CEO puts flying training in the spotlight
Speech to the Royal Federation of Aero Clubs Australia
24 March 2004
It is a great pleasure to be with you.
It goes without saying that aero clubs have been the backbone of GA training for longer than most of us care to remember.
A gathering like this shows me that you are committed to high standards of training, and to support that training by promoting and reinforcing a strong safety culture, a less tangible element in the make-up of a competent and professional pilot, but one that I believe is just as important as the formal training he or she receives.
I have been in the job at CASA for nearly four months. In that time
I have done a lot of listening, a lot of communication, a lot of consultation,
both with industry, and within CASA.
There have already been some changes and others will come along more slowly, but they will come. It won’t be change for the sake of it, it will be change needed to build a better and more effective CASA that focuses on its core safety-related functions as required by the Civil Aviation Act.
For those of you who don’t know me, I am a professional pilot, airforce trained, in which I spend 20 years with a strong emphasis on training. My final RAAF appointment, in the early eighties was as CO CFS. After that, I managed a corporate jet operation whilst developing a safety consulting activity. In the airline sector, I have managed the transition of Kendell Airlines to high capacity jet operations. Most recently I have designed a Safety Management System for Virgin Blue. I fly as often as circumstances will let me, and I believe it is helpful to bring to my new responsibilities the perspective of an Aviation practitioner.
In the recent past I have had the role of independent chair of the Aviation Safety Forum, and as the ‘industry advocate’ in relation to the new regulations.
I of course no longer fill these roles, but the experience has meant that I come to CASA with a built-in bias in favour of the merits of consultation and communication, and with a fairly comprehensive exposure to the industry and its thinking.
CASA’s relationship with the aviation industry is a cornerstone for our future success. One of my highest priorities is to work towards establishing the best possible professional working relationship between CASA and the aviation industry and also between myself personally and industry players.
Each month I meet with about ten aviation organisations or individuals to listen to a range of perspectives relating to CASA and its functions. There is an open invitation for you to participate in that process.
In a broad sense, I see aviation safety as a shared responsibility between CASA and the industry. We need an industry that is willing and able to meet its part of those safety responsibilities. And we need a CASA that is both independent in the discharge of its safety surveillance and enforcement obligations, but at the same time is responsive to the needs of the industry, and is prepared to assist those in the industry wanting to do the right thing by, among other things, by being responsive, by genuinely consulting, by showing flexibility, by providing simpler rules, by listening, by educating, and by operating in an atmosphere of mutual respect.
And we also need an industry which can develop and grow, and not be constrained by rules that don’t do anything for safety.
As far as formal consultation processes are concerned, the existing industry consultative bodies, the Aviation Safety Forum and the Standards Consultative Committee will remain in place and be strengthened. But it is not enough to set up mechanisms to facilitate communication and exchanges of ideas. There needs to be a cultural environment that welcomes industry views and regards members of the industry as a useful and valued source of information. This is consistent with statements I have previously made regarding the extensive reservoir of technical expertise that resides in industry, with people such as yourselves. It is a resource that must not be allowed to wither, but rather must be valued, nurtured, expanded, and that is something I am keen to support.
As far as CASA is concerned, my view is simple. Our focus should be on core safety-related functions. And in executing that focus operationally, we should be looking for deliverables that have a direct safety benefit and permit industry to deliver a safer outcome.
Among those deliverables are rules that are simple and easy to follow. As many of you will know we are currently devoting substantial resources to rewriting virtually all of our regulations, with the theme ‘Safety through Clarity’. A lot of real progress has been made in updating the rules and making them simpler, and our people have been working very hard to meet the deadlines previously set.
But it is critically important for the future of Australian aviation that we get absolutely the best set of rules we can. There are few chances to do a major re-write and if we don’t make the most of this opportunity it may be some time before another comes along. So we need to get it right, and with that in mind I have put rule development in some major areas on hold for review and more industry consultation. I would prefer to achieve the best outcome, rather than meeting deadlines with something that is less than the optimum.
In particular, I have asked that Part 91, the foundation part of the operational rules, be tested by the Standards Consultative Committee, to ensure that each proposed rule can be justified on the basis of addressing known or likely safety risks. I have also asked the SCC to revisit the question of Part 135.
In relation to our other core safety-related functions such as surveillance and education, I will be looking for a similar approach – that is, our activities should be targeted at known or likely safety risks.
This approach will be rolled out over the rest of this year and will become evident to all industry participants. For example, I have asked that our General Aviation audit program include surveillance that targets likely risks by industry sector and where relevant, geographic area.
We at CASA have to recognise that a part of our operations is in the provision of charged services to the industry, and for that activity there are clients who, like in most other spheres of business, are entitled to a high quality of service, and should be treated with professionalism, and with proper consideration and courtesy. I have passed that expectation, personally , to most CASA staff.
But we still need to be independent and unbiased when we come to enforcing the regulations.
The better we get, the less you in the industry will have to complain about, and for those of us who tend to be at the receiving of complaints that has to be a great incentive in itself to be better.
But we also need to improve the way we handle complaints we do get, so that you in the industry can see how your concerns are being handled, that they are being addressed in an objective, open and transparent manner. This is a reflection of my intention that the CASA of the future must be, and be seen to be, fair and accountable. One of the fourteen Directives I issued on 3 March addresses the need to develop a transparent complaints handling mechanism.
We need to constantly monitor our costs.
In relation to enforcement, the recent amendments to the Civil Aviation Act have introduced a number of new enforcement measures, focussing on achieving a wider and more appropriate mix of regulatory tools. These will allow CASA the flexibility to take a more measured response, rather than only having only the options of ‘extreme prejudice’ or a slap on the wrist. The new regulatory tools include an automatic ‘stay’ of suspension or cancellation decisions not involving an immediate risk to air safety. There has been an introduction of a demerit points system for more minor breaches of the regulations.
The new provisions also enhance procedural fairness. People affected by CASA’s administrative decisions will have the opportunity to argue their cases before an independent arbiter, either the Federal Court or the Administrative Appeals Tribunal. The aim is to focus firmly on fairness and natural justice without in any way restricting CASA’s ability to take action on safety breaches. In my view, the balance is a good one. There has been no limitation on CASA’s ability to take appropriate safety action, but there is increased flexibility in terms of penalties, and greater protections in terms of procedural fairness.
I mentioned earlier the need for an objective approach in identifying real safety risks. Indeed, there is a sound argument that all of CASA’s core safety-related functions should be driven by analysis and knowledge of past and likely future safety risks.
And that’s just what we’re going to do.
We have already commenced a broad review of the safety of the Civil Aviation
system. The review is intended to identify the major risks, by sector, and
will test CASA’s operations against those risks. Industry will be invited
to participate, for example, through analysis and, ideally, by contributing
safety data.
In fact, I have announced today, to coincide with your conference, the first
outcome of this program. The first module of the review has been an analysis
of data supplied by the ATSB, of the findings related to GA fatal accidents,
over a ten year period. Perhaps not surprisingly, human factor issues show
up as the major problem.
That leads me fairly directly to training, which I shall touch on shortly.
I am particularly concerned about the large number of fatal accidents that have ‘ uncontrolled flight into terrain’ as a finding. Generally, there is a tendency to focus on individual accidents, or perhaps accident rates, but without necessarily taking the analysis further to see if there are trends, or indications of systemic problems. This initiative is intended to take us behind the immediate statistics and focus on probable causes, and their possible linkages. This ties in with the idea that the regulations we develop need to be more focussed on identifiable safety issues. There is clearly diminished value in devoting resources to making and enforcing regulations which may have theoretical appeal, but in practice do little for safety. As I said earlier, the same could be said for our compliance activity.
And a question for you. Are we sure we know what we are talking about when we are addressing safety? There is a need for an objective approach to identifying real safety risks. Indeed, there is a sound argument that all of CASA’s core safety-related functions should be driven by analysis and knowledge of past and likely future safety risks. We have not had sufficient focus on this in the past and we are in the process of doing something about that.
To support an increased focus on ensuring that our operational decisions are based on objective analysis, I have established in CASA , in the Office of the CEO, a new position of Strategic Research Adviser, to undertake and coordinate practical research initiatives into aviation safety.
In the last few years I have been impressed by the quality of the new generation of aviation professionals entering the industry, including many with aviation technical or management tertiary qualifications. These are likely to be the future leaders of the industry, including CASA. To link our need for better analysis on which to base our decisions, and to encourage and support some of our brighter aviation talent, I have approved the offering of four scholarships, each to the value of $25,000 to be awarded to bright postgraduate students in aviation studies and related fields to undertake practical research in aviation safety.
I believe these are important initiatives where CASA can show some leadership.
But the value of initiatives such as these can be dramatically multiplied by
working in cooperation and collaboration with industry. I hope you share this
view and that it will be possible for us to work together on safety-oriented
projects to achieve meaningful safety outcomes. This might be from something
as simple as aero clubs proposing useful topics for research projects, right
through to jointly working with us on a major exercise.
And a word or two on training. CASA’s biggest single Division is called
Compliance. One of our smallest is called Safety Promotion. In an ideal world,
wouldn’t it be great to see that reversed. With a few compliance and
enforcement people to keep an eye on the cowboys that are inevitable in any
form of human endeavour, aviation included, and most everyone else focussed
on training and education, and the promotion of a safety culture that regards
any unsafe practice as simply unacceptable. Well, we are not yet at that
stage. But I have in mind a number of initiatives to get the momentum going.
The idea is to take a look at the quality of aviation training, and where there are deficiencies identified, or where good programs can be made even better, to do something to assist. I want to assemble a panel of senior instructors and CASA people to collaboratively work together to establish practical ways to best assist the flying training segment of the industry to do even better. They would advise me on action and initiatives we could take, and the nature and quality of outputs we should be looking to achieve.
One of the things the joint panel could look at, for example, might be the preparation and issue of a revised generic Instructor’s Handbook, a modern version of the old “Pub 45”. If it went ahead, content would be based on joint industry/CASA input.
Another possibility for the panel to look at might be the establishment , over the next year or so, of a number of dedicated flying training specialist positions at CASA offices around Australia. These would be experienced professionals who would devote 100% of their time to supporting and enhancing flying training programs, including those provided by aero clubs. I am sure there will be other possible initiatives like these that the panel can consider.
Within this general initiative to support and develop flying training and the instructors that provide it, we have worked up a specific proposal which we would like to put to you for your reaction. It has been developed by Kim Jones, who heads up our Safety Promotion program and who will be speaking with you later today. I don’t want to steal Kim’s thunder, so I will simply invite your interest in what Kim has to put forward, and I will welcome your reaction to it. We are not going to force anything on to you. As I said, we want to work with you and this is merely one way to move forward, at the minimum I would hope it would act as a catalyst to stimulate further thinking.
In conclusion, can I tie all this together by saying that the CASA I see evolving over the next few years is an organisation with a clear understanding of and responsiveness to government policy directions and decisions on aviation and with a clear focus on core safety-related functions.
It is a solid agenda, but I believe we can achieve it. But we will only achieve it with the cooperation and support from the industry, in general, and the organisations you here today represent, in particular. I would like to hope we can count on your support.
Thank you.
Bruce Byron
Chief Executive Officer
24 March 2004