[Peetwo]

Many are trying to understand this:-

CHAIR: I am just trying to understand why the operator can't continue to manage their fatigue and their flying hours in the way that they've been able to do previously, using common sense, using the practical industry requirements. Remember, this is a small part of the industry but very important

Ms Spence: Essentially, we want to demonstrate that you can be an outcomes based regulator through using the FRMS but that does require us to be able to do our side of it and say, 'Yes, we think this delivers a safe outcome on the basis of the proposal that's been put to us.'

Bollocks: what in the world would Spence or Crawford know about operational risk analysis?

Ah, there's the rub. An operator may have a legitimate requirement for say an extended duty period on a regular basis. It may well be a carefully considered and scripted system, designed to suit and accepted by the crew. It may have worked very well – under exemption – for donkey's years with a strong safety record to back up the system. Then, it is submitted for CASA approval – enter the 'specialist consultants'. Ex CASA – their very expensive version of the SMS or the F&D is the only one which will be accepted. (Arses covered).

There is a high risk element associated with 'fatigue'. There is an even higher risk element when a SMS fails. These are the two victims of an inflexible system. To this equation you may add operator attitude – overt and covert – to the mix. A classic example is found in the Pel-Air debacle. In the CASA accepted and approved operations manual there is no attempt at a 'risk matrix'. A long flight, requiring a fuel stop at an island notorious for chancy weather, the alternate a long march away with the associated 'fatigue' accumulator of uncertainty and additional flight time – ignored. Communication problems not a factor, despite being a known possibility; no flight following, no support. Then, the crew have problems getting food and adequate rest. Then the imperative pressure to move the patient. Holes in the cheese begin to align. The rest is history. A high risk flight, no support and a potential fatigue trap. That crew should have only had one problem – to find a phone, call the base, declare fatigue and waited until the next day – the patient was stable and comfortable in hospital. So where was the support? Where was the fatigue matrix? Where was the flight following which could have advised – Norfolk looks marginal – best come back through New Cal? Except that solution was fraught – the French were not happy with it (story for another day).

CHAIR: But if they've had these exemptions for a long time, they've not had a problem and they've got a proven track record, is the limit under the new exemption allowed to be carried over into the new rules

The problems do not lay in the flight and duty rules Senator; they lay within the approval system. They lay within poorly constructed rules, applied as seen by individuals with NDI about operational management. Rules may serve to sketch out the basic requirements – serve as a starting point – but they fall way short of 'understanding' operational risk. The blind compliance CASA demand and support with criminal law, using 'strict liability' to prevent tailor made risk analysis to each operational type must be addressed – and soon.


CHAIR: My experience to date, though, is that most operators are very reluctant to come to you with a specific requirement, because it doesn't always work out well for them. That's the reason why people don't want to give evidence publicly. I'm just telling you that. That's feedback. This is why you have operators that are saying, 'I'm terrified of telling CASA that I need to manage things differently because I may well be managed out of profitability or practicality

Spot on – nearly. CASA are empowered by the Commonwealth only to ensure compliance with the ICAO. They are not empowered to micro manage industry; yet they do. Listen; once again, carefully to the silver tongued Scot as he clearly defines the intent to 'manage' industry risk and fatigue strategy – through CASA approval only for those who comply with their version. Crawford could not find a cat in a cat-house with a spotlight; yet the RRAT seem quite happy to bandy words and be led around like obedient children visiting a museum. Ayup; the 'mystique' of aviation safety weaves it's magic as scared politicians happily avoid any blame.

There is your Catch 22 Senator – Heads they win – Tails you loose. What's not to enjoy eh?

Addendum... :

The CASA Briefing - May 2021

From CEO and Director of Aviation Safety Pip Spence
 
As the newly appointed CEO and Director of Aviation Safety, I count myself fortunate on a number of fronts. I'm fortunate to have secured a job in an organisation that plays a vital role in a sector of the Australian community I value very much. I'm also fortunate to have worked in a range of aviation-related positions over a number of years, allowing me to develop a solid understanding of how the sector works, the challenges faced by its organisations and people and emerging opportunities. Importantly, I'm fortunate to have met many people in a wide range of positions in aviation and to have been a part of interesting and at times inspiring conversations. I do not pretend to know everything about aviation and aviation safety, but I do bring a depth of knowledge and experience to my job.

Over the last few weeks, I have heard from people across the spectrum of Australian aviation. Irrespective of the nature of their operations, they have all emphasised their commitment to working with CASA, and the importance of having a strong and respected safety regulator. This is very heartening and tells me the values of the aviation community align very much with my own. I place great store in respect, collaboration and engagement. Under my leadership, CASA will show respect for the aviation community and actively seek to work with people from all parts of aviation to maintain and improve safety. We have a common goal of achieving the best possible safety outcomes for ourselves and the broader Australian community, and we should never lose sight of this objective.

We have a great team of people within CASA who have a strong commitment to supporting the aviation community achieve the best in safety. I will be giving them my support to further strengthen our national aviation safety culture and I ask you to constructively work with them as the inevitable challenges arise. Over the coming months and years, I look forward to meeting with as many people from Australian aviation as possible as we continue to deliver safe skies for all.
 
All the best
Pip

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EWH take on that:

  New CASA CEO and Director of Aviation Safety Pip Spence has landed at Aviation House and has opened her first CASA Briefing newsletter by outlining her expertise in the aviation industry and how much she understands it. I have no qualms as such with blowing your own trumpet, but if the tune you're playing is not one the audience wants to hear it's still just noise. There is a greater risk; a gauntlet that Spence had chosen to run, and that's to put promote yourself on a platform that currently doesn't exist. In this case, it's a promise of respect. She said "Under my leadership, CASA will show respect for the aviation community and actively seek to work with people from all parts of aviation to maintain and improve safety." Right now that's an unfathomable proposition; the operations side of the regulator has a reputation for disrespect and roughshod tactics when it comes to dealing with the GA community. It's almost part of their DNA. If Spence is going to achieve her platform, some serious changes are needed; changes that will thresh out the dead wood within the department and allow new growth to thrive. Spence's problem is that she has now boldly gone where so many have gone before, and if, like the others, she fails to deliver, the aviation industry will stop listening to her tune because they will have heard it before...

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