Take On The AZR Challenge

Take On The AZR Challenge 

By Catalina9

Airport Operators in Canada are avoiding the AZR challenge and taking on a gambling position to protect their capital investment. An aerodrome without an AZR is to sign a blank check to the local landuse authority. Your Amazing Airport is taking the path of least resistance but also the path of greatest failure. Airport Zoning Regulations (AZR) is a unique program for Canadian airports to protect their capital investment. An aerodrome in Canada is any area of land, water, ice or other supporting surface used, designed, prepared, equipped or set apart for use for the arrival, departure, movement or servicing of aircraft and includes any buildings, installations and equipment. In short, all of Canada is an aerodrome. An airport is an aerodrome with a certificate of certification. Certification of an aerodrome is required for operations of scheduled air service, if the aerodrome is within a built-up area, or if it is in the public interest that the aerodrome is certified.

NOTE: It is always in the public interest that an aerodrome is certified.  

Once upon a time there was an airport…

For an aerodrome to be certified it must pass a test. Just as a pilot must pass a test for a pilot license, an aircraft mechanic must pass a test to conduct aircraft maintenance and most of us passed a test for a driver license. The test an aerodrome must pass is the TP312 5^th Edition test. It’s a comprehensive test. The TP312 test is not given to a person or an entity, but to the parcel of land itself. There are conditions for when an aerodrome is obligated be certified, but there are no conditions under which an aerodrome may be excused from certification. The regulator may oppose certification of your airfield if it is a private member field, is located in a rural area, or there is lack of business at your field. This year, it is 11 years ago since an aerodrome submitted to the Regulator an application for certification. The airfield passed the TP312 test, but the Regulator refused to issue a certificate due to lack of business at the aerodrome. An aerodrome without a certificate and the AZR could in the blink of an eye be reduced to a drone-field by construction of aeronautical obstructions in the vicinity of Your Amazing Airport.

There are no conditions under which an aerodrome is excused from being certified. However, there are conditions under which certain behaviors are unsuitable for a person to be the Certificate Holder or Airport Operator. The tasks a person, as a certificate holder or airport operator is required to perform to maintain their position are to design and maintain the Airport Operation Manual, maintain the Standards of TP312 5^th Edition and maintain the Safety Management System.

 

A Regulator requires Operational Control of an Aviation Document, or Certificate. Pilots maintains operational control of their certificate by training and medical certificates, an airline maintains operational control of their flight crew qualifications and aircraft maintenance. Just as an aircraft certificate is dependent of the aircraft operator, an airport certificate is heavily dependent on the operator. The difference is that an aircraft is moving all the times, while an airport is stationary. The Regulator expects operational control of all aviation documents, not just for pilots and airline operators, but also of airport operators. Operational control of an airport certificate is very different, since the certificate is issued to a static parcel of land. Operational control of an Airport Certificate is achieved by the Airport Zoning Regulations.

 

Some years ago, a finding was issued to an airport operator because a tower was built about 3 SM away from the airport. The tower penetrated the airports’ OLS and therefore became a hazard to aviation safety. Pursuant to the SMS regulations, an airport operator has based its safety management system on the safety policy and that there is a clear commitment to safety. Without an AZR in place, there is no clear commitment to safety since the airport operator does not have a tool to remove aeronautical obstructions that are hazardous to aviation. Should a structure be erected and penetrate an approach surface, the only option available to the airport is to shorten the runway. Making a runway shorter must be approved in the Airport Operations Manual and it is known that an approval may take 3-6 months. Without an AZR, an airport operator is operating outside the parameters of public interest and safety in aviation. An AZR is established to prevent lands adjacent to or in the vicinity of an airport from being used or developed in a manner that is incompatible with the safe operation of an airport or aircraft.

Without AZR the only way out is to move backwards for safety

Without an AZR in place an airport operator finds themselves between a rock and a hard place for compliance with the Safety Management Regulations. The regulations requires that there is a process for identifying hazards to aviation safety and for evaluating and managing the associated risks, that there is a process for ensuring that personnel are trained and competent to perform their duties and that there is a process for the internal reporting and analyzing of hazards, incidents and accidents and for taking corrective actions to prevent their recurrence.

 

"Let’s take a closer look at these three regulatory requirements as it relates to the TP312 5^th Airport Certificate and required tasks by the Airport Operator."

 

The first requirement is that there is a process for identifying hazards to aviation safety and for evaluating and managing the associated risks. Intent is not a hazard to aviation safety. That someone intend to build a tower on short final at Your Amazing Airport is not a hazard to aviation safety itself, since there is no structure intruding on the approach surface. Under these conditions, and without an AZR, an airport operator or the Regulator has no rights to demand that a private citizen do not erect the structure. Since the structure is not erected, an airport operator does not have in place a process to identify hazards to aviation or to evaluate and manage the risks. A plan or proposal is not a hazard to aviation safety and does not become a hazard until the moment the structure penetrate an approach surface established pursuant to TP312 5^th. The only option the operator has is to displace the threshold and shorten the runway. The Regulator has only one option, which is to issue a finding to the airport operator for not maintaining the Standards of TP312. A well-known public airport event is the Chatham silo.

 

The second requirement is that there is that there is a process for ensuring that personnel are trained and competent to perform their duties. Unless there is an AZR in place, airport personnel are without an option to be trained in obstacle management beyond the airport property and without the ability to affect the outcome of the plan.

 

The third requirement is that there is a process for the internal reporting and analyzing of hazards, incidents and accidents and for taking corrective actions to prevent their recurrence. Imagine for a minute a hazard report stating the following: “The Town is planning to build a 500-foot wind turbine 1 SM away from Your Amazing Airport inline with the approach path. When built, the wind turbine will penetrate the approach surface.”  

The one question Your Amazing Airport needs to ask and come up with an answer, is what to do about the hazard. In the case of this report, the airport operator does not have one single tool to stop or prevent the construction of the wind turbine. The only option is to close the runway. 

 

Operational control at an airport is not to manage pilots or aircraft, but to mange the integrity of the certificate and TP312 5^th Standards. The only tool is the Airport Zoning Regulations.

 

 

Catalina9

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Accept Reject Criteria

You can NOT Audit, Assess or Inspect on OPINION!

When a company develops it's Policy, Processes and Procedures, they should do so using a team made up of Subject Matter Experts, SMEs, Stake holders and especially those with the "Profound" knowledge. Dr. W. Edwards Deming, "...those who actually do the job have the profound knowledge of the job.." With this in mind, the procedures for these areas must be developed and the subsequent audit checklists are based on this procedural standard. So the auditor must totally depend on the Audit checklist for determining what is right and what is wrong. Accept/Reject criteria must be clear so that is no doubt of the requirement. Once we introduce opinion, we now have NO objectivity and have no idea what is right and wrong only what is considered right in somebody's mind!

https://youtu.be/LLmbqa02CtM

Filling in the safety gaps

Filling in the safety gaps

Written by David Carr, Wings Magazine

DTI’s risk management approach centres on fixing culture and processes.

Almost six years ago when Joe “Buffalo Joe” McBryan was having another of his legendary feuds with Transport Canada (TC), Sol Taboada, co-owner of Atlanta-based DTI Training, an aviation Safety Management System (SMS) and Quality Assurance (QA) provider, wrote a letter to the Buffalo Airways founder, offering to fix his compliance system for free. He never heard back.

Fast forward to Christmas 2015. Taboada and his entire staff are up in Yellowknife to capture Buffalo Airways day-to-day operation into a policies and procedures manual and develop a safety checklist after TC has pulled the iconic passenger and cargo operator and star of Ice Pilots NWT’s Air Operator Certificate (AOC).

The DTI Training team of Sol and Dennis Taboada
have helped numerous operators implement safer operating practices    

“The company was operating on the expertise of its personnel, which is not abnormal,” Taboada told Wings during a Toronto stopover. “Buffalo Airways have fantastic pilots and fantastic AMEs. There is a lot of knowledge, especially with the types of equipment they use (vintage DC-3s and DC-4s), which are very rare. They did almost everything right, but they didn’t have a procedure.”

Consulting and teaching private operators about procedures is DTI’s core business these days, most of it coming from Canada after Taboada and his brother Dennis, the company’s chief executive, developed and trained inspectors on the QA portion of TC’s SMS system, labelled SMS001. “First we said ‘yes’ then we hung up to find out what Transport Canada was,” he jokes.

Canada now accounts for between 75 and 80 per cent of DTI’s business. It’s a mirror reversal of when the company began delivering QA courses to the U.S. government, and was later hired by the National Aeronautics and Space Administration (NASA) to investigate corporate culture shortly after the Columbia space shuttle disaster.

DTI launched its Canadian operation approximately five years ago and has up to 12 contracted employees at any given time. “About 70 per cent of our revenues stay in Canada,” Taboada points out. “You can’t say that of a lot of American-based consulting companies.”

Indeed there is a piece of Canada in all of DTI’s symposiums, workshops and products such as the Genesis program, giving operators 24/7 access to training on all the basic aspects of QA and specifically SMS from a Canadian perspective. “The Canadian model is the gold standard for SMS,” Taboada said. “Its components will be part of all future SMS requirements around the world.”

Sol Taboada and friend 

Still, there appears to be some confusion over SMS at home, which is what convinced the brothers to branch out into operator training. “We were in Calgary and were taken to one side by a certificate holder who said training government inspectors is one thing; but nobody is training us,” he said.

From the get go, the DTI crew noticed both operators and TC inspectors deviating from the path set by the SMS001 document. “It is a cultural thing. It’s not just Canada, it is world-wide,” Taboada said. “If the SMS001 document and procedures are followed, the results are magnificent. Instead of just catching one or two non-conformances and writing a finding, we are able to determine the culture of an organization. Companies do better financially too, because they get control over their systems.

“But you have operators who have been in the field a long time – you have inspectors who have been around a long time and have done things a certain way. Now, you are saying, ‘No, you have try looking at it this way.’ So, we are seeing different regions apply SMS001 in different ways.”

Indeed, at DTI’s first SMS training course, Taboada was confronted with a regional document labelled SMS001-A. “Now we have a problem. One region is getting special treatment. This is what ties you up in court and turns everything into a mess,” he added.

Since SMS was first launched, Taboada has found that some operators have embraced the practice, while others will continue to fight it. “It is always interesting to see how a customer continues after we are gone. That is the key. Sometimes we get some guys out of trouble, they breathe easy and six months later the operation is back to the way it was.”

Can Taboada instinctively know where to look for a problem before entering a hangar and rolling up his sleeves? “When there is a consistent issue (such as flights being cancelled because of reoccurring problems with a specific piece of equipment in a fleet) there is usually a breakdown somewhere in the procedures. Somewhere something is getting missed.”

"One of the biggest obstacles to following procedures is familiarity."

“Say you are a pilot and there are 37 items on the checklist. Three of those items are no big deal so you skip those. But you can’t,” Taboada noted. “Today, you skip three; six months from now you skip a fourth one and a year from now you skip item 12. The next thing you know you are doing only half the things on the list. It’s not because we are bad but because we are human. We have a tendency to cut corners when we become familiar with something. But invariably, when there is some kind of incident, it is something that was missed.”

Dennis Taboada is always welcome in Canada!

And that is what SMS is set up to uncover. Whereas conventional TC audits zero in on individual noncompliance, SMS uncovers gaps where the internal QA system is non-conforming. “Anybody can make a mistake once or twice,” Taboada points out. “But if once or twice keeps happening over and over, you are showing a systemic failure.”

Taboada concedes that there will always be better ways to do things; but those better ways need to be tested and applied to the manual before becoming standard practice. And this may be one of the great revolutions in policies and procedures; the manuals they are a changing. Perhaps too quickly for some.

“SMS says you can run the business anyway you want. If it take five sentences to get across a message where it used to take 20 sentences that’s okay,” Taboada said. “So, when an inspector says, ‘I don’t like the way your manual is formatted, the correct response is, ‘I couldn’t care less . . . the manual works and everything is in it.’  

“We are seeing that more and more in aviation. You can write up a 25 step procedure on how to strap a barrel onto a helicopter, or you can boil that done to three steps with a picture; it needs look like this.” Heading back north to Yellowknife, Buffalo Airways is reporting less down time and fewer engine failures since following the safety checklist the DTI crew assembled and submitted to TC. “It has been getting better, but you are dealing with old airplanes, so there will always be a maintenance issue,” Taboada pointed out.

Taboada admits that Buffalo Airways was “spotty” in its record keeping. Still, the DTI co-founder is not letting TC off the hook for the way the regulator handled the file. “Transport Canada was absolutely correct. Our problem was they did not follow their own procedures. How they went about suspending the licence was wrong.”

DTI had proposed a “gatekeeper” to double check procedures before a flight was released. This was rejected by the regulator. “The only way you can test a plan to make sure it works is to use it and see if there is a recurrence of issues. That is Transport Canada procedure,” Taboada noted.

“There were a number of times when Buffalo Joe and I were like this,” Taboada laughed, raising his fists and strikes a traditional boxer’s pose. “I have no problems telling people when they are full of it. And he had no problem telling you right back. But we had an interesting working relationship. The grounding cost Buffalo Airways at least $2 million, but they never laid a single person off. You have to respect that.”

-       See more at: https://www.wingsmagazine.com/news/filling-in-the-safety-gaps-14262#sthash.dpP6rhlX.dpuf

Written by David Carr

For more information: dtiatlanta.com