The Devil Is In The Details

 The Devil Is In The Details

By OffRoadPilots

The Titanic disaster was caused by a detail in the watertight compartment design flaw that the walls separating the bulkheads extended only a few feet above the water line, so water could pour from one compartment into another, especially if the ship began to list or pitch forward.

The Alexander Kielland disaster was caused by a fatigue crack in one of its six bracings, which connected the collapsed D-leg to the rest of the rig. This was traced to a small 6mm fillet weld which joined a non-load-bearing flange plate to this D-6 bracing.

The Sioux City IA air disaster was cause by a catastrophic failure of its tail-mounted engine due to an unnoticed manufacturing defect in the engine's fan disk, which resulted in the loss of many flight controls. None of these details were identified as issues of any concerns, but they caused some of the most horrific and catastrophic historical events within their own areas of history. Titanic was built to be unsinkable, a deep-sea diver once said to me that there were terrible working conditions for underwater welders, and it was known ten years prior to the disk failures that these disks had flaws and could fail.

Details may be known by management, but are often dismissed, they are brushed aside as being unimportant, or seen as irrelevant to the issue. Details are not only important in operations, but also for regulatory and standard compliance.

both airlines and airports have to maintain compliance with a comprehensive safety management system (SMS). I concept, an SMS is simple but unless details are identified within a system analysis, the system becomes complex and often unmanageable. A manageable SMS is based on daily quality control, established processes and each operational task is linked to multiple compliance requirements. When processes are established, an SMS has been simplified and manageable, with the primary tasks to monitor for deviations from assigned path. The more details paid attention to in an SMS make the SMS simpler and easier to use. When details are known, it is easy to see where the pieces fit into the whole picture, as opposed to fit a large piece into a detailed issue. When SMS is forced, it makes it difficult and complex to apply in operations. A symptom of an SMS that is too complex or unmanageable for operations, is therefore when SMS is overloaded, or overcontrolled, and safety information is a tool to justify its existence.

Paying attention to details is a regulatory requirement for a certificate holder to adapt their safety management system to the size, nature and complexity of the operations, activities, hazards, and risks associated with the operations. Adapting to size and complexity requires detailed knowledge of their operations. When an operator only has a high- level knowledge and overview of their systems does not allow for a

certificate holder to apply operational targeted processes that suits their size of operations. A certificate holder is required to appoint an accountable executive (AE) to be responsible for operations or activities authorized under the certificate and accountable on their behalf of the certificate holder for meeting the requirements of the regulations. This requirement does not imply that an AE only need to be familiar, or only have partial knowledge of the regulations, but is a requirement for the AE to have detailed knowledge of regulations to detect deviations from established paths and non-conforming processes. Conventional wisdom is that an AE only need to be responsible for financial and human resources, which is a job description of their position, while the knowledge of regulations is the requirements for accepting the role. SMS is a businesslike approach to safety, and no business owners, corporate directors or airport authority would hire an accountant or lawyer who have limited knowledge of regulatory requirements and their areas of responsibilities. However, they continue to hire accountable executives who do not have the knowledge base to fulfil their obligations to the regulations.

Obligations of an airport operator is to review each issue of each aeronautical information publication on receipt and, immediately after a review, notify the Regulator of any inaccurate information. Detailed knowledge of how to obtain a copy of the aeropub is required, detailed knowledge of how often a new revision is issued, and what date it is published is required. They need detailed knowledge of what information pertains to their operations, what action to take in addition to reporting any errors to the Regulator, and how their internal SMS process capture these requirements. An operator must design, develop, and submit to the Regulator an operations plan for airside construction, and operate with airside operations plans for maintenance and repairs. Operations plans must include details of operations for processes to conform to regulatory requirements.

The person managing the safety management system, or SMS manager is required to monitor the concerns of the civil aviation industry in respect of safety and their perceived effect on the certificate holder and determine the adequacy of the training for personnel. In-depth and detailed knowledge of their own operations are required for an SMS manager to monitor the aviation industry in respect to safety and how they view different independent operators. An airport operator who frequently closes their runways due to maintenance and repairs, may be viewed as unsafe since this particular airport does not have project plans in place for airside management and for runways to remain open for business. An airport operator may choose to close a runway between 2AM and 4AM for daily maintenance and inspection, which is different that publish NOTAMS for unexpected maintenance requirements during hours of operations. An SMS manager is required to determine requirement of training, and without the details of expected outcome of the training this function cannot be performed.

Comprehension of details in operations, the text of regulations, and the intent of performance-based regulations are required for an operator to design processes that conform to regulatory requirements.

Generally speaking, a regulation is applicable to any airline or airport, unless there are special provisions for size and complexity. One such regulation is the airport winter maintenance regulations, where the regulation is applicable to airports serving turbojet aircraft, and the other part appliable to airport serving propeller aircraft and on-demand operations only. Winter operations for airports serving propeller aircraft is to consult a representative sample of the air operators that use the airport about the intended level of winter maintenance and the remove sand from movement areas when it is no longer needed. Additional requirements for airports serving turbojet aircraft are that they have a winter operations plan, snow removal priority areas, pre-threshold maximum snow accumulation, use of ice control and chemicals, friction measurement and movement area inspection reports. The detail of this regulatory requirement is not in this regulation itself, but in the requirement for an airport certificate. An applicant for an airport certificate must maintain verification records that they can operate with a safety management system and is requirement for non-certified aerodrome operations prior to the issuance of an airport certificate. When a certified airport operator elects to operate as an airport serving propeller aircraft only, they voluntarily give up their SMS records for operations serving turbojet aircraft. Should an airline operator wish to operate turbojet aircraft out of this airport, they must delay their operations until the airport can verify their capability to operate with an SMS supporting turbojet aircraft. The detail of this requirement is to connect the link between two regulations to conduct a system analysis of future operational restrictions. With the implementation of the safety management system, any operational regulations must be linked to the SMS regulations. This is a detail that an AE must be aware of and able to distinguish between multiple regulations and how they are linked to same SMS regulation.

An airport is required to maintain a runway strip, or an area beyond the side of the pavement of a runway, and beyond both threshold, that are without aeronautical obstructions. This includes natural obstructions and other encroachments such are riverbanks. One airport decided, without consultation, to fill in a riverbend to widen their runway strip.

After the construction application was submitted, the community responded with opposition to this initiative. The airport boundary needed to be expanded by filling in the river and bird wetlands. In practice, this means that birds, wildlife, and plants are forced to leave their habitats. In the application, the airport manager wrote the following: "Regarding natural diversity: The airport does not have the professional expertise to assess any special impacts on natural diversity. Our experience from operating the airports over several years is that there is very limited animal and bird life in that area. We assume that this is due to the presence of the lake on the opposite side of the runway, which has a bustling wildlife and bird activities, and which therefore seems to be more attractive. Nor has any extensive movement of wildlife or birds been observed between this lake and the riverbend, which is probably due to the activity on the runway. In addition, the airport has limited data entries in their bird and wildlife register.” The airport manager states in their application that they do not have the professional expertise to assess impact on bird and wildlife, and due to airport operations, bird and wildlife activities are scared away and therefore does not exist as a justification to stop the construction project. This application is in non-compliance with an SMS to conduct system analysis of projects and comprehend all details included. An accountable executive needs to be able to comprehend the details and impact on the community by reading their own submission. There is also a regulatory requirement for airport extensions to consult with their neighbors, stakeholder, and other interested parties.

When the Regulator conducts an inspection, and since the regulations are performance based, they will inspect what is not written in the text of the regulations. An inspection includes the regulations itself, how it is linked to other regulations, and how an SMS enterprise maintain a path to monitor processes. An AE needs to have knowledge to link for an airport to publish NOTAM (Notice To Air Men, and the new definition is Notice To Air Missions), and for the captain of an aircraft to be able to assess an airport for suitability. The intent of an airport operator, and a certificate requirement, is for an operator to operate an aerodrome as an airport. This requirement implies that the airport meet certification standards 24/7. A published NOTAM does not change that requirement but is a tool for an airport operator to fix or repair an unexpected issue within a short timeframe.

The devil is in these details and other safety or regulatory details. For all practical purposes, what this mean is that an SMS enterprise does not have any justifiable cause to operate outside of the intent of the regulations, or exempting themselves from standards, or their own policies as they please, and most important, it is a responsibility for an accountable executive to know what this entail to ensure ongoing compliance.

OffRoadPilots