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

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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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