Sunday, April 16, 2023

More is Less and Less is More

 More is Less and Less is More

By OffRoadPilots

An accountable executive (AE) once said that they operate their safety management system (SMS) and airport operations by a principle that more is less and less is more. When operating by this principle, their regulatory compliance was in essence non-existing, and the regulator demanded the surrender of their airport certificate. The airport operator presented a corrective action plan to abolish the principle that less is more, and the regulator accepted their corrective action plan. Their airport certificate was secured, but an enormous task was ahead to establish regulatory compliance with all SMS and airport regulations. After the airport certificate was secured and compliance level established, the airport operator abandoned their quality control system and reverted back to their previously less is more principle.

A regulatory requirement is for the AE to be responsible for operations or activities authorized under the certificate and accountable on behalf of the certificate holder for meeting the requirements of the regulations. Traditionally, the airport manager (APM) was the certificate holder and would also remain the certificate holder after implementing the safety management system. As the certificate holder, the APM is the airport authority, the decision maker, and an AE is accountable to the APM to maintain compliance with the regulations. Compliance with all regulations and standards are comprehensive tasks, with compliance established with a line-item audit. When operating by the less is more principle, airport operators take it upon themselves to exclude regulations they have decided not to be applicable to their operations. Airport operators do not take into account that there is none, or minimal, scaling of the regulations to suite size and complexity of airport operations. The scaling is a regulatory requirement applicable to scale the processes as opposed to decline compliance with the regulatory part.

When applying the less is more principle, they are applied laterally to any systems without considerations to the issue at stake or expected outcome. Statements such as, “remember that less is more” are commonly used when undefined expectations are a part of the outcome, or minor tasks are removed from regulatory requirements, or lack of process comprehension, or when non- compliant tasks are excluded from the equation. There are times when the less is more principle is true, but the less-is-more system, is not a system to integrate into a safety management system.

The less-is-more system absolutely has its place within many systems, and advertising is one of them. Imagine for a minute that you are driving down the highway and you see a sign that says something like Our breakfast menu has pancakes, toast, eggs, farmers gravy, bacon, sausage, eggs, and coset between $10-15 per adult person.” By the time you get to pancakes, you have passed the sign and wondering what it said. In a less-is-more system, the sign would say Hungry? Next exit” With this sign the business gets more visitors who are hungry and generate more revenue. In addition, since there are fewer words, the sign cost less to make. The less-is-more system is a trigger to the imagination to fill in the blanks, and the blanks give positive, or happy feelings of what the imaginary outcome is. Online advertising has also changed to the less-is-more system by shortening their advertisements to five seconds to hit their target points and for the imagination to fill in the rest. Whenever there is a void, it will be filled with something. Other examples of less-is-more is it lower an item price below regular price to sell more units, it is to offer 25-cents video machines to attract more plays, it is to show less of the neighbourhood when advertising a home to attract more customers, it is to pay less for internet with slower connection and spend more time to upload and download, it is to spend less money on personal improvements to assert more internal control of personnel, it is to spend less money on training for a more uniform and conforming environment, or possible most important reason to operate with a less-is-more system is to play ignorance after occurrences. 

An AE once said that it is difficult to work with hazards that are unknown. The less-is-more system absolutely serves a purpose for an AE operate with a less productive safety management system and to some extent the regulator accepts the ignorance play. Just a few weeks ago, an airline gave this excuse for an aircraft that took off with contaminated surfaces saying that the pilots did not follow safety rules and the regulator accepted without further investigation. In 1956 two airlines were operating in a less-is-more environment causing a midair collision. Most people would not chose the less-is-more system when selecting medical treatment, but it is accepted in aviation safety. Ignorance is bliss, or if you do not know about something, you do not worry about it.

The less-is-more system is a destructive system for a safety management system for both airport and airline operations. The role of an accountable executive is to maintain compliance with records keeping. The regulatory requirements for records keeping are to maintain a record system, that do not comprise the integrity of the records system, measures are taken to ensure that the records contained in the recording systems are protected against inadvertent loss or destruction and against tampering, and a copy of the records contained in the recording systems can be printed on paper and provided to the regulatory on notice given. It would take some imagination to make less-is-more out of these requirements, but if works when processes are combined to cover multiple requirements. This is only possible with a daily quality control system, and a user friendly software that comply with all requirements. When a quality control process is established and determined to conform to regulatory requirements, there is minimal work needed in daily operations. Without a proven daily quality control system an airport or airline operator must complete the same tasks daily and start from the bottom every day to ensure compliance. E.g., using paper format records without continuance to the next day or the historical records.

The regulatory requirement foranAEistobe responsible for operations or activities authorized under the certificate and accountable on behalf of the certificate holder for meeting the requirements of the regulations. This is an enormous task and it make sense that an AE sets performance goals to minimalize these tasks as much as possible. Exempting operations from the regulations is not the way to go. A small to medium airport operator may only receive a turbojet aircraft a few times a month and decide on their own that compliance with obligations is not justified since this is how we always did it.” This is the less-is-more system in that complying with fewer regulations provide more options, or opinions to how airport operations should run. With this approach the safety-card is played, and any tasks or actions are justified by the word safety.” When the word safety is applied, there is very little opposition to the tasks, and especially if airside personnel remain untrained and without knowledge of oversite requirements. Keeping workers in the dark is a prerequisite when operating with the less-is-more system. Only after a complete line-item audit is completed of the operations, the daily quality control system is in place, and processes assigned to regulatory requirements, the less-is-more system could be applied by monitoring drift and operations daily, and make adjustments as required when personnel are drifting from design operations. However, the AE who decided to change over to the less-is-more system, also excluded the audit requirement from compliance system.

The more is less and less is more system is incompatible with operation of an airport or aircraft, and the safety management system. The litmus test of systems compatible with airport and airline operations is in their daily quality control system.

OffRoadPilots




No comments:

Post a Comment

Passion For Safety

Passion For Safety By OffRoadPilots S afety is in everyone’s interest, but not everyone has a passion for safety. Generally, safety is defin...