Thursday, March 9th, 2017
ICAO provides a global framework of Standards and Recommended Practices (SARPs) establishing a regulating floor as a basis for initial acceptance of flights amongst member states. SARPs cover all the main areas of aviation safety and ICAO runs monitoring and assistance programme globally to promote compliance. ICAO has placed requirements on States to ensure effective implementation of Safety Management Systems for both regulators and industry, reflecting modern-day thinking on how to complement and enhance traditional compliance-based regulation.
Regulatory Environment Our Nig CARs are based on ICAO SARPs but go wider and deeper, covering all domains of aviation safety: airworthiness operations, personnel licensing, aerodromes and air flight management NCAA ensures implementation and monitoring by means of an auditing programme.
How well is this being done and what results are we getting?
Compliance does not necessarily guarantee safety and the fact that you have no accidents does not mean you are safe.
The Traits of a Safe Organization
In general terms, safe organizations:
* pursue safety as one of the objectives of the organization and regard safety as a major contributor in achieving production goals;
* have developed appropriate risk management structures, which allow for an appropriate balance between production management and risk management;
* enjoy an open, good and healthy safety corporate culture;
* possess a structure which has been designed with a suitable degree of complexity, standardized procedures and centralized decision-making which is consistent with the objectives of the organization and the characteristics of the surrounding environment;
* rely on internal responsibility rather than regulatory compliance to achieve safety objectives; and
* respond to observed safety deficiencies with long-term measures in response to latent failures as well as short-term, localized actions in response to active failures.
Regulatory compliance by itself achieves very limited safety objectives.
The airline operators are generally in compliance with the Regulations which prescribes the scope of safety to be achieved.
They go through vigorous AOC assessment before being issued AOC. Thereafter NCAA carries out periodic audits and some measure of monitoring through base inspections and line checks.
Suffice to say that some organizations don’t deserve to hold an AOC because they don’t keep the structures in ground that AOC requires for commercial operation. The structures presented for AOC issue are hardly sustained for maintaining the AOC.
NCAA monitoring results in corrective action being carried out by the operators but this does not go deep enough to address risks. Hence effective implementation of Safety Management System is very vital to improving safety.
What must NCAA do to actually ensure compliance or improve on compliance?
Certainly not by increased inspection but rather by continuous monitoring approach similar to ICAO CMA
Emphasis should now be on safety analysis, studies and surveys
This requires data gathering i.e. create safety database – MOR, SDR etc
Hence the need for Research and Development Unit in NCAA
This has been suggested over the years which NCAA has turned deaf ear to. No Authority can go into the future without this.
Safety management requires data and a lot of analysis which very few airlines have put in place.
How does the Regulator identify safety trends in an organization? What parameters or indicators have they established as guide?
Regulatory Safety Audits
The checks carried out by the Regulator are intended to assess safety performance.
Address 3 elements:
a. Surveillance and compliance with requirements
b. Areas of organizational risk and the systems in place to manage these risks
c. Competence and performance
NCAA is presently working on SSP as required by ICAO. The base requirement for an SSP is to set out how an acceptable level of safety performance in aviation is achieved by the State. This, I understand, the NCAA is relentlessly working on and coming up with key Safety Performance Indicators (SPIs) and Action Plan.
Risk identification is pivotal to our effectiveness. Need to develop our data classification and analysis to ensure we get the right information.
What is our Regulatory Authority doing to improve their effectiveness?
We must have a robust State Safety Programme (SSP)
Focus on factors that could lead to high-risk outcomes
Identify the main aviation risks that could cause fatalities – high risk outcomes
What are the most frequent scenarios that led – or could lead to – these high risk outcomes?
Conduct detailed analysis of the root causes that lie behind these risks
Common to all these scenarios are causal factors such as human performance or technical error environment, infrastructure, bad weather.
Evidence-based proactive approach to Regulation
The risks to the total aviation system in Nigeria need to be better understood as each individual and organization in the system has a unique risk profile. To continue to improve aviation safety, the direction is now moving towards a performance-based oversight model – Enhancing Safety Performance (ESP).
We must take a total system view of the aviation sector and new business models such as increased wet leasing, transnational organizations and new commercial arrangements for the provision of services. Aviation security advances may also have safety implication. Consequently, we should be able to bring security, commercial and legal expertise to bear in order to improve safety outcomes.
The international regulatory framework governing aviation safety is constantly being developed and refined to respond to evolving needs and to address the needs a proactive and progressive global industry. One example is the move from compliance-based to performance-based safety regulation. It must be recognized that it is crucially important not only that the right regulatory changes are made but also that such changes are introduced in a manner that minimizes the safety and economic risks inherent in implementing change.
We need to go well beyond rule making and compliance checking, with increasing emphasis on data collection and analysis, on research, on identification of major safety risks in a safety plan and on the use of non-legislative measures to mitigate risks.
Need to improve the coherence of the work across the full spectrum of aviation activities to deliver the more comprehensive regulatory ESP brings
What does Performance Based Regulation (PBR) mean and why is it important?
PBR is a regulatory approach that focuses on desired, measurable outcomes and goes beyond safety compliance of operators. The regulator sets objectives for the achievement and demonstration of safety, requiring operators to show (by argument and evidence) that those objectives are met. It aims to identify risks across the aviation system and develop effective ways to manage and mitigate these risks.
By thoroughly assessing and priotising risks at an organization, sector and total risk level, resources can be better optimized, allowing Regulators to focus on what delivers the greatest improvement to safety performance.
PBO (Performance Based Oversight) ensures organizations are monitored according to their safety and risk levels, focusing both the Regulator and Industry on the actual underlying safety risk rather than purely focusing on compliance.
PBR affects all safety related areas of a Regulator. Consequently a transformation to PBR is likely to include changes to how the Regulator is structured and organized.
Need for Performance and Process Improvement Programme PPIP
In order for the Authority to meet the challenges and exploit the opportunities that lie ahead, it must be recognized that the internal systems need a significant update.
Need to focus on those safety issues that matter most, to make better regulatory decisions and capitalize on current processes and systems to provide a much better and more efficient service to stakeholders.
In order to improve Safety Performance the Authority needs to adapt its structure to address the needs of a changing aviation industry.
UK CAA recognized the importance of formal project management in ensuring the efficient delivery of planned outputs and have accordingly appointed a business management team within their SARG.
GCPT Sam Ojikutu
Secretary General ART