Regulatory Conforming Processes

 Regulatory Conforming Processes

By OffRoadPilots

Regulatory conforming processes are processes producing outputs that conform to regulatory requirements. There are three fundamental tasks required when building regulatory performing processes. The first task is the research for input task, the second task is the process design and development task, and the third is the regulatory identification and assignment task. A process must be linked to one regulatory requirement. In a healthy SMS environment, a process is linked to several regulations, or several standards, and to the SMS policy.

The research for input task is a comprehensive research of regulatory requirements for airport or airline operations. In addition to airport or airline regulations, multiple other federal or local regulations may be applicable, such as environment regulation, transportation of the public regulations, and other regulations. However, when researching regulatory requirements for the purpose of building a conforming process, only airport or airline operations regulations are researched for inputs. These are the regulations that an airport or airline operating certificate is tied to and dependant on for its existence. Performance-based regulations are based on a 95% confidence level.

Regulatory research also includes a comprehensive research of standard requirements for airport or airline operations. Standards are also performance- based in the same way as the regulations are. Airport standards has been adapted for use in an operational concept to reflect and support the operational reality of aircraft capabilities and performance specifications. An airport standard establishes a level of service for an airline and its fleet. Rapidly changing technologies in aircraft performance and avionics have a very real potential to impact future aerodrome operations. An increase in the size of critical aircraft or the provision of lower landing, departure or taxi limits will require the aerodrome operator to re-assess the aerodrome facilities and operational procedures to ensure they provide the required standards.

Accuracy requirements for aeronautical data are based upon a 95% confidence level and in that respect, three types of positional data are identified. Positional data are surveyed points e.g. runway threshold, calculated points, e.g. mathematical calculations from the known surveyed points of thresholds for determination of the aerodrome reference point, and declared points, e.g. flight information region boundary points. The confidence level is in the method, or process itself, and is not in a particular confidence interval. If the sampling method was repeated many times, 95% of the intervals constructed would capture the true population mean. As the sample size increases, the range of interval values will narrow, meaning that a larger sample size, or an increased number of data collected, the mean of the sample will generate a much more accurate result if compared with a smaller sample, or fewer tasks completed.

There is a misconception among operators that a 95% confidence level is the same as airports or airlines being 95% safe. Conventional wisdom is that the application of numerical safety levels, such as airline ratings are indications of what level the public are protected from harm when an airline has achieved the maximum 7 of 7 in their rating. An airline rating level takes several other parameters into account, such as staff friendliness, service availability and more to provide a complete travel experience safety level. In the same way as airline ratings apply several parameters in their assessment, airline and airports do the same in their operational assessment oversight. There are therefore no contradictions between a 95% confidence level and a 100% safety rating level, or rated 7/7.

A 95% confidence level is that established safety performance indicators (SPI) and safety performance targets (SPT) will fall within their expectations 95 of 100 times. An airline may establish a confidence level of 95% that their pilots will touch down within the first 1/3 of the runway. For the same airline to establish a 100% confidence level, the airline needs to operate with an expectation that their pilots will touch down anywhere on the full length of the runway 100 of 100 times. A targeted 95% confidence level is therefore safer in operations than a targeted 100% confidence level, which does not provide enough stopping distance for a pilot who used up all of the runway before landing.

The next step is the process design and development task. When designing processes, the objective is to produce an operational sound outcome. At this stage in the design process, regulations, standards, and the SMS policy are considered, but they are not applied to the process design. The reason for considering regulations but not applying regulations, is that an easy trap to fall into is to build a regulatory process. In a regulatory process an airliner captain must fly the regulations when they need to fly the process. E.g. if a regulation, or flight operational quality assurance expectation requires a pilot not to bank an aircraft beyond 25 degrees angle, the wind could push the aircraft into an undesired position, as opposed to flying the process when a pilot would increase the bank angle to maintain aircraft control. A goal when building processes, is for processes be practical to use, and with a task-flow that make sense to users.

Regulations are objective and impartial to a process, while safety is subjective and biased. Regulatory compliance is the priority, while safety is paramount. Maintaining continued regulatory compliance is the foundation and building blocks for the existence of an airport or airline certificate. When safety is paramount, it becomes the highest-ranking order of a system, and regulatory priority is the only tool to maintain safety as the highest-ranking order. Just as an accountable executive is the highest-ranking order of a safety management system, regulatory compliance is the operational priority to maintain that order.

An airport has an obligation to operate with a runway environment that maintains continuous regulatory compliance. This is achieved in multiple ways when each activity or task is linked to a regulatory requirement. One task several airports have adapted, is the daily inspection task. This is not a regulated task, but by using the process daily, they are engaged in activities, or processes, that conforms to regulatory compliance. The key to success is to comprehend what regulatory requirements each activity is linked to.

The last step is the regulatory identification and assignment task, which is to conduct a process analysis to verify what tasks within the process are lined to a regulation. A process compliance analysis is conducted backwards, starting from the end result and output, and move backwards until the beginning. Any broken link in the process must be closed for compliance.

After all broken links are closed, the next step is to analyze the process forward and apply compliance to each step in the process. There will also be steps that are not linked to aviation regulations, such as checking the vehicle before operating airside. Compliance requirements are linked to tasks performed while conducting the inspection. One task may be linked to multiple regulations, and one regulation may be linked to multiple tasks. Comprehensive knowledge of the regulations is required to perform these tasks. The accountable executive is the person who is responsible for compliance with all regulations and is also the person who is the final authority for assigning regulations to tasks.

When regulatory conforming processes are built, implemented, and communicated to workers, compliance becomes simple. Airport or airline workers does not need to change how they work, or how things are done, but are simply completing their processes as expected. Over time as data becomes available, the only task left is to enter data into a statistical process control system for control charts to be produced and analyzed.

The beauty of operating with regulatory linked processes, is that all information is available to airport and airline operators when safety performance is analyzed, and when the regulator conducts inspections.

OffRoadPilots