By Catalina9
Over the years, the Regulator has conducted SMS
Assessments, Program Validation Inspections (PVI) and Process Inspections. In
addition, they have conducted several nonstandard Compliance Inspections, which
is an old terminology for any type of inspections. The purpose of inspections
is to establish an operator’s level of regulatory compliance. Aviation safety
inspectors may apply subjectively portions of their Staff Instruction (SI). The
SI is not available to the public by searching databases and it could be a
conglomerate task for an enterprise to ensure compliance with expected
processes. This does not imply that an enterprise does not conform to
regulatory compliance, but that aviation inspectors, who don’t comprehend airline
or airport operations, may have unreasonable expectations of what to expect of
the processes.
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Nonstandard inspections or audits
skews Quality Control.
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When nonstandard inspections are conducted it
becomes extremely difficult for an enterprise to comprehend what aviation
safety inspectors actually are inspecting for. Other inspection methods are to
go directly to audit findings and inspect if the finding was corrected. The
Regulator’s mandate is to conduct surveillance of an enterprise, or close
observations. An observation is always in plain view, but becomes an
investigation when inspectors are following a lead from an observation.
Surveillance activities fall into two broad levels:
systems and process level. Systems level surveillance is conducted using
assessments and/or Program Validation Inspections. During these activities, a
surveillance team reviews an enterprise's systems to develop an understanding
of how they comply with regulatory requirements. The point of entry becomes the
critical factor of how an aviation safety inspector proceed with the
inspection. If the inspection is an Assessment, the point of entry is the
Safety Management System itself. For a PVI the point of entry is the Quality
Assurance Program. Documentation reviewed by inspectors are publications that
provide process, policy and procedures. Internally generated records are
reviewed on-site as part of the sampling plan.
Process level surveillance is conducted using
Process Inspections. During the PI, inspectors review an Enterprise’s processes
and traces processes backwards. When inspectors are tracing the process
backwards, gaps in the process are discovered and origination of the input
defined. A PI also defines the fork in the road or the place where the process
may lead back to the intended input or to a totally separate input. When
inspectors are tracing the process forward, they must apply virtual scenarios
to proceed when arriving at the fork in the road, which leads to incorrect findings.
Simplified, when moving forward any turns are justified with an explanation, or
emotions, while tracing backwards any turns are justified by facts.
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Issuing SMS system findings is wasting
valuable time .when based on PVI
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The only time a finding is an SMS system finding
pursuant to Canadian Aviation Regulations 107.02, is when all systems pursuant
to 107.03 are in noncompliance with the objectives. CAR 107.03 lists nine SMS
subsystems that must comply with their objectives. These systems are the Safety
Policy System, Goal Achievement System, Hazard System, Training System,
Reporting System, Process System, Quality Assurance Program System, Audit
System and Other Regulations System. The Regulator frequently issues SMS system
findings, while the finding should be a process finding of one of the nine
subsystems. This is spelled out in the Staff Instruction’s point of entry.
Since SMS was implemented in Canada there has been
much opposition to SMS from the public and inspectors. Multiple surveys were
conducted, which most showed that SMS was more of a hazard to aviation than
improvement of safety. Questions in some of these surveys were designed to skew
the outcome to discredit SMS. It was easier for inspectors to reject than to
put effort into learning about SMS. SMS is in concept very simple and
practical. One simple step both the Regulator and Enterprises conducting
internal audits must take when assessing their SMS, is to develop a random
sampling plan of their operational regulatory requirements and operational
standards. In addition, both the Regulator and Enterprises must inspect and not
investigate to arrive at a correct result.
Catalina9
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