Sunday, March 25, 2018

What If…

What If…

Post by CatalinaNJB

New pilots learn the “What If” prior to departing on their very first solo cross country. Over the years as experience is gained, there could be a tendency for pilots to place these “What If” on the shelf. This may happen since experience often instinctively reverts back to the basics of safety when unexpected events occur. Other times than flying when the “What If” processes are applied is when SMS safety risk levels analysis are conducted. Demonstrating that a “What If” is valid is based on a probability analysis rather than an opinion of possibility. Decisions to accept or reject the safety risk is the final output of the “What If” process. Every operator, being airline or airport, are making continuous safety improvements from this very basic and decades old principle of aviation safety. Never in the history of aviation have it been more important to apply this basic principle, since SMS is being implemented by regulations in many of the ICAO member States and the aviation industry is watching the outcome or return on investment of an SMS.

Safe and regulatory compliant. But the inspector might not comprehend this    
Let’s for a moment apply this “What If” principle to regulatory oversight inspections and what impact this may have on safety in aviation. In this virtual scenario the “What If” question is: What if the regulator conducted an inspection of an operator certificate, but a short time thereafter decided to delete all inspection records, demanded the operator to ignore all findings, proceeded with a new inspection of the same items of that operator and then came up with different findings? The impact of the integrity of that regulator would most likely be devastating. There is a possibility that this could happen, but what is the probability    

When working with the “What If” scenarios, it is based on facts, or data, and not on subjective opinions. So, what if the virtual example of a regulatory inspection actually happened? The first thing that would come to someone’s mind is that the regulator is not qualified to conduct inspections. The second question might be how could this possible happen. The third, and probably the most important question could be what impact this could haver on long-term oversight. If the regulator, after an official inspection, is shedding evidence to cover up their incompetency, then there are no records of evidence to apply as basis for continuous training of inspectors. In addition, it would have global impact on the integrity of that oversight body if there was action taken due to their lack of qualifications. Under the ICAO mandate, a Member State has an obligation to oversee aviation safety.  This is one reason why it is crucial to aviation safety, not only nationally, but globally that the regulatory and oversight body is trained and competent to conduct inspections. Since this is a virtual scenario, we don’t have anything to worry about. However, there may be evidence that the regulatory oversight body is applying possibilities and not probabilities when conducting inspections of performance-based regulations.     

What if the majority of regulatory oversight inspections were invalid and didn’t serve in the interest of public safety but in the interest of their own agenda? This is always a possibility, but what is the probability? Since probability is based on facts and data there is no evidence that such an agenda driven approach exists.

Defend your Certificate    
Taking this virtual scenario to the next step, it becomes crucial to aviation safety, crucial to public interest and crucial to each enterprise that every certificate holder accepts their own accountability to safety and take on training to gain knowledge. The status quo in operations is that their leaders have not reach a SMS comprehension level required to defend their operations when the regulator makes findings    

Data is the bases of comprehension. When analyzed, data collected becomes information. Acquiring this information becomes knowledge and knowledge is the foundation of comprehending systems and systems interactions. Without comprehending the organizational Safety Management System, any finding statement may be accepted by the operator in support of a performance-based regulatory finding.

Not in a million years will the regulatory oversight body accept their lack of qualifications. It therefore becomes the accountability of the Certificate Holder to attend training, learning and information sharing courser, work shops and seminars, to fulfil their safety accountability obligation. Since this “What If” scenario was a virtual scenario, there is no possible way that an inspector representing the regulator is incompetent. However, even when accepting this as a virtual scenario, the fact is that any Certificate Holder must pass the bar of comprehending their own SMS to prevent destruction of their Certificate.


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