within their own operational documentation.

 

So with the example given about circuit direction or parachuting, the relevant FTFs Hazard Register would list RH circuits RW18 with their specific Ops Manual/local flying orders noting this with the requirement for people operating at their airfield to be aware and comply with the non-normal circuit direction. The FTF could also ensure that the relevant CASA documents relating to that airfield correctly reflect such information. WRT the parachutists, a similar course of action could be applied. Etc.

 

If they were part of the RAAus SMS, as well as local initiatives, the FTFs would also be obliged to incorporate any RAAus initiatives in respect to general Risk Mitigation strategies, for example to amend syllabi to incorporate more extensive stall/spin training, to emphasise the decision making process with respect to flying into deteriorating weather conditions etc..

 

I think everyone will agree that liability should remain with the service provider, unless it is proven that the overseeing authority has been negligent. I believe that the FTFs, as the service provider, will remain liable even if the FTF is part of the RAAus SMS. Perhaps a legal person can confirm or refute this?

 

WRT auditing of each individual FTFs safety system, I would see this as a role of the Safety Manager in the first instance who will provide support, and in the final instance, by an RAAus Quality Manager who has no direct involvement in the Safety System and can report without prejudice. Any deficiency noted by the Quality Audit would require rectification.

 

Whether a FTF comes under the RAAus SMS as a SAG, or whether RAAus assists each FTF establish their own standalone SMS through provision of a template probably doesn't matter as long as the overall system complies with the CASA requirement, liability remains where it should, and that an effective system and processes are developed as painlessly as possible.

 

 

[turboplanner]

Facthunter, the members write the Safety Management System, and they certainly should involve you to ensure the things which concern you are avoided.

 

 

[turboplanner]

Gee with friends like you and Oscar who needs enemies?

All you have to do is simply read the applicable SMS documents, and I've even provided the links for you.

 

 

[Teckair]

All you have to do is simply read the applicable SMS documents, and I've even provided the links for you.

I have the SMS documents and I feel and it is widely recognised they are not appropriate for the majority of the flying schools.

 

 

[turboplanner]

If you are talking about the shell sample document RAA sent to you, we're not talking about that.

 

As we've found out over the past few weeks, CASA including RAA, CAA(UK), and FAA(USA) all reference the same ICAO document.

 

So there's no point trying to squirm out of it.

 

 

[Dafydd Llewellyn]

Looking at the prospective members of the Board, the thing I do NOT see is: A comprehensive understanding of the Civil Aviation Regulations. I see people who know how to run a business; how to run a flying school, how to work governance with boards, how to run NFP organisations, etc. But these things have to fit into the aviation environment, which imposes an entirely different set of constraints. This thread is about the safety-training-compliance-coordinator; presumably people imagine they can simply delegate all that pestiferous CAR/CASR/CAO stuff to him, and then get on with more interesting things, like NATFLY etc. WRONG! More than anything else, the majority of the board members need to be able to find their way around the aviation regulations, because the RAA exemptions are fundamentally a means of allowing an alternative way of achieving a more-or-less equivalent result, that happens to suit the style of operations of the majority of recreational aeroplane operators. If the board does not have adequate strengths in this area, it will all go wrong again.

 

Learning one's way through the regulatory jungle is not easy; most people who earn their living from aviation, barely have the time to learn the rules for their own small area. But at least the board candidates ought to be conscious of the imperative necessity for this knowledge to be available to the board. It would seem to me that there should be at least three board members who at least know how and where to look, to be able to bring the regulatory constraints to the attention of the remaining board

 

members.

 

No, it is NOT sufficient to be familiar with CAO 95.55, the Deed of Agreement, and the RAAus constitution. For example, you need look no further that Wayne Mathews' article in the most recent Sport Aviation. Wayne has raised the issue of Weight & Balance. Good - about B time. But nowhere does he mention that the exemptions in CAO 95.55 do NOT include CAR 235 or CAO 100.7 - which set the requirements for weight & balance control for ALL Australian aircraft. The organisation has been going since 1983 under various names, and it STILL has not grasped this?

 

How long are you all going to stay in cloud-cuckoo land? It's been 30 years so far . . .

 

 

[Keith Page]

Oh Keith, now I understand. Now I realise I have to TRAIN my students, train them for the likely scenarios and to stay within the envelope. Well, who would have thought..... Thanks, old mate, for clearing that up.

But don't worry, my students will be getting less personal attention soon, as I will be spending the time on your on your beloved SMS paperwork.

Oi! Nong,

Bit of sarcasm there. You are way off track of what I am saying. The SMS is more about adopting good practices with in systems and procedures.

 

There is one very good test I quote " Better off being a live coward than a dead hero"..

 

The other point Nong if you run a well deciplined school you do not have to fear not a thing, you most likely have a great deal of the SMS in place already. Your only fear is, if you run by Raferty's

 

Regards

 

Keith Page.