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CASA Annual Report 2002 03 Part 4: Corporate governance

Part 4: Operational performance report

Output group 2: Aviation safety compliance

Description

CASA secures compliance with Australian aviation safety legislation through stringent entry control procedures, a national surveillance program undertaken by way of field and 'desktop' audits, and the appropriate use of enforcement measures.

Planned output

Compliance with Australian aviation safety legislation is secured through effective education, surveillance and procedurally fair enforcement.

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Context for 2002–03

  • Continuing moves towards an industry culture that encourages participants to take their full share of responsibility for aviation safety and a regulatory model based on the 'safety maturity curve'.
  • The need to develop a strong safety intelligence capability, with reliable tools used in the context of a robust risk model and to consolidate risk-based surveillance as an effective complement of scheduled auditing.
  • CASA's progressive introduction of system safety auditing across all sectors of the aviation industry.
  • The need to respond to surveillance and enforcement issues identified through CASA's own review processes and through external scrutiny.

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Highlights of performance

Highlights of CASA's performance during 2002–03 include:

  • 99 per cent of total scheduled audits completed
  • field staff able to focus on more safety significant tasks through revised application assessment processes
  • tools developed, and staff trained, for greater regulatory consistency
  • efficiencies achieved through the application of electronic technology to reporting.

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Performance report

Performance measure Target Result

Number of low-capacity regular public transport (LCRPT) operators visited to introduce safety management practices and current surveillance processes, against project plan.

95%

81%

This initiative began in mid 2002 and visits were planned to occur over a two-year period. By the end of 2002–03, we had completed 81% of the total number of visits planned.

The visits program has applied only to LCRPT operators managed by CASA's Area Offices, as those managed by our Airline Offices have already been introduced to safety management practices and systems surveillance. The initiative was established when CASA surveillance practices were being revised and developed. As well as an added opportunity for industry education, the initiative has provided valuable experience that CASA is using to bed down effective surveillance procedures.

We are reviewing the need for the initiative now that safety management systems training is available to both staff and industry as part of our safety promotion program, and operator case management is coming on stream through the Regulatory Reform Program Implementation.

The new Surveillance Procedures Manual will provide detailed information on systems auditing methods that operators will be able to access through the Internet. An educative video, to be released early in 2003–04, will provide additional guidance.

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Performance measure Target Result

Number of low-capacity regular public transport operators audited using system safety audit techniques.

90%

100%

All LCRPT operators were audited using system safety audit techniques. These audits have now been subsumed into normal, everyday surveillance activity following an initial linkage with the above education visits initiative.

A Surveillance Review Team has been established. The lessons learned from the LCRPT initiative and the writing of the Surveillance Procedures Manual will be part of the ongoing review for continuous improvement of our surveillance practices and procedures.

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Performance measure Target Result

System established for monitoring and improving consistency of informal enforcement action.

System implemented and functioning

All elements of the system established; implementation to proceed early in 2003–04

Our new procedures will ensure CASA's national coordinator of enforcement receives reports on all informal enforcement action.

A simpler, clearer report and changes to the database will yield more consistent and comprehensive information for monitoring use of informal enforcement, while electronic submission of input and automatic data entry will make the process more efficient.

The new arrangements will be implemented early in 2003–04.

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Performance measure Target Result

Level of consistency and accuracy of Safety Trend Indicator completion by CASA inspectors.

60%

No systematic measurement in 2002–03

CASA is building the robustness of the Safety Trend Indicator through continuous improvement of the data collected and the data collection process.

While there was no systematic measurement of performance against the target, indications are that we achieved a great improvement in consistency and accuracy of data input with introduction of Safety Trend Indicator Version 1.1 in an electronic 'smart' form. More work is underway to enhance the usefulness of information collected.

As well as the 'smart form' interactiveness, use of the form has been enhanced by including refined instructions on its completion, and by providing further guidance material through issuing a Compliance Management Instruction.

Data processing has been made more efficient with automatic data entry to the Safety Trend Indicator database. Additional efficiencies will be achieved early in 2003–04 through database linkages reducing text input required for the form.

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Performance measure Target Result

Request for corrective action measures defined and implemented.

95% complete

95% complete

We changed the way reasons for issuing requests for corrective action are specified, to reflect the four systems 'attributes' CASA inspectors use in their audits to verify the effectiveness of an operator's systems and processes.

Specifying the relevant attribute - 'management responsibility', 'infrastructure', 'process in practice' and 'monitoring and feedback' - will make for better traceability of causal factors.

The new approach will be implemented in 2003–04 as part of a comprehensive set of new procedures to improve handling and enhance the effectiveness of requests for corrective action. Procedures have been documented in the new Surveillance Procedures Manual.

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Performance measure Target Result

Core competencies for CASA inspectors identified and training gap analysis of inspectorate complete.

95%

Not measured

In August 2002, CASA considered the report of a high-level working group into the learning and development needs of our inspectors. In response to findings in that report, CASA decided to focus on:

  • implementing the CASA Learning and Development strategy
  • developing an 'education partner' arrangement to enhance our capability to meet identified learning and development needs
  • developing and delivering a Graduate Certificate in Aviation Safety Regulation as a foundation qualification for CASA inspectors.

Delivery of existing training programs on our national training calendar is aligned with development of core capabilities for CASA staff.

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Performance measure Target Result

Operational policy and guidance material requirements identified, developed or refined, and implemented.

Ongoing

Ongoing

The Surveillance Procedures Manual was comprehensively rewritten to reflect our move to system safety auditing, incorporate best practice and address problems raised in audits of CASA's surveillance practices by the Australian National Audit Office and KPMG.

Training has been conducted in all field offices so inspectors are familiar with the new manual and have common understandings of what the procedures entail. This will be supplemented with targeted training and mentoring/champion arrangements during a phased implementation.

We are now working through a number of issues raised in final consultations with the unions to enable the phased implementation of the new manual by the end of 2003.

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Performance measure Target Result

Information technology/database options for improved repository of policy, guidance and precedent information identified, and information requirements and protocols developed.

60%

Deferred

CASA plans to improve the repository of information supporting standardisation and consistency in our compliance activities.

During the year we decided to defer developing a dedicated compliance database until a wider examination of knowledge management options within CASA has been undertaken as part of the CASA Improvement Program.

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Performance measure Target Result

Results of internal survey to assess usefulness of initiatives to facilitate consistent regulatory decision making.

Survey results confirm usefulness

Survey deferred

We deferred the survey pending implementation of a number of these initiatives.

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Performance measure Target Result

Percentage of audits achieved against the audit plan for the general aviation sector.

100%

99%

CASA completed 714 of the audits scheduled for general aviation for 2002–03.

All audits were completed in accordance with planning, with the exception of two in the 4th quarter. In both cases we had conducted the audit of the operator, but had not finalised the matter, by the close of the year.

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Performance measure Target Result

Percentage of audits achieved against the audit plan for domestic airline operations

100%

98%

CASA completed 103 of the audits scheduled for domestic airlines for 2002–03.

All audits were completed in accordance with planning, with the exception of one audit in each of the 2nd and 3rd quarters of the year, which were deferred due to resource constraints. These audits were chosen on the basis of their relatively low risk.

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Performance measure Target Result

Percentage of audits achieved against the audit plan for international airline operations

100%

98%

CASA completed 97 of the audits scheduled for international airlines for 2002–03.

All audits were completed in accordance with planning, with the exception of two audits in the 4th quarter of the year.

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Performance measure Target Result

The percentage of audits achieved against the audit plan for aviation infrastructure and sports audits.

100%

99%

CASA completed 234 of the audits scheduled for 2002–03.

All audits were completed in accordance with planning, with the exception of two audits of aerodromes in the 4th quarter of the year, which were deferred due to resource constraints. Both were assessed as low risk and will be conducted early in the new financial year.

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Performance measure Target Result

Percentage of 'desktop' audits achieved against the Safety Trend Indicator (STI) audit plan

100%

99%

CASA completed 2863 of the audits scheduled for 2002–03.

All of the scheduled audits were completed in accordance with planning, with the exception of one audit in each of the 3rd and 4th quarters of the year.

One of these audits was delayed as it will be linked with a future special audit; the other was completed but is awaiting finalisation.

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Performance measure Target Result

Number of special audits carried out.

Not applicable

307

'Special' audits are based on safety intelligence and are planned and carried out from time to time.

Table 12: Number of special audits conducted, 2002–03

Sector Number

General aviation

279

Airline operations

18

Aviation infrastructure and sports

10

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Initiatives, developments and issues in 2002–03

CASA again had to deal with a high volume of compliance activity. The industry experienced continued volatility and adjustment in response to market pressures and restructuring, which resulted in further increases of 9 per cent in Air Operator Certificate transactions and 8 per cent in Certificate of Approval transactions within the general aviation sector. In addition, CASA's compliance staff were involved in assessments associated with introduction of the Qantas A330 fleet and the continued evolution of Australia Wide and Hazelton into one Air Operator's Certificate holder trading as Regional Express (Rex). CASA also worked with Qantas on a project relating to introducing the A380.

Despite these regulatory service pressures on our inspectors, we completed almost all our scheduled surveillance and maintained a thorough 'special' audit program, generated by both industry and other safety intelligence sources.

We undertook a range of initiatives to improve our performance as a regulator and to promote better safety approaches in the industry.

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Education

We continued a project in which our inspectors teamed with our safety promotion staff to introduce low-capacity regular public transport operators to safety management practices and the systems safety approach to surveillance. The project has involved working with individual operators to tailor safety management systems to their particular operation and history of compliance problems, and then evaluating the effectiveness of each operator's implementation in planned audits.

Surveillance

We devoted considerable effort in 2002–03 to addressing problems with our surveillance regime identified by the Aviation Safety Forum, and in recent audits by the Australian National Audit Office1 and KPMG. Common themes were the need for greater consistency, and closer adherence to policy and procedure.

1. Australian National Audit Office, Aviation Safety Compliance Follow-up Audit, Report No. 66, Canberra, 2002.

A major focus was development of a comprehensive new Surveillance Procedures Manual. The manual captures the lessons learned over the past few years and reflects best practice, agreed through a process of national discussion and review. The close involvement of CASA's area managers and team leaders, together with the opportunities given for input and feedback from field staff, have resulted in a growing level of ownership and acceptance of the procedures.

We are now working through a number of issues raised in final consultations with the unions to enable the phased implementation of the surveillance manual by the end of 2003.

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Enforcement

We commissioned KPMG to help us review the way our existing enforcement processes are applied and the way we identify, evaluate and manage risks associated with our investigative and enforcement decisions. In response to issues KPMG, and earlier the Australian National Audit Office2, raised we worked on changes in procedures, documentation and reporting mechanisms to improve consistency in our approach to informal enforcement actions.

2. Ibid

We also began preparing for the anticipated passage of legislation giving CASA a wider array of enforcement powers and introducing additional natural justice measures.

Details of our enforcement actions during the year are provided in Appendix 3.

Safety intelligence

We continued to refine the accuracy and consistency of the Safety Trend Indicator, which was developed as a risk assessment tool when we introduced risk-based auditing to complement our scheduled audit program. In addition, we commissioned an evaluation of the reliability of Safety Trend Indicator data as a basis for further work to improve this tool and determine its place in a future safety intelligence system.

In 2002–03, we began work on a risk model and, as recommended by the Australian National Audit Office and to the extent resource constraints have allowed, we also began examining the range of data available to us and assessing its feasibility for integration into a comprehensive safety intelligence system.

As a first step, a consultant is looking at the scope for reliably identifying trends and patterns from Electronic Safety Incident Reports provided by Airservices Australia and Air Safety Incident Reports provided by the Australian Transport Safety Bureau, as well as from the Significant Defect Reports provided by operators.

We moved to make more effective use, immediately, of Electronic Safety Incident Reports by setting up a workflow database to systematically manage and record handling.

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Where to from here

Surveillance

2003–04 will see the phased implementation of CASA's new Surveillance Procedures Manual.

With the introduction of the new Civil Aviation Safety Regulations, passenger-carrying charter will be treated the same as regular public transport. Systems-based auditing is already being applied to large charter operations and will be formally introduced across that sector when the Surveillance Procedures Manual is released.

Enforcement

In 2003–04 we will be implementing the new Enforcement Procedures Manual, which addresses problems with exercising existing enforcement powers that have been identified in recent audits.

The new manual will also incorporate new processes and procedures to deal with the changes to the civil aviation safety enforcement regime contained in the Civil Aviation Amendment Bill 2003, currently awaiting Royal assent.

The changes will give CASA new enforcement powers, including a protection scheme to encourage voluntary reporting, enforceable voluntary undertakings and a demerit points scheme to deter repeat offences. The new provisions will also provide for an automatic stay of most CASA decisions to suspend or cancel licences and a requirement for Federal Court review of immediate suspension action undertaken in circumstances of serious and imminent risk.

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Regulatory reform implementation

CASA's inspectors will be increasingly involved in implementing regulatory reform, by preparing themselves, through participation in training, and helping industry, through case management strategies.

First Australian A330 proving flight

A core team of five Aviation Safety Compliance personnel were on board the first proving flight in Australia of an Airbus A330 to observe all aspects of the operation.

Proving flights demand that airlines demonstrate that all areas can work together to produce a safe operation that also complies with the legislation. To create a realistic flight environment, passengers with both check-in and carry-on baggage are required to be on proving flights. On the A330 flight, the 115 passengers were Qantas staff and their families.

A number of scenarios were presented to the operating crew throughout the December flight to enable CASA to make an assessment. These scenarios included preparing for an emergency evacuation, passenger incapacitation, and aircraft component defects.

Qantas passed the test and was re-issued with its Air Operator's Certificate. The A330 took part in its first scheduled flight on 2 January 2003, and is being praised by both Qantas staff and passengers.

The CASA team has also received praise. Qantas was impressed by the team's highly professional approach and evident commitment to aviation safety.

David Klein and Jean-Phillip Cottenceau

CASA Senior Airworthiness Inspector David Klein (left), pictured with Jean-Phillip Cottenceau, from Airbus, in Toulouse on 6 December 2002 at the issue of the new Qantas A330's Certificate of Airworthiness.

New technologies conference

Some 50 members of the aviation industry, including staff from Qantas, Virgin Blue and Impulse Airlines, attended a 'new technologies' conference organised and chaired by CASA in September 2002.

The aim of the conference was to familiarise staff from the airlines with the approval processes for a range of new technologies planned for introduction. These new technologies include head-up displays (HUD), electronic flight bags (EFBs), new computerised instrument approach design and development, quiet climb systems (QCS), vertical situation displays (VSD), navigation performance scales, global landing systems (GLS), integrated approach navigation, surface guidance systems, enhanced vision systems and synthetic vision systems.

CASA explained the regulatory issues involved in introduction of new technologies and the general requirements to be met. The industry participants gave CASA invaluable feedback on the industry's expectations of CASA in the process. The conference gave everyone the opportunity to raise issues and discuss solutions.

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Fatigue Risk Management Systems

CASA began a trial of an alternative approach to managing fatigue within the general aviation industry at the beginning of 2001, with the aim of replacing the many exemptions to Civil Aviation Order 48 that had evolved in response to industry requirements, but had no scientific basis.

The trial applied the methodology of emerging science on fatigue issues, particularly the work of the Centre for Sleep Research at the University of South Australia, to form the basis of a Fatigue Management System. A total of 22 of these systems were approved during the trial.

Earlier this year the trial was validated by an independent review, and the concept has begun to gain widespread acceptance within the industry. There are now 26 operators holding exemptions from Civil Aviation Order 48 on the basis that they now manage fatigue to an appropriate standard. An additional 17 operators are in the process of developing a Fatigue Management System for their own operations.

Work being done within the scientific community around the world is providing CASA with a solid basis for continuing down this new path. In particular, accepted risk assessment and management processes and procedures are now being applied and this is reflected in the revised name, Fatigue Risk Management Systems (FRMS).

We are continuing to work closely with both the industry and the scientific community to develop the concept to a mature level, which will ultimately be the basis for world's best practice in this area.

The airline sector is now commencing development work on FRMS for their operations. It is becoming quite evident that many operators are seeing the benefits of approaching the management of the fatigue risk in their operations in a systemic manner. CASA is now proposing that these systems become part of a new rule set.

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Working with the balloon Industry

During the year a joint CASA-industry technical committee was set up to overcome problems of non-compliance in Australia's rapidly growing commercial ballooning industry. The Committee will improve CASA's communication with the industry and follows the establishment of the Professional Balloon Association of Australia (PBAA).

There are now about 30 holders of Air Operator's Certificates for commercial ballooning, including some who are among the biggest adventure tourism operators in the world. The sector carries more than 100,000 passengers a year.

CASA completed an industry-wide audit undertaken over a period of 18 months. Issues arising from the audit have been referred to the technical committee.

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