Surveillance Activities
Post by Catalina9
The difference between surveillance and oversight is
that surveillance is close observation of an enterprise, being airport or
airline under suspicion while oversight is something that is left out, missed
or forgotten. Surveillance is all activities directly related to evaluating an
enterprise's compliance with applicable regulatory requirements including
assessments, program validation inspections and process inspections. The
regulator does no longer conduct oversight, they do close observations of
systems, processes, procedures and work performance activities. A
system is a group of inter-dependent processes and personnel working together
to achieve a defined result. A system comprises policies, processes and
procedures. It is through systems that enterprises should achieve a state of
compliance to their regulatory requirements on an on-going basis.
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Surveillance is to focus on the
hazards.
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The regulator’s observations are not only of your regulatory
compliance, but includes all activities affecting your enterprise. This
includes activities that are unrelated to safety in operations. When an
enterprise contacts the regulator with a question, a red flag goes up and the regulator
elevates the risk level for that enterprise. Should you be brave enough to ask
the same question several times, your risk level quadruples. Surveillance is
not oversight, but close observations of your processes and personnel involved.
This information is published in aviation advisory circulars and should be
known by all enterprises. It therefore becomes crucial for the success of the Safety
Management System that enterprises take it upon themselves to monitor their own
activities. No organization has the capacity to conduct 100% of the monitoring,
100 % of the times at 100% of the locations. The only way for an enterprise to
ensure process compliance is to apply statistical process control (SPC) of
operations. Events unrelated to safety in operations takes time away from
operational tasks and is a direct hazard to aviation. When applying this
concept to findings, that corrective actions for findings are unrelated safety
activities, an enterprise with multiple findings becomes an elevated safety
risk to aviation with an increase in unidentified hazards and there is less
time to ensure safety in operations.
Knowing all this places the accountability on an
enterprise to ensure that their processes conform to:
1)
Regulatory
compliance;
2)
Policy
compliance; and
3)
Operational
Safety compliance.
Safety is paramount, but regulatory compliance is
first priority. Without regulatory compliance the platform, or base for
operations does not exist. Policy compliance is the second priority. Without
policy compliance, there are no operational controls. Operational safety
compliance is 3rd priority.
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Performance-based
regulations is a blank sheet of paper to write your history.
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Without operational safety compliance there is no
customer service, there is no project solutions quality leadership or Safety
Management System in place.
It has been said that if the regulations don’t state
you must comply with a task you don’t have to. With the implementation of SMS
and performance-based regulations, this is exactly why an enterprise needs to take
it upon themselves and establish performance compliant processes. Times has
past when the regulator takes care of your safety. The regulations itself
cannot establish your processes. However, if the regulator makes an attempt to
establish processes for an enterprise there will be an apparent conflict. This
is simply because the regulations are performance based while the regulator
expects implementation of prescriptive based regulations.
When organizational polices, processes, procedures
and common practices are established, an enterprise has developed their tools
for safety in operations and a Safety Management System. Performance-based SMS
regulations are here to assist an operator, being airport or airline, with
performance details that are compatible with the safe operations of an airport
or aircraft.
Catalina9
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