CASA: The regulator's role in meeting the training goals: How we can help?
CAPA Aviation Training & Safety Summit
Brisbane, 3 August 2016
Robert Walker Stakeholder Engagement Group Manager
Distinguished guests, ladies and gentlemen,
When I flew up here this morning my mind wandered a little and I reflected that the aircraft I was on, (a Boeing 737) looked superficially like the Boeing 727 T-jets that captivated me when I was an aviation-obsessed primary school boy.
I’ve changed, and so has aviation, and it’s useful for our sense of perspective to remind us of how much change there has been.
In 1965, before I was at school, admittedly, 4 million Australians travelled on domestic passenger flights. By comparison, 4.87 million passengers flew domestically in May this year.
And more than 60 million passengers flew on Australian domestic routes in 2015, more than twice the 1996 figure. Put that another way, for every person holding a boarding pass in 1965, there were 15 last year.
And there’s no sign of that growth stopping. Air transport continues to boom, as two sets of figures released last month demonstrate.
Airbus released a forecast at this year’s Farnborough air show predicting that, over the next 20 years, the world airliner fleet will grow from 19,500 commercial aircraft (that’s aircraft with more than 100 seats) at the end of 2015, to almost 40,000 by 2035.
It calculated the total industry spend on aftermarket services, such as training, MROs, and navigation services software will reach three trillion US dollars, or about four trillion Australian dollars.
Today there are about 200,000 active airline transport pilots in the world. The Airbus Global Service Forecast predicts this will double, and then some, to 450,000 pilots by 2035.
Of course some of these pilots will retire between now and 2035, so Airbus predicts a training need for 560,000 new pilots over this period.
It also predicts demand for 540,000 new engineers to service airframes, engines, and components.
Boeing’s seventh annual pilot and technician outlook, published last week, is in the same vicinity, with slightly higher numbers. Its 20-year forecast is for 617,000 new airline pilots required and 679,000 engineers.
Boeing’s cabin crew outlook predicts that 814,000 new cabin crew will be needed over 20 years, or about 40,000 per year.
In the Asia-Pacific region Boeing predicts demand for 248,000 new pilots-40 per cent of the global demand – and demand for 268,000 new engineers.
Airbus expects the Asia-Pacific region's share of world GDP to rise from 31 per cent today to 39 per cent by 2035. It’s where growth will be the most intense.
Gloomier economists will tell you that although Australia is part of the Asia Pacific region its fundamental problem is that it’s on the edge of that region, Maybe, but in aviation terms Australia has fundamental advantages for providing services such as flight crew, engineering and cabin crew training.
- We’re a continent of benign weather, uncrowded expanses and mostly flat topography, all of which are ideal for flight training.
- We’re a country which has a long aviation heritage, and a long heritage of taking aviation safety seriously. Our air transport operators and our national regulator are well- regarded internationally and our safety record in air transport is impressive.
- We’re an English-speaking yet multicultural society, in which people from anywhere in the world can feel at home. Our higher education sector already trades on this advantage.
That, in a nutshell is why I think Australia is well-placed to take part in and benefit from the projected Asia Pacific Aviation boom, and the projected global aviation boom.
What do these massive numbers and the changes they will mean from a regulator’s point of view?
First, it frames the question of ‘how we can help?’ How can we best help in a boom is a very different matter to what we should do to help an industry in a bust.
The figures deliver a clear message: regular public transport aviation, the big end of town, doesn’t need our encouragement to grow. It’s going to get much bigger, and much busier, and that growth is a safety challenge of the first order.
There’s a simple lesson to be drawn from figures that suggest a doubling of passenger aircraft numbers: if accident rates stay the same - that is to say at historically low levels - there will be twice as many crashes.
So, the safety challenge for the regulator of the future will be the same as for the industry:
keep doing what you’re doing, but do it better.
What does this mean?
Lots of things, but one of them is moving from an era of reactive, rules-based safety to a safety system of data-driven, trend analysis, and safety initiatives based on this knowledge.
To put it another way, a safety regime based simply around rules and enforcement is not going to provide the level of safety that air travellers of the future will demand. There’s nothing controversial about that statement. It doesn’t mean CASA is going to abandon rules or enforcement, just that we, and the industry, will have to do more, much more.
And here’s the thing - the data driven, analytical safety model we aspire to is one that revolves around communication. Data flows from the industry to the regulator, its lessons are distilled and then the regulator passes this knowledge back to the industry. The conversation never stops. Communication, stakeholder engagement and relationships are not a luxury, a distraction or a secondary activity. They are going to be at the centre of safety in the future.
My boss, CASA’s Director of Aviation Safety, Mark Skidmore has made this clear in a recent speech.
It was called ‘Positioning CASA to be the regulator of tomorrow’ and was the keynote address at the CHC safety and quality summit in Vancouver, Canada, in April.
He said: ‘I believe a modern regulator should engage, educate and enforce fairly, and proportionately, and only when necessary - this premise is expected to provide a breath of fresh air to CASA and to the industry we regulate.’
One of the foundations of an information and communications-based regulatory system is just culture.
Just culture is exactly what it says. Not a no-blame culture, because that quickly becomes a no-insight culture, but a culture that recognises the motivation, dedication and limitations of the people who work in this industry, and of human beings in general.
Without wanting to steal too much of his work, let me share with you three paragraphs of what Mark said about just culture in his Vancouver speech.
‘The advantage of a just culture approach is that it encourages people to be open and accountable about their mistakes, so there is better reporting of errors and the ability to learn from them is enhanced. Fear of punishment doesn’t stop people from making mistakes. But mistakes can be avoided by having comprehensive safety systems, training and an overarching commitment by everyone to achieving the best possible safety outcomes.
A lot of work is underway to implement a just culture approach in CASA. We will work to develop a regulatory and operational environment where genuinely honest mistakes are recognised for what they are — and use them as an opportunity for further learning and improvement. CASA’s response will be to understand why the mistakes were made and how we can reduce the likelihood that the same mistakes will occur in the future.
Mark had the next sentence in bold print.
- I consider this approach as a fundamental shift from our recent past —
He went on to say:
- ‘we need to recognise that a cultural change in both CASA and industry is required to harvest the real benefits of this concept. This itself is a challenge for us, but we are working on it.’
Elements of a just culture approach are already implicit in CASA’s enforcement policy and practice. However, we will be making this commitment clearer and more explicit as part of our overarching approach to regulatory policy and practice.’
I’ll add some words of my own, based on my experience in Airservices Australia and as a communications consultant to aviation and other high-consequence industries.
‘In cooperative and resilient industries just culture is BAU- business as usual.’
In these organisations Safety is not just something addressed in a monthly, or even a weekly meeting – it’s inherent, and a factor in every action performed by every person in the organisation. This level of safety commitment can’t be achieved without a culture that devolves responsibility and trust to staff, and the really interesting thing is that these values are also the ones that drive productivity.
The Harvard business review in December 2015 quoted studies that found disengaged workers had 49 per cent more accidents, and 60 per cent more errors and defects. Low employee engagement scores, also experienced 18 per cent lower productivity, 16 per cent lower profitability, 37 per cent lower job growth, and 65 per cent lower share price over time.
The lesson very strongly appears to be that a robust safety culture is also a good business culture.
So, how are we transitioning to this new model of a data and communications-based regulator with a commitment to just culture?
Firstly, we’re changing our structure.
In 2016 CASA has reformed into three groups:
- The Aviation Group, covering operations, flight standards, industry permissions, airspace and aerodromes. One manager now reports on these areas to the Director of Aviation Safety.
- The Sustainability Group, covering all essential support functions, such as human resources, as well as service delivery
- The Stakeholder Engagement Group.
This is the group I lead, and it has three components.
- Safety promotion and communication, through publications, campaigns, social media, apps (our dangerous goods app is a particular success. It lets you use your smartphone to check whether something you’re thinking of bringing in your luggage is allowed), and our front line of engagement, our aviation safety advisers.
- Safety education – both internal and external, through development of courses and materials
- Government and international relations, which works to keep the legislative arm of government and other governments informed of what we are doing, and why.
My job description is simple but stringent. It is to ensure consultation is effective, and communication is targeted so everyone gets the information they need in a timely manner.
Talking with the industry, not to the industry will be our new way of operating. When we do lay down the law, it will be after a thorough discussion, in which all sides have considered the other’s point of view.
A particular point I want to emphasise is that of internal communication and education. We are a geographically distributed organisation, of 793 people with offices in locations as diverse as Canberra, and Horn Island in the Torres Strait. Consistency in an organisation so diverse doesn’t just happen and we understand that. It’s a never-ending process to keep us all singing from the same hymn sheet, whether it be about nuts and bolts operational issues, or the broader concepts such as just culture.
Externally, who are we talking to? We nutted out this question earlier this year and decided it made sense to think of three groups
- General stakeholders – The flying public, even the non-flying public. People whose only contact with an aircraft would be if it crashed into their house – are still stakeholders in aviation.
- Clients- those directly affected by what we do. Airlines, operators, pilots, aircrew, engineers, airports
- Safety partners: organisations we work cooperatively with to achieve safety outcomes that represent a far higher performance than the baseline required by regulations. We will acknowledge and respect the excellence of these organisations, while at the same time maintaining a frank dialogue, informed by the latest safety thinking to help them maintain these standards. This fits with a sophisticated understanding of what safety is, and how it is pursued. As American theorist Karl Weick (rhymes with bike) says, safety is a dynamic non-event. Both CASA and its safety partners ‘get it.’ We understand that in order for nothing major and bad to happen, a lot of small and good things have to happen, every day, and without fail. Checklists, inspections, readbacks, people following uneasy hunches and taking a second look, tough decisions about weather, fatigue, scheduling, those sorts of things.
Obviously there’s a baseline of respect that applies to all stakeholders. But there’s a hierarchy, which determines our relationship with each group. As we climb this pyramid the nature of our relationship with each successive level changes. At the top it has many elements of a relationship of equals. In many cases this simply reflects the personal and work histories of the people in question. CASA and aviation industry personnel are in a continual cycle of replacement and exchange.
It becomes hard to work out who are the poachers and who are the gamekeepers until you realise that this oppositional framework is the wrong way to look at the situation. Poachers and gamekeepers have different interests – one wants a dead bird, the other a live one. But everyone involved in aviation has the same interest in safety. Accidents benefit no-one.
AS Mark Skidmore told the CHC Safety & Quality Summit
‘CASA is just a part of the aviation safety system - we do not hold all the knowledge - we need to work together by forming safety partnerships across industry, agencies, regulators and across other nations.’
So the restructuring has led us to consider our relationship with our stakeholders.
That leads us to the second change. We’ve also started listening, really listening. I’m not exaggerating when I say it’s one of our core activities now. Let me show you an example: the Part 61 Solutions Taskforce.
First some background. New flight crew licensing regulations were introduced on 1 September 2014 – These were Parts 61, 64, 141 and 142
A range of issues was identified with their implementation and transition, so in November 2015, CASA drew together the Part 61 Solutions Taskforce.
Its job is to:
- deliver solutions for the aviation community and CASA relating to valid issues associated with the new rules
- ensure known or likely safety risks continued to be effectively addressed
- ensure unnecessary costs were not imposed
- ensure the rules did not unnecessarily hinder participation or the potential for industry growth.
The taskforce formed an industry advisory panel to help prioritise action on identified issues and test proposed solutions. It comprises 16 aviation representatives from a range of sectors, including
- aerial application
- flying training
- representative bodies
- owners and operators
What has the Taskforce delivered so far?
- The transition for flying training organisations has been extended to 31 August 2018
- There are now more flexible ways for pilots to meet multi-crew cooperation requirements
- The taskforce clarified standards for aeroplane multi-crew cooperation training
- Some airline transport pilot licence (ATPL) requirements were relaxed
- Established a pathway for aerial agriculture rating holders to conduct firefighting operations
So, to recap and conclude:
- We (the regulator and the industry) have a common problem: success (it’s a nice problem to have, but it’s still a problem).
- If we go on doing what we are doing, it won’t be good enough (even though that approach has served us very well until now). And that goes for the industry, too.
- CASA is transitioning to become a proactive regulator using data to identify potential risk areas (because waiting for accidents to happen is 1980s’ thinking)
- This requires working in partnership with industry
- Working in partnership with industry requires just culture
- Just culture starts in our own organisation. Internal training and education are key to getting our house in order, and like housework, they never stop.
- The future will be different. We can only refine and improve safety by working together. No poachers, no gamekeepers, just partners.
Thank you for your interest and attention.