RAA Safety-Training-Compliance Coordinator appointed

[dlegg]

Probably all you list seqfta,

 

but matters little as all are in the unenviable position of being members of an organisation that is unable to provide the core essense of its existance: aircraft registration

 

 

[fly_tornado]

It's a bloody full time job FT, plus some probabily. Not a part time occasional attendance thing like being a board member. Would you do it without being paid ?....I don't think so...............................Maj...

When did it become a full time position? That's one of the "facts" that Ed created to try and force the decision. There probably is some need for a safety officer in the RAA but I doubt that its full time, unless its attracting a high calibre applicant like Myles.

 

 

[turboplanner]

CASA, at least, do not necessarily require a "full time SMS Manager".

The CASA document "SMS for Aviation – A Practical Guide 2 - Safety policy and objectives" states that:

 

"Safety manager

 

Appointing the right safety manager is critical. This role can make or break an SMS.

 

A large organisation might have a dedicated safety department, led by a head of safety management.

 

A medium-sized organisation might have a separate safety manager, possibly with a small number of staff, whereas a small organisation might just appoint a part-time safety manager, or add these duties to an existing role."

The chain of documentation WHICH CASA ARE BOUND TO requires RAA to have a full time SMS Manager.

 

CASA has a unique ability to muddy issues with "advisory" or "explanatory" documents which often use different wording to the legal documents, often creating confusion.

 

Just think about what radio transmission standards we are legally required to be using now vs. what you hear day by day.

 

Recreational Aviation Australia In. is a large organization consisting of 8,000 to 10,000 members, and a Peak Organization required to drive a Safety Management System since 2010.

 

The document you referred to is superfluous - the original documentation which I've posted here is pretty much in plain English and spells out what is required.

 

If what Andy is alluding to is true, one or more CASA employees have put themselves into the same basket as the board members and are taking a massive personal risk.

 

 

[turboplanner]

When did it become a full time position? That's one of the "facts" that Ed created to try and force the decision. There probably is some need for a safety officer in the RAA but I doubt that its full time, unless its attracting a high calibre applicant like Myles.

Since 2010, and it has nothing to do with Ed; it's there in the documentation for you to read like the rest of us.

 

 

[seqfta]

Yes , very true , "Aircraft Rego" , No rego , no planes flying , no organization ! ... but being optimistic , and comparing the "flying Club" segment to the "Flying School" segment .

 

Through out this country , as a generalization ,

 

question (1) : are the schools and clubs endeavoring to incorporate together or divide apart ?

 

(2) : What are the agenda's to remain viable of the "clubs" vs the "schools" ?

 

 

[fly_tornado]

I read the document, it said permanent, permanent doesn't mean full time. Again we have Ed tweaking the facts to justify his abuse of process. Its not a real hands on job, its just processing a few forms and cashing a few cheques.

 

 

[AlfaRomeo]

Sorry Turbo but for once I must categorically disagree with you. RA-Aus is not a large or even medium organisation. With 15 employees, it qualifies as a small business. For an SMS to be successful in a small business, it must be scaled to fit the organisation or else it will do more to harm safety than enhance it as everyone's time gets absorbed with paperwork instead of walking around and doing safety.

 

RA-Aus needs to operate safely not just operate a complex safety system.

 

In my view, a permanent safety manager erodes "safety" out of the jobs of the Operations and Technical Managers. Safety is a line function for line managers. They certainly need support to do the leg work of getting a suitable SMS in place but it is not helpful for the responsibility of managing safely to be supplanted by a permanent staff function. Safety of pilots and their passengers and the general public they fly over is not the responsibility of the Safety Manager it is the responsibility of the PIC, their aircraft maintainer and the Ops and Tech Managers.

 

Surely what RA-Aus needs is a consultant with demonstrated expertise at establishing a SMS in the Aviation arena? There are a number of such organisations and RA-Aus has been in discussions with them very recently. Consultants are much better at auditing systems than the people who designed or operate the system. Consultants can be expensive but for a relatively short duration. A smart safety system is infrastructure in much the same way as the office building and computer systems.

 

It is indeed a pity that we haven't all been advised about what is happening in this area particularly all the "sky is falling" warnings from Ed. While we can all hope that the Board will tell us soon, hoping and complaining about it here won't achieve a single (useful) thing. I will contact by Board Reps today and ask them to tell us all what is happening in this area and I urge all RA-Aus members to do likewise.

 

I strongly agree with you that it is not appropriate to enter into a detailed public discussion of Myles's suitability for the role. From the outcomes we know of, you could logically deduce that the judgement of the Board Majority, who do know Myles, is that he was not suitable and that the process for his selection was not in keeping with sound management practices nor demonstrably ethical and nor in keeping with the principles of good governance which our Board Members are obliged to observe.

 

It is time to let go of this unsavoury episode of improper conduct and cronyism and get on with the future.

 

 

[Guest airsick]

It worries me that the current executive still aren't complying with the constitution. Where's our financials for the 2012/13 year?

 

I'll cut the new exec a little slack because they have only been there since 9 July but a little communication wouldn't go astray...

 

 

[coljones]

It worries me that the current executive still aren't complying with the constitution. Where's our financials for the 2012/13 year?I'll cut the new exec a little slack because they have only been there since 9 July but a little communication wouldn't go astray...

When (if) you get on the board you might like to push for financial reports that include past performance vs current performance vs expected performance vs prospective performance as well as a current income profile and reserves policy statements. As AR has indicated elsewhere there may be some value in moving the financial year away from the peak accounting period (June-July) and the silly season (December-January).

 

 

[dodo]

It worries me that the current executive still aren't complying with the constitution. Where's our financials for the 2012/13 year?I'll cut the new exec a little slack because they have only been there since 9 July but a little communication wouldn't go astray...

The draft financial statements are on the RA site now. Definitely interesting!

 

dodo

 

 

[Captain]

It worries me that the current executive still aren't complying with the constitution. Where's our financials for the 2012/13 year?I'll cut the new exec a little slack because they have only been there since 9 July but a little communication wouldn't go astray...

I agree with you Mick,

 

The slack-cutting that I mentioned in my post # 914 started to run out at end July.

 

There clearly needs to be some updates, posted on the RAA Website that explain whatever is the current situation in a number of key areas, and it needs to happen quick-sticks.

 

 

[dodo]

I agree with you Mick,The slack-cutting that I mentioned in my post # ??? started to run out at end July.

 

There clearly needs to be some updates, posted on the RAA Website that explain whatever is the current situation in a number of key areas, and it needs to happen quick-sticks.

The financial statements raise a few questions. Interesting that our employee expenses and key personnel expenses haven't changed much, but some of the related costs have.

Legal costs...

 

And just from a quick look, some of the other expenses and revenues are interesting.

 

dodo

 

 

[Captain]

The financial statements raise a few questions. Interesting that our employee expenses and key personnel expenses haven't changed much, but some of the related costs have.Legal costs...

And just from a quick look, some of the other expenses and revenues are interesting.

 

dodo

G'day Doey,

 

On 1st reading it is hard to see the result of the recent Court Case on our finances, other than that the legal costs have gone through the roof, and it looks like there has been no provision made for any future court action.

 

But I wonder how much of that legal cost was SR & Middo related re the resignation that wasn't .... and in their exercise at & leading up to the EGM.

 

The CASA contribution to the administration of this part of Aussie aviation looks particularly puny in the overall consideration of what it takes RAA to do it.

 

 

[dodo]

From gossip/rumour, I got the impression the plaintiff wasn't after money, but would settle for blood or substantial change (or something!). If so, the plaintiffs main motivation may have been that the accident was unnecessary, and that either people should be held accountable, or that change should happen to ensure a similar accident did not occur in future, or something along those lines.

 

If so, any settlement may not have involved money.

 

Either way, now that it has been settled, our board can now tell us what we got for our money, or what any consequences are.

 

I would be very disappointed if we are now told it is a confidential settlement blah, blah, blah, after having been told that a case in progress can't be reported to the membership in any meaningful way.

 

That sort of expenditure does require meaningful reporting to the membership.

 

And my post assumes the bulk of the expense was on a single case...I wonder if there are there any others coming along?

 

dodo

 

 

[turboplanner]

Sorry Turbo but for once I must categorically disagree with you. RA-Aus is not a large or even medium organisation. With 15 employees, it qualifies as a small business. For an SMS to be successful in a small business, it must be scaled to fit the organisation or else it will do more to harm safety than enhance it as everyone's time gets absorbed with paperwork instead of walking around and doing safety.RA-Aus needs to operate safely not just operate a complex safety system.

 

In my view, a permanent safety manager erodes "safety" out of the jobs of the Operations and Technical Managers. Safety is a line function for line managers. They certainly need support to do the leg work of getting a suitable SMS in place but it is not helpful for the responsibility of managing safely to be supplanted by a permanent staff function. Safety of pilots and their passengers and the general public they fly over is not the responsibility of the Safety Manager it is the responsibility of the PIC, their aircraft maintainer and the Ops and Tech Managers.

 

Surely what RA-Aus needs is a consultant with demonstrated expertise at establishing a SMS in the Aviation arena? There are a number of such organisations and RA-Aus has been in discussions with them very recently. Consultants are much better at auditing systems than the people who designed or operate the system. Consultants can be expensive but for a relatively short duration. A smart safety system is infrastructure in much the same way as the office building and computer systems.

 

It is indeed a pity that we haven't all been advised about what is happening in this area particularly all the "sky is falling" warnings from Ed. While we can all hope that the Board will tell us soon, hoping and complaining about it here won't achieve a single (useful) thing. I will contact by Board Reps today and ask them to tell us all what is happening in this area and I urge all RA-Aus members to do likewise.

 

I strongly agree with you that it is not appropriate to enter into a detailed public discussion of Myles's suitability for the role. From the outcomes we know of, you could logically deduce that the judgement of the Board Majority, who do know Myles, is that he was not suitable and that the process for his selection was not in keeping with sound management practices nor demonstrably ethical and nor in keeping with the principles of good governance which our Board Members are obliged to observe.

 

It is time to let go of this unsavoury episode of improper conduct and cronyism and get on with the future.

 

The size of RAA, whether is be a 15 man Office in Canberra where no accidents or fatalities are occurring or across Australia with 5000 + aircraft and regular fatalities is immaterial, because DWF quoted from Booklet 2 on the CASA website which is related to CASA's activities such as airlines, charter companies, maintenance facilities etc - aviation operators and businesses. If you put his clause in your browser and read it, you'll even find examples of a mythical Bus Air Chart and Bush Air Maintenance Services.

 

We fall under Self Regulatory Bodies where there is a more formal document trail; we have to do a similar job to the one DWF quoted, and at local aerodrome, local club, local FTF level, the SMS Management can be based on size.

 

Here are the links I previously posted which lead to ICAO document 9589.

 

This morning I found additional reference on the Department of Infrastructure site where DIT announced that under their ICAO obligations they were required to maintain a State Aviation Safety Program. I've posted the links below, and these links eventually go down to CASA and its SMS section.

 

There will be more I haven't yet picked up, but I don't have time to check.

 

What I would be interested to hear from you Alfa, regarding the flysafe link (third one down) is whether as a board member you were working to the job description in that document?

 

WX047 August 1, 2013

 

Department of Infrastructure & Transport

 

DIT posted this statement in 201. There is a link from this link

 

The International Civil Aviation Organization (ICAO) now requires member nations to produce a State Safety Program.

 

http://www.casa.gov.au/scripts/nc.dll?WCMS:STANDARD::pc=PC_100396

 

Department of Infrastructure & Transport

 

This link provides some detail, and another link to the CASA site regarding SMS for various operations such as airlines, charter operators, maintenance operations, aerodromes etc.

 

State Safety Risk Management

 

http://www.infrastructure.gov.au/aviation/safety/ssp/chapter_2.aspx

 

“The Deed of Agreement between CASA and Recreational Aviation Australia, Inc. requires a Safety Management System to be in place”

 

This is confirmed by the following CASA document:http://flysafe.raa.asn.au/regulations/casa_sport_aviation_handbook.pdfThe document spells out board member obligations:

 

An SMS Manager is required by CASA to meet its obligations to ICAO

 

This CASA link calls up ICAO document 9859 http://www.casa.gov.au/scripts/nc.dll?WCMS:STANDARD::pc=PC_101001This link to ICAO 9859, calls up a Manager - http://www2.icao.int/en/ism/Guidance Materials/SMM_3rd_Ed_Advance_R4_19Oct12_clean.pdfOn Page 168, Table A SMS Element says:Establish a key person/officer responsible for the administration and maintenance of the SMS.On Page 175, Appendix 1 there is a sample Job Description for a Safety Manager

 

 

[AlfaRomeo]

TP, I think you will find that we are a lot closer on this than others may deduce from our "discussion". We both agree that RA-Aus needs a Safety System and in my 5 minutes on the Board, we signed off on a Safety System that CASA was pleased to give us a tick for. The full Board, with the exception of Myles Breitkreutz (who, ironically, judged it not critical he attend), underwent an intensive Risk Management workshop that was sponsored by CASA and would have been paid for by CASA if the Board hadn't taken forever to get around to doing the workshop. That sfa had since happened with the roll-out of the RA-Aus System remains beyond my influence. It is now, as it has been since February 2012, in the hands of the Board.

 

There is no doubt that every enterprise, to be successful, needs to operate systematically. A system, as you know, can be summarised along the lines of input, processing and output, with a feedback loop to continuously correct and improve the process. This applies to every facet of an operation. Nobody has argued on here, that I know of, that RA-Aus does not have safety obligations. No smart thinking person would argue that those obligations could be met other than systematically. For a system to function well, it needs good fundamental design, sound introduction and managed for continuous improvement based on data feedback.

 

Then we come back to the question of Scale. You seem content that a one-man FTF would run a different scale of Safety System to an airline. So lets look at a big operation in a high risk industry. A mining operation of one of our big two miners, BHP B or Rio Tinto, typically involves assets in the range of $1 billion +/- a few hundred million. Typically, they can directly employ of the order of 1,000 people on site plus a considerable number of contractors. Each such site would have a manager dedicated to the Safety System and he/she would typically have an assistant. This is a support not a line function. The responsibility for the sound, effective operation of the Safety System is with line managers - not the Safety Manager.

 

So, how about an operation the scale of RA-Aus? RA-Aus has assets of less than $2.5 million and a staff of 15. A permanent, full-time Safety Manager in an operation of that size is, as a professional organisation specialist might put it, "nuts". What's worse than the level of overkill is the adverse effect of that role on the line functions of Operations and Technical. But you've heard enough from me on that score.

 

It is fair that you could point out that the 3,500+ aircraft with a value of somewhere approaching $200 million are the subject of the RA-Aus safety system as are the 10,000 pilots and perhaps up to a similar number of passengers and perhaps 10 times that number of people exposed to the overflying by RA-Aus aircraft. But, we already have an Ops and Asst Ops Managers looking after these Pilots and the 200 odd FTFs and we have a Tech and Asst Tech Manager with specialist contractor backup looking after aircraft construction and maintenance safety standards.

 

In an organisation the size of RA-Aus, the GM ends up with accountability for everything. That is why when you have inadequate performance in that role that everything goes sub-standard and progree is indetectable. Each line Manager has Safety as a key component of their accountabilities. In my experience this is emphasised by being put as the 1st accountability in their role descriptions. All these people are pretty busy and have to cover a very wide range of disciplines. They do need the support of an experienced aviation safety professional to design and implement and subsequently AUDIT the safety system if it's going to do more than fill a lot of shelves with paper. But, the practice of safety management is the job of the Ops and Tech Managers - it is their very reason for being - it is what they do.

 

 

[turboplanner]

If a regulation calls up an approved helmet to be worn by a motorcycle rider, that’s it; you don’t have the option of saying “Well that’s expensive, so I’ll just dodge the cars instead – that’s safe.”

 

Alfa, we are not close at all; even though I’ve provided most of the documents for you, you’re still going off dodging cars.

 

You and dodo are both agreeing on the way we operated in the prescriptive legislation era, but the Governments moved away from this in the 1980’s.

 

I’m not yet again going into the history of why things changed and the way we have to do things now if we want to protect ourselves, that’s your risk.

 

Alfa, you didn’t answer my question on whether you complied with the board member job description spelled out in the Sport Aviation Self Administration Handbook 2010, which is still a current document. If you didn’t, this could put you at considerable risk if a claim came in.

 

Here again is the link

 

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

 

The Handbook was published in June 2010, and is still applicable, as I mentioned.

 

It spells out CASA’s interpretation of Self-Regulation

 

It discusses Risk Management

 

It discusses the mandatory SMS, and says this is consistent with:

 

·ICAO

 

·CASA

 

·CAANZ

 

·Transport Canada

 

·FAA

 

·CAA UK

 

So the stories that we don’t have this BS in New Zealand or USA, probably mean “yet”

 

On Page 24 is the Incoming Board Checklist, and Item 4e shows the board member’s duties in relation to the Safety Management System framework.

 

On Page 25 is the checklist for board members during their term, and Item 4a says “Ensure the organisation’s SMS framework is up to date.

 

The board of Recreational Aviation Australia Inc. is a Board of Management, not a Board of Directors, which seems to confuse people daily, and lead to secrecy, and a lot of the other issues which, particularly now, are occurring.

 

These people are required to MANAGE the day to day activities of the Association.

 

With the board members duties spelled out clearly for anyone to see on the CASA website, and given that these people are elected to manage, let’s see what we do know.

 

From June 2010, RAA was under a safety obligation to set up an SMS and appoint an SMS Manager.

 

They could have called for volunteers, hired a Consultant, or a number of other things because the CASA/ICAO system is written for performance rather than by prescription.

 

There was great urgency for this, since in the world of Public Liability claims, from the minute the booklet was issued to RAA, it was operating without a safety system.

 

So the correct management action for protection of members’ finances at that time would have been to have grounded all aircraft and excluded members of the public from all venues until such time as an SMS existed. This is not as bad as it sounds; that may have taken one or two days with the right document format.

 

That wasn’t done, and although, as we saw above, the SMS was the responsibility of the board members, I was told they gave the job to Steve Bell.

 

Nothing happened.

 

In 2012, as Alfa has been referring to, the board members made a superfluous decision which appears to centre on the basic shell document Steve had previously come up with, which as we’ve seen was not an SMS system. They then gave it to Steve Tizzard.

 

Nothing happened.

 

Then came 2013 when things became a little more urgent.

 

The outcome of this is that all board members since June 2010 could be subject to claims arising from crashes since that date. Some of these will still be in process, moving towards the Courts in the next two to four years. This also applies to crashes occurring now and in the future until a working SMS exists.

 

Since you can’t hand off a Tort, it makes sense that you don’t try to hand off your Duty of Care, particularly if it was your job. In this respect I don’t believe either Steve Bell or Steve Tizzard would have any legal responsibility.

 

I must apologise for using a draftsman’s term regarding documents; “calls up” has the same meaning as “requires”

 

So all these board members could face claims, and since their obligation was known to them, could also face criminal prosecution.

 

While this is a matter for them, inevitably members’ money will be involved, rightly or wrongly.

 

The clock is ticking, and that was the urgency Ed Herring faced when confronted by CASA – the only dates which count are June 2010, and the date there is an SMS operating.

 

So that is the issue with, in 2013, leisurely thinking of employing a consultant who might get it right and something might happen this year or next – members are carrying a time bomb.

 

If CASA were to get into this saga and perhaps agree to a time delay, then the CASA people involved in that also take on their own risks.

 

 

[oracle1]

Just cant believe the hoax that CASA was going to shut us down is still being flogged to justify the MB appointment. It's like ground hog day in here, move on, if the SMS is a problem appoint someone with due process followed who is competent to do the job. END OF STORY.........

 

 

[DWF]

I have just checked the RAAus web site.

 

There is an Executive update and an SMS update!

 

The sky has not fallen in.

 

The Board has had a meeting with CASA and it seems a new plan to implement an SMS has been agreed.

 

This is getting better than Blue Hills (remember that?). I await the next exciting episode.

 

DWF

 

 

[Guest Andys@coffs]

for clarity

 

its in the members section then CASA then 2013.........

 

There are 2 updates

 

Andy

 

 

[Spriteah]

TP. Although I have said this before I will again.

 

RAAus are not mandated to have a full time Safety Manager. CASA has stated this to the board. Do not take that to mean we won't, we might, but we do not need too. Read and print all the links you like. CASA interpretation (which is the one I care about) has been clearly stated.

 

Regards,

 

Jim Tatlock.

 

 

[DWF]

I have just had another look at the 2012-13 Deed of Agreement with CASA. It was signed on 25th Sept 2012, so, if the Deed runs for 12 months, then it is still the current Deed.

 

13.1 of the Deed says "The Organisation" [RAAus] "will ensure that the Specified Personnel will conduct the Schedule B Functions in a diligent and competent manner and will comply with this Deed."

 

'Schedule B - General tasks and functions' lists the Compliance Functions, Standards Functions and Safety Promotion Functions that RAAus has agreed to and CASA has paid for.

 

1.1, the Definitions section of the Deed, says

 

"Specified Personnel for the Schedule Functions means those persons named in Item 3 of Schedule A.

 

The Deed is a 24 page document but only 23 pages are shown on the RAAus web site.

 

Page 17 is missing. Page 17 contains (part of ) Schedule A.

 

So, Item 3 of Schedule A lists the Specified Personnel who are to carry out the Functions specified in Schedule B.

 

But page 17 is missing.

 

Is this by chance or can we read something else into it?

 

As far as I can ascertain, none of the Milestones (regarding an SMS) on Schedule D have been achieved.

 

DWF

 

 

[turboplanner]

TP. Although I have said this before I will again.RAAus are not mandated to have a full time Safety Manager. CASA has stated this to the board. Do not take that to mean we won't, we might, but we do not need too. Read and print all the links you like. CASA interpretation (which is the one I care about) has been clearly stated.

 

Regards,

 

Jim Tatlock.

If you don't want to read the regulations you are bound by, then consider this.

 

If you were a Driving instructor and you were teaching a person with a Learners certificate how to drive, and the person was speeding, and you said that was OK, he could slow down after a kilometre or two, but he skidded into an oncoming car due to the excessive speed, the learner would have had the approval of the trainer, but both would be charged.

 

The fact is Recreational Aviation Australia Inc. do not have a Safety Management System.

 

In a multi million dollar claim the question asked will be: Does Recreational Aviation Australia Inc. have a compliant Safety Management System?

 

 

[AlfaRomeo]

Perhaps to wrap this one up, a quick read of the RA-Aus website would show any member that the SMS is now being progressed by the Board to CASA's satisfaction. CASA would not be happy it is late but content, so they say, that it is now progressing satisfactorily. No doubt they will keep a close eye on its implementation.

 

 

[turboplanner]

Yes, we were aware of that Alfa, it was the implication of that, with CASA personnel now in the bowl of soup with the RAA board members down the years, we were talking about.