Forward-Looking Accountability

 Forward-Looking Accountability

By OffRoadPilots

Coincident with the safety management system (SMS) regulations, organizations are required to appoint an accountable executive (AE). The accountable executive is a single, identifiable person within each organization who will discharge the certificate holder’s responsibilities, and in particular, lead in cultural change within a just-culture. It is imperative that the correct person be identified as the accountable executive, and that the individual understands and accepts the roles and responsibilities associated with that position. This is not intended to be a position title without accountability, and on the other hand, it is not a position to accept liability. Simplified, the position as an accountable executive is a position where the appointed person is responsible for airline or airport operations and accountable on behalf of the certificate holder (CH) for meeting the requirements of these regulations.

The AE is responsible to the regulator to operate with processes that conforms to regulatory requirement, standards, and the overarching SMS policy. Regulations requiring the appointment of an accountable executive are separate from those requiring an SMS, i.e., an AE is also required for operators that are not controlled by the SMS regulations.

When incidents occur in business, there is often a call to find those who are responsible and hold them accountable for their actions. In too many cases, accountability translates into disciplinary action against the frontline workers directly tied to the incident (such as verbal and written warnings, suspension, and even termination. If a frontline worker is engaged in at-risk behavior that resulted in an incident, punitive actions are not the preferred process. Incidents are rarely just the result of one person’s decision-making process.

A system that seems unjust or unfair leads to the erosion of trust and respect between frontline workers and management. Without trust, excellence in safety is unattainable.

In addition to undermining trust, there are other reasons to be cautious with the use of punitive actions, discipline, and blame. Research shows that negative consequences have detrimental side effects that often outweigh any positive benefit. Some side effects include fear, lower morale, limited engagement, and suppressed reporting of incidents and near misses.

Most importantly, discipline often does not result in safety improvement. Several years ago, a pilot violated a regulation and was placed on leave without pay for two weeks. The safety manager proposed a corrective action plan to investigate the organization, and to learn if there were gaps in any processes, such as crew resource management, flight training, process training or certification. Management rejected the proposal, and within three months the pilot’s behavior was a contributing factor to a fatal King Air crash. Discipline and other negative consequences do not belong in safety. This does not imply a reduced accountability but is a shift from backwards-looking accountability to forward- looking accountability. Backward-looking accountability is about finding blame, finding the individual who made the mistake, and delivering punishment. Forward-looking accountability acknowledges the mistake and any harm it caused but, more importantly, it identifies changes that need to be made, and assigns responsibility for making those changes. The accountability is focused around making changes, changing organizational systems, modifying management practices, addressing hazards, and building safe habit. Forward-looking accountability is a prerequisite to build a positive safety culture, or just-culture.

Conventional wisdom is that an accountable executive is responsible for human and financial resources only. However, there are two requirements for an accountable executive. The first is a knowledge requirement and the second is a condition requirement. The knowledge requirement is that an accountable executive fully comprehend all regulatory requirements with skills required to design, develop, and operate with processes that conforms to regulatory requirements. A certificate holder shall appoint an individual as accountable executive to be responsible for operations or activities authorized under the certificate and accountable on their behalf for meeting the requirements of the regulations. The condition requirement is that the accountable executive exercise full control of financial and human resources that are necessary for the activities and operations authorized under the certificate.

A successful accountable executive is forward-looking and is accountable to both their knowledge requirement to meet the requirements of the regulations, and accountable to their condition requirement to control financial and human resources. Forward-looking accountability is achieved by risk level decisions, priorities, and expected output of processes. If an expected outcome, or expectation is not defined, there is no definite purpose for that process.

Accepting a risk is the responsibility of an accountable executive. Should someone else, e.g. an airport manager, accept the risk for airport operations, the accountable executive does no longer work within a forward-looking accountably system, since the risk was accepted by an unauthorized person.

Forward-looking accountability trickles from the AE to directors, management, and to workers within an SMS enterprise. The accountable executive is the only person responsible on behalf of the certificate holder for compliance with the regulations. All other personnel are accountable for their application of regulatory conforming processes to their area of operations. Regulatory conforming processes are accepted by the AE and distributed to workers for their benefit as guidance to remain within established parameters. Unless conforming processes are distributed to worker, for them to know what is expected, they and the AE, no longer work within a forward-looking accountability system.

Forward-looking accountability is simple in concept, but it takes hard work to implement processes that conforms to regulatory requirements. Simplified, forward-looking accountability is like being safe when driving down a two-lane highway. If someone had told the wagon-train people of 1857 that wagons one day will travel 80MPH in opposite direction on a trail without accidents, they would not believe it. In their mind, a trail was two ruts that were difficult to move away from. Today, vehicles (wagons) are travelling safety at 80MPH on a trail due to forward- looking accountability. Vehicle operators have learned what lights and markings define and they comply with their messages. The road is paved with a yellow line in the middle to separate the opposite wagons (cars). A driver applies the forward- looking accountability principle by complying with the process, to stay on the right side of the line (some countries left side) and is accountable to opposite traffic on the road. After a vehicle is passed, a driver is no longer accountable to that vehicle, but is forward-looking accountable to what lays ahead. A driver is forward-looking accountable to pedestrians, wildlife, or out of control vehicles approaching head- on. Within a forward-looking accountability system, there is not a question if the oncoming driver comply with the rules or not when approaching head-on, the accountability is to initiate an occurrence, or avoidance maneuver, to avoid an accident. If the principle that the regulation does not say to move away was applied, and a driver demanded to exercise their right, an accident is inevitable. Airport and airline operators insist that they do not need to take action since the regulations does not state that they do. Not long ago an airport operated with 100% ice on their runway, since the regulation did not state that they needed to clear the ice.

Forward-looking accountability must be within a just-culture, since it is impossible to predict the future and what, when, where, who, why and how an accident will happen. Within a just-culture there are decisions made, that after the fact may be determined to be a contributing decision to an accident. When working within a forward-looking accountability system, it is crucial to success that the person who made a decision in good fait, but contributing to an accident, is given a thank you by the AE. The outcome of a spontaneous decision due to external interference does not always give a desired output. Some years ago, and within a forward- looking accountability system, a pilot decided to make do a go-around due to cross wind which contributed to a severe crash when the wind suddenly increased from 20KTS to 50KTS, changed direction, and caused the aircraft to stall. The pilot was given a thank you for making the proper decision, which was to initiate a missed approach.

Forward-looking accountability is to take responsibility for reporting, willingness to admit mistakes, and taking responsibility for changes. A forward-looking accountability is a fluid, or an unstable environment since the accountability is to make decisions, as opposed to do what someone else decided for you. This does not imply that policies, processes, or procedures should not be followed, but that resilience and reacting to changes are integrated parts of a forward-looking accountability system. E.g. An aircraft mechanic discover that a tool is missing, but the tool is not needed for current or future jobs. When applying the forward- accountability principle, the mechanic notify supervisor to order the tool. It is said that it is human to error, but at the opposite end of the spectrum, humans are capable of reacting to events, or hazards, to avoid accidents. Forward-looking accountability is different than being proactive, since accountability is strategic planning at the AE position, and proactive is risk analysis at the operations positions.

Accountability that is backward-looking is determined to find a scapegoat, and to blame and shame an individual for messing up. The first stage of accountability is about looking ahead at the fork-in-the-road to find ways to do the work effectively, and the second stage is to accept the accountability.

Forward-looking accountability acknowledges mistakes and the harm resulting from it and lay out the opportunities for making changes to reduce the probability, or risk level of such harm to happen again.

Forward-looking accountability is to design airports to size and complexity of future airliners.

OffRoadPilots