Ramble On - In a nutshell -
Australia Aviation Regulatory Burden - A Tragedy
Is it just me that has noted that the burden of compliance is ever increasing and becoming impossible to meet.
At some operations I know, there have been people working almost non stop on writing operations manuals for the majority of a decade and it’s still nowhere near done.
The extra staff required to meet regulatory compliance is eye watering. The work load and stress caused by CASA compliance is just incredible.
The majority of the burden stems from the most poorly structured and written suite of rules I have ever seen.
Very few Australian regulations are written in a style for operators or end users but designed to be for lawyers to form the noose with which to hang an operator after an event.
I have nightmares about getting a good working knowledge on the current regulatory Flight Duty times when flight operations cross into 3 or 4 of the Annex definitions.
Part of the burden is also self inflicted because the Operations Manuals are no longer just one simple manual but now a never ending suite of volumes that are each of a size and complexity such that they are almost impossible to have a good working knowledge of let alone retain.
Combine the above with the poorly written extra curricular studies (CRM, RVSM, RNP, TCAS, EGPWS, HF, TEM, EMERGENCY DRILLS, DGs) and I see how costs just skyrocket- because it must be almost impossible to make a profit under this burden.
And it is certainly not SAFER.
Safe is NOT having an 800 page AIP, a 1000 page Operating Manual suite and untold hundreds of pages of CARs, CASRs, CAOs, MOSs, and NOTAMs to recall when things go wrong on a dark and stormy night or when your eyeballs are hanging out during a miserable grey wet first light approach after an oceanic or ITCZ crossing. At that point there are only a handful of numbers that are important and they may all be in an AFM for which there is no longer working brain space to store.
I see that it’s time for operators to stand up and stop this snowball effect. It’s time that we got back to some good simple flying basics in this way too complicated CASA regulatory world. For a start it’s long overdue that we had regulations written for operators and not lawyers and Ops Manuals that were designed for operating and not arse covering.
Succinct, accurate, eminently sensible. The case for adopting the NZ or USA model is undeniable. CASA aim for 100% 'safe' conviction rate, no matter the 'evidence', through the use of this type of rule set, that is the target. Passing strange though that the abominations and blatant disregard for the most basic of rules, occasioning death in Broome, were allowed to continue, without even a mild rebuke, let alone a criminal prosecution. Take a quick study of the Andy Pascoe case; or Bruce Rhodes or Glen Buckley; or, any of the numerous other matters; run a comparison. The relentless nature of prolonged attack, the cost – both fiscal and human. Then run that against 'Croc- Fodder' or his noble off- sider in Broome.
If you can find logic; or, justice; or, even an improved safety case; then you are a better man than I am Gunga Din.
Toot – toot....
Australia Aviation Regulatory Burden - A Tragedy
Is it just me that has noted that the burden of compliance is ever increasing and becoming impossible to meet.
At some operations I know, there have been people working almost non stop on writing operations manuals for the majority of a decade and it’s still nowhere near done.
The extra staff required to meet regulatory compliance is eye watering. The work load and stress caused by CASA compliance is just incredible.
The majority of the burden stems from the most poorly structured and written suite of rules I have ever seen.
Very few Australian regulations are written in a style for operators or end users but designed to be for lawyers to form the noose with which to hang an operator after an event.
I have nightmares about getting a good working knowledge on the current regulatory Flight Duty times when flight operations cross into 3 or 4 of the Annex definitions.
Part of the burden is also self inflicted because the Operations Manuals are no longer just one simple manual but now a never ending suite of volumes that are each of a size and complexity such that they are almost impossible to have a good working knowledge of let alone retain.
Combine the above with the poorly written extra curricular studies (CRM, RVSM, RNP, TCAS, EGPWS, HF, TEM, EMERGENCY DRILLS, DGs) and I see how costs just skyrocket- because it must be almost impossible to make a profit under this burden.
And it is certainly not SAFER.
Safe is NOT having an 800 page AIP, a 1000 page Operating Manual suite and untold hundreds of pages of CARs, CASRs, CAOs, MOSs, and NOTAMs to recall when things go wrong on a dark and stormy night or when your eyeballs are hanging out during a miserable grey wet first light approach after an oceanic or ITCZ crossing. At that point there are only a handful of numbers that are important and they may all be in an AFM for which there is no longer working brain space to store.
I see that it’s time for operators to stand up and stop this snowball effect. It’s time that we got back to some good simple flying basics in this way too complicated CASA regulatory world. For a start it’s long overdue that we had regulations written for operators and not lawyers and Ops Manuals that were designed for operating and not arse covering.
Succinct, accurate, eminently sensible. The case for adopting the NZ or USA model is undeniable. CASA aim for 100% 'safe' conviction rate, no matter the 'evidence', through the use of this type of rule set, that is the target. Passing strange though that the abominations and blatant disregard for the most basic of rules, occasioning death in Broome, were allowed to continue, without even a mild rebuke, let alone a criminal prosecution. Take a quick study of the Andy Pascoe case; or Bruce Rhodes or Glen Buckley; or, any of the numerous other matters; run a comparison. The relentless nature of prolonged attack, the cost – both fiscal and human. Then run that against 'Croc- Fodder' or his noble off- sider in Broome.
If you can find logic; or, justice; or, even an improved safety case; then you are a better man than I am Gunga Din.
Toot – toot....