“Turning the Corner”
Ali Bahrami’s First Speech as AVS-1
Ali Bahrami’s 1st Speech as AVS-1—“Turning the Corner”
Following in the footsteps of Peggy Gilligan is no small feat; she established some strategic directions, which are critical to the FAA’s fulfillment of its safety mission and which demand excellent leadership to implement. Ali Bahrami is Administrator Huerta’s selection to try to fill those shoes. He is well qualified in terms of experience, but his ability to influence his widely dispersed, somewhat intransigent organization will be demonstrated by his future actions and words.
His first speech, as measured by the FAA.gov/news/speeches inclusion, was a speech to the Air Cargo Safety Forum on August 17, 2017 in Herndon, VA. [A Google search did not find any mention of the forum or the speech.] The subject of his remarks is air cargo safety, in general, and the National Airlines B-747 cargo freighter crash at Bagram, Afghanistan, specifically. [In that the new AVS-1’s primary message is the benefits of the new compliance program, the FAA fined National Airline $77,000 for improper loading of the cargo.]
While the physical audience may have been the attendees of the Forum, the message may have also been his first statement of:
- his endorsement of all of the initiatives set by Peggy Gilligan, as an announcement to industry,
- his message to his about 15,000 staff that compliance, collaboration, proactive use of data, SMS, SAIS, FOQA and a number of other new ways of doing business will be their foundations of their daily aviation safety work.
Here are some of the key quotes:
- There is no question that working together, we have a greater impact on promoting and advancing safety. Industry and regulators have been very active to improve safety through proactive means … using data and identification of precursors. And developing mitigation to address them. We’ve made significant progress over the past two decades. Each one of us should take pride in having a role in achieving our collective successes. In this partnership, our respective roles and responsibilities can’t be overemphasized. Today’s safety record is a testimony to what can happen when we work together, share information and take our role and responsibility seriously.
- The target for the Commercial Air Carrier passenger fatality rate this year was no more than 6.4 fatalities per 100 million persons on board. As of July 31, the actual number is zero point three.
- The numbers for GA are headed in the right direction as well. In FY 2017, our target for GA was not to exceed 1.01 fatal accidents per 100,000 flight hours. As of July 31, the rate stands at 0.81 fatal accidents per 100,000 flight hours. That’s remarkable.
- In safety, communication matters. In cargo safety, consistency matters. If you don’t have both of those, we’ll never get to the place where collaboration can make a difference.
- I want you to know we’re cognizant of your challenges. A very diverse fleet and very diverse operations. Lack of OEM support for legacy aircraft, which also happens to be a problem for us. Attracting pilots. Retaining pilots. There’s a difference between supplemental and scheduled, just the way there’s a difference between cargo and passenger operations.
- The Cargo Focus Team … issued two SAFOs on non-compliance with the weight and balance manual, and another on pallet straps. Separately, I should note that there is a rulemaking committee tasking on loadmaster certification.
- Our collaboration doesn’t end there. I think the Commercial Aviation Safety Team seals the deal. It shows all of us what happens when the regulator, industry and labor are all sitting down at the same table.
- CAST is what’s going to help us build on those. It’s a multi-step process, and everyone in the room is leaning in every step of the way. At InfoShare, ASAP and FOQA. With the Aviation Safety Information Analysis and Sharing system that helps us scrub data from across the industry. And from CAST—which develops effective mitigation strategies that all of us voluntarily adopt. Collaboration works. And we see it in the cargo industry, where you and your labor partners are the cornerstone to ensuring the highest standards in safety.
- Speaking of CAST, some of its mitigation strategies might not be compatible with some of your operational requirements. That’s OK. You may have other mitigation strategies that are equally effective. From our perspective, under a safety management system, carriers are expected to conduct a risk assessment of systemic risk identified by CAST … and then take appropriate action as the operator considers to be adequate.
- That’s the compliance philosophy, which by any measure is an overwhelming success. The Compliance Philosophy is founded on the assumption that everybody in the aviation community wants aviation to be as safe as possible. And so far, the results are positive.
- We’re finding that the time spent to correct problems through Compliance Actions is much less when compared with the time spent on enforcement. Since the program began two years ago, we have cut the number of enforcement actions by 70 percent. During the same time, we have corrected over 8,000 safety issues using non-enforcement Compliance Actions. These actions represent issues that were identified, documented, and addressed with a corrective measure. These are risks that were mitigated, problems eliminated, safety of the NAS improved.
- My point here is that when we, or the carrier discover noncompliance or potential noncompliance, if the carrier is willing and able to make correction and become compliant, we will use compliance actions rather than enforcement.
- We want to work with industry to determine the root cause of the noncompliance. We want to establish mitigations that will prevent these types of issues from happening again.
- We’re about education. We’re about making sure that issues come to the fore, that they’re analyzed, and that inappropriate behavior, techniques and situations are identified, mitigated and eliminated. The feedback we’re getting is helping to drive the change. The compliance philosophy is dynamic: the better the feedback, the stronger it becomes.
Those are powerful words. It is, perhaps, the first time that a senior FAA executive has bragged that the number of enforcement cases was reduced by 70% and that 8,000 problems were resolved with compliance action. The days of the FAA ticket writers are over is the message from Mr. Bahrami. Now it will be interesting to see him become the Apostle of Compliance.
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