The Flight Safety Foundation is, as noted in its logo, independent, impartial and international. For example, its Board of Governors draws members from 13 countries. Its recognition of the FAA’s and CASA’s new Safety Compliance programs should be noted by all aviation safety professionals.
Here’s the Foundation’s statement on these accomplishments:
“These leading national civil aviation authorities are embarking on enlightened best practices to compliance and enforcement by emphasizing the importance of proportionality, discretion, and remedial action to address safety issues. The vast majority of deviation from the rules are due to human factors, honest mistakes, or diminished skills, where training and education are appropriate corrective measures, not punishment or enforcement…All countries should closely examine CASA’s and FAA’s new, forward-thinking compliance and enforcement philosophies and get away from outdated ‘cop-on-the-beat’ mentality, where inspectors are looking to write up violations, instead of helping organizations and individuals become compliant and enhance safety.” [emphasis added]
FSF cited the FAA’s Compliance Philosophy Order, issued on September 3, 2015, Order 2150.3B, Change 9 as well as FAA Order 8300, on June 26, 2015, as reflecting a better approach stressing improving safety over sanctions to deter violations. Equally praised was CASA’s new “Regulatory Philosophy” issued on September 15, 2015.
As with any such major transition— from a seventy year approach of inspect-and-enforce to the new a cooperative, risk-based philosophy— will require attitude adjustments within these two agencies. Major training curricula and support for the line personnel will have to be designed and implemented. For all of the investigators’ careers, their pay raise and promotions have reflected whether they were aggressive “traffic cops.” Now, under the new policy, those reviews will look for cooperation, collaboration and consultation; even more difficult for these veterans will be that they must heavily rely upon and COMPREHEND the significance of the SMS/SASO data analyses and predictors.
As to the FAA, a much underappreciated organizational change by the Chief Counsel may facilitate the transition. Having a single source of review of the next proposed enforcement cases will establish consistency in actions nationally.
The FAA’s efforts continue. Recently, it revised its VDRP (8900.331 – Aviation Safety Action Program (ASAP), Voluntary Disclosure Reporting Program (VDRP) and the New Compliance Philosophy). Specifically this change addresses the new Compliance Philosophy by removing Administrative Action under the VDRP. That’s a technical amendment which reflects the extent to which the management is insuring that all of the documents reflect the new regulatory regime.
The task which needs prioritization is the alteration of the field inspectors’ attitude. The FSF recognition might be cited as outside, independent and major aviation authority’s confirmation of the decision to take a different recognition. Hopefully, the FAA field staff will find that as validation for changing their historical attitudes.