INADEQUATE OVERSIGHT OF PUBLIC USE AIRCRAFT

by Joe Del Balzo on December 5, 2011

The following statements from Bloomberg Business Week, Nov. 30 are attention getters and serve to remind us of the importance of sound safety oversight.

“More people have died in crashes on government aircraft, which are exempt from most U.S. safety regulations, than on commercial airliners over the past five years, the first time that’s happened over a similar span.”

“U.S., state and local government agencies operate or hire hundreds of helicopters, single-engine planes and jets, according to National Transportation Safety Board records. These flights aren’t regulated by the Federal Aviation Administration, which oversees commercial and private flights.”

“While government agencies may impose their own safety rules and conduct inspections, standards vary and rules are sometimes not enforced, safety-board investigations have found.”

“Government agencies, many times, start out with sound procedures,” John Goglia a former safety board member said in an interview. “Over time, people don’t follow procedures and insufficient oversight prevents the slow deterioration of best practices from being picked up.”

“This has always been the black hole of aviation safety,” Jim Hall, a former safety-board chairman, said in an interview. “There is absolutely no reason that the government is not required to adhere to the same standards as everyone else in terms of aviation regulations.”

John Goglia also made the point that “Industry would never go as long as government without an audit to insure we are using best practices and following our own procedures.”

There is at least one government agency that I know is doing it right.

Although not required to do so, Federal Aviation Administration (FAA) operates and maintains a fleet of aircraft in accordance with Federal Aviation Regulation (FAR) Part 135, including the maintenance of their aircraft fleet to the high standards of a Continuous Airworthiness Maintenance Program (CAMP), which is also required and used by the civil air carrier industry. All maintenance and engineering services are accomplished in accordance with the policies, procedures, and guidelines required of similar civil and commercial sector activities. FAA also has a formal Internal Evaluation Program (IEP) and an oversight office that conducts external audits.

There are positive steps that operators can take today to ensure that their procedures are consistent with FAA policies, procedures and guidelines required of civil and commercial operators. It starts with an independent operational safety audit to determine the level of conformance with key operations, maintenance and safety department-related requirements and industry best practices.

When JDA performs these audits we start with an assessment of an operator’s manual system against the Internal Evaluation Program (IEP) checklist that we have developed for Part 135 carriers. Following completion of the Design Assessment, we then assess the actual performance of employees in order to determine whether the processes and procedures detailed in the manual system are being followed and are effective in practice. The end result is a set of recommendations related to industry best practices for improving the operation and manual suite. As SASO comes into play in 2013, the Design Attributes will need to be documented in their manuals against which actual performance will be assessed (Performance Attributes).

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What kind of relationship do you have with the FAA?

by Mike Rioux on November 18, 2011

The Department of Transportation (DOT) and the Federal Aviation Administration (FAA) have recently taken a much tougher stance on enforcement actions with air carriers, manufacturers and maintenance repair organizations. The number of fines and enforcement actions has increased year after year. Whether this tougher enforcement stance is warranted remains to be seen. Critics postulate that the punitive approach will make certificate holders hunker down and abandon voluntary reporting given the possibility that the report will result in a fine. Hard-line enforcement types say it protects consumers and ensures operators toe the line.

Traditonally, the avaition industry has taken a reactive approach to dealing with Letters of Investigation (LOIs) and enforcement actions. The FAA issues an LOI, and the certificate holder reacts (defensively) and does not understand or agree with the action taken by the regulator – typical and not unexpected. As a result, the business relationship between certificate holder and the FAA becomes more contentious.

What kind of relationship do you have with your FAA Certifcate Management Office or Flight Standards District Office (FSDO) principal inspectors? Do you treat them like the enemy and , respond defensively, or are they your best golfing buddy? Hopefully neither of the cases apply to you or your organization!

Here are some suggestions for creating a positive and professional business relationship with the FAA.

  1. Create a regulatory affairs organziation or FAA/industry liasion group – name is up to you but it should define the role.
    1. The size of the regulatory affairs organization should refect the size and complexity of your company – a 1-person department or a 4-6 person staff are both OK.
    2. Have a regulatory affairs office and locate it close by where FAA personnel arrive at your facility – even a sign that says FAA please check in here may be appropriate.
  2. Create a regulatory Standard Operation Procedure (SOP), forms and data reports.
    1. Dessiminate information throughout the organization so employees are aware of your process and procedures – conduct all-hands training as necessary.
    2. Ensure all other line stations or other company locations that receive FAA inspectors are trained and use these procdures – consistency is the key!
  3. Treat the FAA like a customer: Assist the FAA whenever they show up at your facility.
    1. Log their name, time in and out and purpose of the visit– keep these records.
    2. Escort the FAA while they are conducting business. If they are attending a meeting drop them off, and ensure someone escorts them after the meeting.
    3. If the FAA requests copies of records or files, ensure that they are provided with copies promptly. Make sure you log what they received, take notes during any visit and enter the information into a data file.
    4. When you are with the FAA representative, listen more and speak less – no one ever learned anything by talking and what you say may come back to haunt you.
  4. Establish great record keeping standards. This applies to the entire organzition not just Regulatory Affairs.
  5. Become knowldegable of regulations and FAA policies. The www.faa.gov website is a great resource, but it is complex, so make the necessary time to become familiar with the site.

“We’re not one big happy family.” Your job is to build a positive working relationship with the FAA. Creating a pseudo-family isn’t part of the job. You should absolutely be friendly, but you should not be best buddies. Don’t say you have the interpersonal and professional skills to strike the right balance, because you don’t - no one has that ability.

“You won’t have all the answers and neither will the FAA.” Just because someone works at the FAA, does not means that all their views and opinions are valid. Positions and promotions don’t always come with wisdom. Always assume you don’t have all the information you need to make a great decision or respond to a request; that way you’ll listen more than you speak.

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"Is it Legal?" versus "Is it Safe?"

by Jim Hobart on July 27, 2011

When your organization complies and meets the regulatory requirements necessary to operate then that is considered being legal and safe by the FAA. Is there more that can be done to be “Safer?” The FAA, through its various policies, processes and procedures, determines what is “legal;” anything less compliant than that, therefore, is “Illegal” or more commonly referred to as non compliant. The FAA sets the minimum standards to which any operator must adhere and they set these minimums because they are the criteria that provide the minimum level of safety. What does that really mean to the overall level of safety?

We can assume with absolute certainty that the FAA has the mission “to provide the safest, most efficient aerospace system in the world.” In recent years, the FAA has mandated enhanced safety systems such as Traffic and Collision Avoidance Systems (TCAS) and Enhanced Ground Proximity Warning Systems (E-GPWS) among others. But, what else can we, as the operators, do to enhance our level of safety?

Safety Management Systems (SMS), if followed, will certainly enhance an operator’s safety presence and risk identification and mitigation. JDA firmly believes in the benefit that SMS can add to any organization and has been licensed by MITRE/CAASD to be an SMS training provider. The questions though are, “What is SMS?” and, “How can SMS enhance an operator’s safety system?”

With a good implementation plan, strong senior management commitment, a robust reporting system, expert support and a solid manual system, SMS can be managed like any other program within your company. It does not have to be an overwhelming and complex task that requires excessive resources. Yes, there might be some manual re-writing involved, but usually an operator’s manual system already contains many of the requirements and procedures to satisfy the SMS protocols. JDA offers consultative services to assist operators in getting their SMS in place. Additionally, JDA has auditors on staff and has associates that can perform a Gap Analysis to determine what or how much has to be done to get a fully functional SMS in place.

Although not yet required in the US, SMS is currently required by some countries to operate within those particular countries. The responsibility to prove an operator has an SMS is left up to that operator. One way to provide proof for Part 91 operators is through an IS-BAO audit. This audit is a third-party verification of an operator’s SMS manual system. JDA offers IS-BAO audit services as well as SMS and Auditor training. Auditor training is essential to make certain safety personnel are aware of all that is necessary to ensure all aspects of an operator’s manual system conform to the SMS Audit Protocols.

Being fully trained in audit procedures, completing the SMS requirements and becoming IS-BAO accredited are some of the “extras” that go beyond the minimum requirements of safety. These elements add to any operator’s safety system and are best practices that help mitigate risks, enhance safety, reduce liability, and limit exposure. JDA’s full line of aviation safety training and certification services adds quality and safety to an operator’s procedures and processes.

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Keep me a Sane Air Traveler: Follow these 12 Simple Tips

by Mike Rioux on April 18, 2011

Airport SecurityAir travel used to be enjoyable - remember those days? The problem with air travel now is not just the airlines, over booked flights, long security lines and inspection, which is a given. The problem is passengers, who demand too much for too little. It seems that the comparatively low cost of air travel has created a new type of airline passenger who shows up in flip flops, cargo shorts, tee shirt and backpack at Boston Logan in February heading to Atlanta.

Air travel should be simple: take me from point A to B safely and on time; don’t lose my luggage (especially if I pay for the privilege); no need to feed me or quench my thirst; and no need to provide entertainment as I can either read a book or do work.

Being in the aviation business we travel frequently and outside of airline delays (and terrorists); there’s nothing worse than having to deal with a clueless traveler. You know the ones that cause huge delays in lines and make the flight just miserable. They are the ones you want to introduce to your alter ego, whoever that may be at the time.

So in an attempt to help make air travel a little easier to bear, here are some simple and common sense tips on how to be a better traveler and reduce your risk of someone tipping TSA off that you need a cavity search because you were muttering something about “bomb in my backpack.”

1. Packing: If you have to sit on your roller bag to close it you have too much stuff - leave something home. You are returning, and wherever you are going, I’d bet they have stores there. Overstuffed bags decrease the chance it will actually fit in the overhead (see below points on use of the overhead). Better yet check the bag - it’s free on Southwest and worth it to pay the fee on other air carriers. There is nothing worse than a swimmer on a single isle 737 trying to find empty overhead bin space. More on a swimmer later.

2. Airport Arrival: Get there EARLY. Wake up earlier. I did. You can too. Now, if you’re late because of a car accident or because your connection arrived late, that’s cool. If you’re late because you can’t plan - sorry the sympathy locker is closed. Here is a news flash - airports are more crowded and security checks are slower. Arrive earlier. Have a drink at the gate or something.

3. Security Part 1: GET YOUR ID AND BOARDING PASS OUT. 2nd news flash - TSA will ask for a government issued ID - no option. When you get up to the TSA agent after standing in line for 20 minutes and you take two minutes rooting through your bags/wallet for your ID, it makes my head explode and more importantly slows up the line. Doing this is the equivalent of standing in line at Burger Doodle for 20 minutes and when it’s your turn to order you begin reading the menu to figure out what you want. Be prepared with ID and boarding pass.

4. Security Part 2: THEY’RE METAL DETECTORS PEOPLE! Please don’t be the guy who goes through, sets it off, and then remembers he has 43 keys and a steel ball bearing in his pocket. Empty your pockets. This shouldn’t be a surprise. This guidance also applies to all your toiletries. The guidelines are simple. Follow them. Otherwise we get to stand there thinking of various ways to give you a Vulcan mind probe while you go cycle through the metal detector seven times.

5. Security Part 3: Once you’ve successfully navigated the x-ray and metal detector, it is not the time to repack your bag, tie your shoes or primp your clothes. While you’re repacking, stuff is piling up on the x-ray belt and we’re all waiting for you to get out of the way. Grab your stuff, move along, and commence repacking operations in the always-empty Mango juice lounge on the other side of security.

6. Boarding Part 1: Zone 4 means Zone 4, not “Zone 1 because no one can see the Zone 4 on your boarding pass.” Board when called. Simple concept - even Southwest figured out they had to give us cattle call numbers to maintain some semblance of a boarding process. It’s like grade school - no cut ahead, no do-over, stamped it to infinity plus one.

7. Boarding Part 2: If the overhead is closed, it’s probably full. Don’t open it to see if you can squeeze in your oversized bag. If it doesn’t fit check it! Oh by the way, don’t leave your bag in the aisle or elsewhere for the flight attendant to take care of it. If a flight attendant gets injured lifting your 75 lb bag, you are most likely not going anywhere until they find a replacement. Put your bag in the overhead bin over your seat. None of this “chuck” it in the first overhead you see then saunter back to your seat in row 25 stuff. If you’re in the back, bring your bag with you. They have overheads back there too. When you put it in the overhead in the front row, you create a chaotic process of bag shuffling, bag gate checking, and swimmers - which are passengers working their way back to their seat ‘upstream’ while others are still boarding.

8. Boarding Part 3: SIT DOWN. If you’re having trouble juggling your triple grande iced mocha decaf double whip half cream half milk latte, your 6 magazines, family-size bag of Doritos, liter of Pepsi and your iPad, maybe you need to rethink your carry-on strategy. Sit down. Let everyone else board so we can get seated. Related: 1 carry-on and 1 personal item mean just that. It doesn’t mean 1 oversized bag + 1 fanny pack + 1 souvenir too big to ship + 1 laptop case. I’ve stopped blaming the airlines in most cases for late departures and now lay the blame on the people who can’t get seated in a timely manner. Oh by the way, visit the rest room before you board - don’t go to the can during the boarding process.

9. Portable Devices: Despite what Bill Maher told Captain Sullenberg on HBO a couple weeks ago, Bill’s opinion about turning off portable electronic devices doesn’t matter. It’s a rule: no PEDS until advised - just comply period. Off with the smart phones, GPS, lap tops until we get to 10,000 ft - same thing applies on approach and on arrival.

10. Seat Backs and Tray Tables: Nothing worse than squeezing into a coach seat with 21″ seat pitch and having the guy in front of you recline his seat all the way back. Nothing better than getting your tray table and lap top jammed in your gut. Before you recline, look behind or better yet ask if it’s OK to recline your seat a little.

11. In Flight: If you strike up a conversation, good for you. If you are instead greeted with monosyllabic replies and furtive attempts by your seat partner to extricate their attention back into their book, take the hint. They don’t want to talk to you. And if you do find a chat partner, please keep it below 800 decibels. If you insist on bringing your own food aboard, please rethink the tuna sandwich with garlic and onions and the family-size bag of Doritos.

12. Deplaning: Wait your turn; exit by row. Nothing worse than the guy in the back of the bus rushing to get four rows ahead. If your bags are stowed four rows behind your seat, wait until the aisle clears. You are safely on the ground and they are not giving away your rental car.

Woody Allen said 80% of life is just showing up, but in the case of air travel that does not work. If you are better prepared when you travel and think about what is coming next, then the trip will be more enjoyable for all.

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Rhyme and Reason

by Dustin Wilcox on February 7, 2011

It is important that the use of cell phones and PEDs onboard aircraft is controlled

Recently, I was on a flight and heard an all too familiar announcement, “The cabin door is now closed. Please discontinue the use of all electronic devices.” It appeared the voice on the PA fell on deaf ears. I saw people continue to type away on their phones. Most eventually turned them off. One individual continued typing away even after a flight attendant asked him directly to turn it off. By the time we took to the runway, he had begun to power down. But it’s hard to ignore how long he failed to follow the announcement/request. Were we in any danger? Most likely not, as we were only taxiing. Still his action, or lack of, was a disregard for the rules.

Not too long ago, a well-known person was involved in a dispute on an aircraft regarding phone use after being told to turn it off. Reading the comments was entertaining. I had no idea so many people were A&Ps, engineers, or electronics experts. The basics of the comments were: “I leave my phone on all the time and nothing happens” or “I have yet to hear of this causing a crash.” Maybe they’ve been lucky, or the “right” set of circumstances hasn’t happened, or maybe they are right and there is no issue. But who wants to find out the hard way?

It’s often said that many regulations are written in blood. Thankfully this isn’t one of them. The general public can’t begin to fathom the complexity of modern aircraft and navigation. They don’t understand the complexity, so they can’t understand the basis for the rule.

I’ve found that people follow rules better when they know why they were formulated (try explaining to Joe Public a fly-by-wire aircraft shooting a Cat III approach and all the intricacies involved and how the electronic field of his phone could affect it). This is an important point when working with your SMS. As you receive risk reports and make assessments you will most likely begin to modify existing procedures or adopt new ones. As these are rolled out, employees should be given an explanation as to why (through your feedback loop and safety promotion program) the changes are occurring. Explaining will help clarify in their minds why the old procedure is wrong and should not be followed anymore or why a new procedure was needed. In places with a less than ideal culture, I’ve heard employees complain of changed or new procedures and saying that management just changed the procedure to annoy them as a consequence of some previous issue when often there are solid safety issues supporting the change.

Federal Communications Commission (FCC) rules prohibit the use of cellular phones using the 800 MHz frequency and other wireless devices on airborne aircraft. This ban was put in place because of potential interference to wireless networks on the ground.

In addition to the FCC’s rules, the Federal Aviation Administration (FAA) restricts in-flight use of PEDs such as wireless devices because of potential interference to the aircraft’s navigation and communication systems. The basis for the portable electronic device “rule” came from the RTCA/DO-233 “Portable Electronic Devices Carried on Board Aircraft” and the FAA Advisory Circular (AC) 91-21.1B.

I can’t give you the details of the report but considering that the RTCA conducts thorough studies and analysis there is probably evidence that the potential for PED interference exists, even if it is remote.

It is important that the use of cell phones and PEDs is controlled, especially during early parts of flight because that’s when most of the safety information is being given. They are afraid people will be distracted by talking on a phone or listening to an iPod and therefore not listen to the safety announcements.

Do your best to follow them and believe that they are there for a reason.

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When It Comes to Safety, Looking Back and Lead to Progress

by Dustin Wilcox on January 18, 2011

Looking back at the events and regulations that went into effect in 2010 and will be a big factor in 2011A new year is upon us: another chance for us to improve our safety. As American philosopher George Santayana once said, “Those who cannot remember the past are condemned to repeat it.” Now is a good chance for us to look back at the events and regulations that went into effect in 2010 and will be a big factor in 2011.

For U.S. operators, 2010 saw a lot of change. These include the Flight Crew Duty/Rest Time Notice of Proposed Rulemaking (NPRM), bill HR 5900 (flight time requirements for 121 pilots), helicopter hospital emergency medical evacuation service (HEMES) NPRM, and the ICAO Safety Management System (SMS) deadline.

The Flight Crew Duty/Rest Time NPRM was contested by the airlines but had lots of support from Congress, the flying public, and a majority of pilots. The Colgan crash in Buffalo was tragic and a review of the pilots’ work schedule put this proposed rule on a fast track. A review of the crew duty/rest time had long been a hot topic among many groups but failed to make any ground until Buffalo. This rule, coupled with HR 5900, could have drastic effects in the aviation industry.

Debate continues on the basis for the rule and its scientific basis, and it is hard to say how the final rule will look. But you can be sure flight and duty time rules will change in some way, with a ripple effect throughout the industry. While the Colgan pilots’ work schedule was a factor in getting the topic to the forefront of public attention, their flaunting of the grey area on commuting to their work base was also a big factor in the fatigue that contributed to the accident.

BHR 5900 also resulted from the Colgan crash. The bill would require that both pilots operating an aircraft under 14 CFR Part 121 have an ATP and 1,500 hours of total time. This is a drastic increase from today’s requirement for First Officers to have a commercial pilot certificate (typically a 250 hour minimum) with an instrument rating and training in the aircraft. While both pilots in the aircraft that went down met the flight time requirements, the argument is that a large number of pilots who join the regional carriers have substantially fewer hours, may be less safe, and letting this trend of low-time pilots continue is not in the public’s best interest. The big debate becomes quantity versus quality. Does having more time make you a better, safer pilot? If it does (which I don’t believe), where are future pilots supposed to build this time?

HEMES operations have long been under the eye of the FAA. Their safety record over the past few years has been less than desirable. The NPRM released in 2010 seeks to address the safety shortcomings and will have drastic effects for the entire HEMES industry. Unfortunately given the industry’s safety record, I’d say this has been a long time coming. No one can debate that these aircraft often operate in tough environments with multiple off-site landings and weather conditions to deal with, but there is always room for advancement.

November brought about the long-awaited and much-talked about SMS requirement. For the most part the deadline came and went in the U.S. with little notice. The FAA recently released an NPRM on SMS but is no closer than that to setting forth requirements. The only people worried are those travelling to foreign destinations where the SMS requirement has already been implemented. Even then it’s still unclear as to what will suffice as having an SMS. Many just want a manual shown when they are ramp checked, but anyone who truly knows safety knows that having a manual doesn’t mean you have SMS. It just means you have a stack of paper with words on it. SMS is so much more than the manual, and it can be difficult to set up. There will be hurdles to overcome, especially for small operators, but SMS is here.

The year 2010 was a good one for aviation safety in the U.S. in terms of accidents, but there is lots of room for improvement. I can think of numerous overruns, ramp rash, and in-flight events that occurred. Each one is a chance for improvement. Between these chances for improvement, plus the upcoming rule changes, 2011 looks to be a busy year in safety.

A happy and safe new year to everyone.

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Safety: Not just a flight issue

by Dustin Wilcox on December 22, 2010

There is a very big misconception about the aviation industry. A majority of the public think only two jobs exist within our industry: pilots and flight attendants. If I had a nickel for every time I was asked if I was a pilot when I told someone I worked in aviation, I wouldn’t be sitting here writing this blog.

This misconception seems to carry over into safety programs as well. I can’t tell you how many safety manuals and programs I’ve seen that purely focus on the flying aspect of our industry.

It’s easy to understand why this misconception exists.

Everyone sees the airplane as the representation of the company. They never see all the people working behind the scenes to get that airplane in the air. Also, the worst case scenario for safety concerns is an airplane crash. But think of this:

One major carrier that is headquartered in Texas has 79,000 employees worldwide. Of those 79,000 employees, 11,500 are pilots, 18,000 are flight attendants, and 9,500 are mechanics and ground service/ramp personnel. These three positions make up almost 50% of the total workforce that are directly involved with the aircraft.

But that also means another 50% of the company is not involved directly with aircraft. These people fill the HR, Accounting, IT, Tech Pubs, and Legal departments, among many others. Having a safety manual/program that is solely focused on the flight side leaves almost 40,000 people out of the picture.

A hiring manager may not have to worry about an airplane crash, but the injuries they could incur from slips/trips/falls, lifting, and repetitive motions could also create a high financial and resource burden on the company, not to mention the overall goal of keeping all employees healthy and safe.

An SMS should work for all employees of the organization. Ignoring half of your workforce when developing a program is setting your system up to fail and promotes a negative safety culture (they don’t care about us, why should I worry about being safe?).

Everyone within your company has an equal right to work in a safe environment. Review your safety program/manual. Is all the wording and programs based around those that directly interact with an aircraft? Is anyone on your safety committee representing all the employees who support your operation?

It’s never too late to adapt your system to meet the entire organization’s needs.

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Applauding Safety

by Dustin Wilcox on December 6, 2010

Applaud SafetyIt’s that time of the year again. No, not the holidays. Safety requirements! About these, there are two things you should be aware of: the FAA recently released the NPRM for SMS, and the ICAO deadline for SMS passed a few weeks ago. Which could mean, if you have any plans to visit, for example, the Bahamas over the holidays you might get a friendly visit from a certain someone. Nope, not Santa Claus. Upon landing you might be greeted by a ramp inspector checking your compliance with SMS. If you don’t meet one of their means of compliance, you will be denied entry. That certainly could put you in a “Ba-humbug” mood.

All too often safety and SMS focus on the negatives. We are always looking at what happened, or almost happened, in a bad way. We ignore all the things that happen on a daily basis that ensure we stay safe. The ramp worker who goes out of his way to coach a new hire on the safe way to do something; the office employee who notices a hazard outside the dispatch center and alerts building maintenance before someone gets hurt. These little actions take place every day and usually go unrecognized. Safety programs are often viewed in a negative light because we are always looking at the bad things that can happen. I rarely see the safety positives highlighted other than at once-a-year safety award ceremonies.

At a former job we had flown to Love Field in Dallas in a Gulfstream V. We were only going to be there for a few hours and because of the aircraft’s size, we were placed a fair distance from the FBO. As we were getting ready to leave, we had to taxi through a long row of aircraft that had arrived after us. The FBO placed a lineman at the nose of every aircraft we were going to taxi by to ensure wingtip clearance. We safely passed through, gave the marshaller a quick wave and were on our way.

That was seven years ago, well before SMS was the buzz that it is now. This kind of above and beyond effort for safety warranted a phone call or a letter to the FBO manager commending him and his crew on their approach to safety. Recognition like this always helps to promote a safety culture within any organization (reinforcing a safe behavior is a sure way to encourage the safety culture). Also, sharing something like a letter recognizing their safety actions will instill a sense of pride in frontline workers and ensure they continue the behavior.

Pursuing a safe work environment doesn’t always have to be doom and gloom. Safety managers need to strive to recognize positive safety contribution on a frequent basis. Let someone know they are doing it right and highlight it to everyone else as well. Your internal safety reporting program is a great way for employees and managers to share the positive safety information with the Safety Department for recognition.

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Where Safety Meets Responsibility

by Dustin Wilcox on September 27, 2010

Nearly every time there is a highly publicized safety event, the employer comes under fire for not doing enough to provide a safe working environment for employees. Sometimes the criticism is warranted; sometimes it happens because blaming the employer is easy to do. No one ever likes to point out that individuals hurt or killed in an accident may have been responsible for their own misfortune. Yet, sometimes this is the case. Employers need to be responsible and provide the necessary training, equipment, tools, and manpower necessary for things to be done safely. All too often the responsibility for safety is thought to end with employers, but this is wrong. Safety is a two-way street. Not only does the employer need to be responsible for safety, so does the employee.

I’ve worked in various safe and unsafe jobs in a multitude of industries in my career. I like to think I’ve seen it all. I’ve had employers that provided every piece of safety equipment you could imagine, and I’ve had the others that didn’t provide anything. More times than I care to admit, I’ve seen colleagues ignore every safety precaution set by the company and perform an unsafe action. Luckily all turned out well, but what happens when things don’t go well? The employee gets hurt and possibly the company gets blamed for not doing something. Employees have just as much responsibility for safety as the employer. The ultimate responsibility to be safe falls on the employee. He or she must actively make the decision to use the tools provided and follow the policies and procedures set forth for their safety. If their employer isn’t doing what’s needed to provide a safe environment, the employee has the responsibility to point this out or take action to address the problem, whether it is refusal to work or bringing the situation up to higher authority.

Recently the FAA released its Notice of Proposed Rulemaking (NPRM) on flight duty and rest times. The proposed rule was met with both positive and negative reaction. While this has been a hot topic for years, it took the unfortunate crash in Buffalo to force something to happen. While a number of causes were listed by the NTSB, one specifically was that the pilots’ performance was likely impaired by fatigue. Let’s not debate regional pay scales and work schedules, but these pilots had a responsibility to their company and passengers to make the right decisions to meet the required rest rules. Instead of resting during their required rest period, they made the decision to spend their time commuting in a quasi rest state. Assuming the employer was following all the rules when scheduling, this left the responsibility of adhering to the rules to the flight crew. There is no doubt that the crew knew that what they were doing fell into a very gray area.

We can only hope the eventual final rule will help prevent a future Buffalo crash. Even with the new rules, it always comes back to a shared responsibility of safety. The employer and employee must work together sharing the responsibility to provide a safe environment for everyone.

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The Jack of all Trades aka The Safety Manager

by Dustin Wilcox on August 17, 2010

As the aviation industry transitions into a world of SMS, the role of Safety Manager is evolving and has been brought into the lime light. Before today’s safety environment, this job may have been in a back office, processing reports and occasionally providing information to upper level management, but in today’s world the job is at the forefront of the larger safety program and all it encompasses. Safety is no longer crunching data from something that has already happened, it is actively pursuing and watching for the next potential risk.

To be a Safety Manager in today’s safety world, a person truly needs to be a Jack of all Trades. They need to know about flight operations, maintenance, dispatch, ground operations, cabin activities, airport operations, security, regulations, process design/improvement, data collection/analysis, report writing, presentation development, auditing, determining and assessing risk, industry happenings, and so the list goes on. The person that takes on the role of safety manager needs to have a grasp and understanding of all those topics and more.

A Safety Manager may be stronger in some fields than others, but that is what the rest of the safety department and subject matter experts are for. I’m bewildered when I see job listings for safety managers that list an ATP, jet time, and thousands of hours of flight time as a job requirement. Am I missing something? Is this person going to be a pilot or a safety manager? Why does the safety manager need to be jet qualified? Does being a pilot automatically give you the skills I mentioned? Being a highly experienced pilot has no correlation to being a successful safety manager. The Safety Manager needs to be able to read, understand, and correlate information on a wide variety of topics in aviation. Can you find someone who has experience/knowledge in all these areas? There may be a few in the industry, but you truly need someone who knows the basics and is willing to learn and isn’t biased based on their individual strengths.

For larger organizations, such as 121 air carriers and large 135 operators, finding and hiring a safety manager would be fairly easy. For small operators such as single aircraft 135s or corporate operations, the resources and finances necessary to hire a safety manager are minimal or nonexistent. The job often gets assigned to someone with an already full time position and safety is a secondary, or backburner, job. This makes it difficult if not impossible to implement and manage a full, functioning SMS. A dedicated safety manager with the appropriate knowledge and experience is necessary to be successful. If you can’t meet your Safety Manager needs, but still want the knowledge and experience, there is always the JDA Virtual Safety Office (VSO) option. Contact us for more information.

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Taking Care of the Client

by Gene Bloch on May 24, 2010

Having worked for over twenty-five years in the fields of telecommunications and aviation, I have engaged with many major clients including Bloomberg L.P., Southwest Airlines, Lehman Brothers, MCI International and Republic Airways among others. As a result, I have been afforded countless opportunities to learn about what constitutes a successful project and a positive client-vendor relationship. Over time, these learning experiences have coalesced into a set of key guiding principles that ensure a successful outcome when supporting a client on an important initiative.

First, never lose sight of the fact that you are dealing with people and not just a company. Take the time to find out what the key drivers are for the people you are interacting with, and ensure that their needs are met to the fullest extent possible. A client’s success and your own should never be viewed as mutually exclusive. In fact, it is exactly the opposite - if client people succeed in their roles, then your firm will be successful as well.

Second, part of ascertaining your client counterparts’ key drivers, is being able to glean the business drivers behind a project rather than just focusing on its technical aspects. Regardless of the field or the individual, the higher you go in an organization the more you will find a businessperson rather than a technical subject matter expert. And the views of a businessperson on the degree of project success can be influenced by many non-technical factors.

For example, the timing of an air carrier’s certification package submittal may have huge ramifications on an upcoming stock offering; or may be highly influenced by the delivery date, and ensuing monthly financial obligations, for newly acquired aircraft. JDA has experienced both of these scenarios, and was successful not just because it delivered a high quality manual system but because it did so within the timeframes mandated by these business drivers. Make sure you understand and meet your client’s major timeline events.

Third, resist the temptation to say ‘yes’ to ‘anything and everything’ to win business and [temporarily] please a client. Instead, be realistic and honest with a client when setting expectations. It is far better to jointly figure out how best to achieve a project’s goals via the combined resources and capabilities of the two companies than to set unrealistic expectations that cannot be met and ultimately result in dissatisfaction and consternation.

Fourth, communicate frequently with your client - providing too many updates is far better than too few. Make sure that client management has a clear view of project status at all times. Most importantly, if issues arise, address them with the client immediately. Don’t shy away from the ‘tough’ conversations when they become necessary. You need to give client management advance warning of problems so that they have sufficient opportunity to solve them or mitigate their effects. Few things are worse than belatedly telling a client about a problem (e.g., a potential schedule slippage because their personnel missed deliverable dates) when they no longer have a window of opportunity to correct things.

Following these guiding principles for taking care of our clients at JDA has yielded consistently successful project results, and most importantly, has led to many positive personal working relationships that to me constitute ultimate project success.

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It’s 2 a.m. and the phone rings…

by Dustin Wilcox on May 3, 2010

It seems like there have been a multitude of events in the news lately that would require a company to put its Emergency Response Plan (ERP) into action. Unfortunately, 2 a.m. with an event unfolding is no time to realize that your program is weak and out-of-date or, worse yet, non-existent.

Having an ERP is almost like admitting that you haven’t done everything you can to be accident free or that you can’t manage all your risks. Every business, no matter what risks they incur, should have an ERP. What would you do if you experienced a natural disaster at your work place and had to initiate a recovery plan? Without some kind of plan, you’ll be shooting in the dark on what to do. Whether it’s an airplane crash, toxic waste spill, tornado, or earthquake, an ERP serves the same purpose. If you don’t have one, get busy and start working on one!

For those that already have a plan, when was the last time you reviewed it? One of my roles with JDA is to serve as a tech writer on manual system revision projects. I have reviewed a variety of ERPs in which company contact personnel listed in the ERP were no longer with the company or that the telephone numbers had changed. If it hadn’t been for the manual revision project, the ERP would have been fairly useless and outdated documents that would have been of little value in the event of real disaster event.

A company should review its ERP at least once annually if not twice a year. Also, if conditions dictate a review or revision do it. Events such as headquarters office address change, personnel changes, new phone systems/numbers and new software programs, etc. warrant a review. Having a current ERP is a great first step but you also need to practice to make sure that your program functions according to the plan. A disaster is not the first time you want your response actually “testing” your ERP. At least once a year, perform an unannounced TEST emergency. Initiate the chain and observe. Afterwards, conduct a post ERP test debrief to discuss how things went and any positives or negatives discovered. Take this information into account and update your ERP procedures manual.

No one wants something to happen, but when it does wouldn’t you rather be prepared?

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Defining “Safe”

by Dustin Wilcox on April 27, 2010

"Safe" Aircraft Parked in the Desert

"Safe" Aircraft Parked in the Desert

The Iceland Eyjafjallajokull volcano has caused quite a ruckus within the aviation industry over the past 10 days, but it’s not the volcano or flight safety in ash clouds that I’m writing about. While reading about the grounded flights, I came across a quote from one of the union leaders and a 737 pilot for one of the European airlines. They basically said the only way you are truly safe in aviation is to ground all your aircraft and never fly again. That along with some discussions with co-workers brings me to this blog’s topic, what do we mean by “safe” in aviation?

Every airline and aviation organization will emphasize that safety is their number one priority, which I interpret as the operator will do everything in its power to be as safe as possible. Well I have to agree with the union leader that the best way to be accident free and truly safe is to sell your airplanes, but that business model doesn’t work in commercial aviation. Flying is inherently risky. You’re taking a machine composed of millions of parts, operating and maintaining it with people, and flying it thousands of feet in the air at hundreds of miles per hour through varying meteorological conditions. This sounds perfectly safe, doesn’t it? So how do we explain being safe?

We need to revamp our perception of aviation safety. There is no doubt that every operator strives for a goal of zero accidents. However, we recognize that we operate in an immensely complicated system and sometimes things happen - people make errors or components and systems fail. Aviation in itself is not inherently dangerous but it is terribly unforgiving of any carelessness, incapacity or neglect.

Instead of stating safety is our number one priority, we should clarify the safety objective and state that we always seek to operate in a manner that we deem as an acceptable risk. Flying will always be risky, but if airlines can proactively manage that risk and ensure it is at an acceptable level, we’ll be close to practicing what we preach and being honest with the traveling public. How do you operate with an acceptable risk -with an active and comprehensive Safety Management System (SMS).

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Expanding SMS Beyond Aviation

by Gene Bloch on April 27, 2010

The introduction of System Safety-based principles to air carrier operations and surveillance in the latter half of the 1990s has led to the safest decade in U.S. aviation history. Not resting on these laurels, aviation regulators and air carriers have now extended System Safety concepts even further via the promotion and implementation of comprehensive Safety Management Systems (SMS) that serve to proactively identify hazards, mitigate risks and promote a positive safety culture.

Part 121 air carriers were the first to embrace SMS in the U.S., but now Part 135 and even Part 91 international operators are getting on the SMS bandwagon. Not stopping there, the FAA has also introduced an Advisory Circular on SMS for Part 139 airports, and is providing funding for SMS pilot programs at several U.S. airports.

It is encouraging to see SMS expanding within aviation to beyond just Part 121 air carriers and into other types of air operators and airports, but these represent only the beginning of new applications for Safety Management Systems.

In particular, the concepts of SMS are hugely applicable to many other fields beyond just aviation, including other modes of transportation (e.g., Washington D.C.’s troubled Metrorail transit system), health care providers (with a staggering number of deaths caused by avoidable medical errors) and the food and mining industries, among others. Indeed, the recent mine tragedy in West Virginia provides a stark example of how the proactive introduction of an SMS could have potentially saved lives.

While JDA was founded and is staffed by aviation-centric safety leaders, we fully recognize how our work within the aviation safety community can benefit other industries as well, and we are actively working to extend the aviation successes of System Safety and Safety Management Systems into these other areas of need. If we are successful in getting others to listen, understand, and act upon the SMS message, the end result will be immensely satisfying - fewer patients dying from medical errors, fewer passengers and track workers dying from rail accidents, fewer miners dying, and fewer deaths from avoidable food borne pathogens. The stakes could not be higher.

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Safety “Aha” Moments

by Dustin Wilcox on February 12, 2010

CBS recently aired a new show, “Undercover Boss,” just after the Super Bowl. The first episode featured Waste Management President Larry O’Donnell. At the very beginning, Mr. O’Donnell shared a story about how his daughter was permanently injured from a medical error when she was an infant and that event drove home the importance of safety to him. “As a result of what happened to her, I never want to work at a company that I’m responsible for, where people don’t know how to follow the proper procedures.” Many people who have a true dedication to safety have had moments in their life that really hit the safety mark and opened their eyes to the importance of safety. Let’s call these “aha” moments.

My personal journey to safety has been long, bumpy, and slightly painful. I never intended to get into safety. From a young age I worked in industries that lent themselves to injury, and as you can see from my stories in the comment section below, I have had some very close calls. Each of these events resulted in an important safety lesson. People will argue that if we find ourselves in jobs that are unsafe, we should quit. However for one reason or another many of us may not have that option. Even when jobs were plentiful, finding a new job was not always easy. Most of us suck it up and do our job and hope and pray that everything will go well. Usually it does, and even for those of us in safety, we trip up from time to time.

I have experienced enough “aha” moments in my life that I want to do my best to make sure others don’t have to experience them. I hope you don’t wait for an “aha” moment at your company to get serious about safety because by then, it may be too late. The “aha” moment your employees experience may not be so gentle and could end with serious consequences. Let my experiences be lessons for all of us. Get focused and start mitigating all those situations that could result in providing the wrong lesson in your company.

Below are a few of my “aha” moments. Please share your “aha” moments as well. Perhaps we can all learn from each other.

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