Building A Bridge With The "New" FAA- Strategies and Updates for Working Together

Transcription

1 Building A Bridge With The "New" FAA- Strategies and Updates for Working Together MARPA 2016

2 Who We Are Team of Experts Diverse Industry Experience Key Regulatory Oversight Background Solutions to complex aviation issues. 2

3 Good Safety = Good Business Air Carriers CAAs Business and General Aviation Who We Serve Manufacturer s Suppliers, Distributors Commercial Operators MROs 3

4 Our Capabilities Assessments and Audits Certification Safety Management Systems Training 4

5 Relationship Temp Check Are they your best golfing buddy? Do you treat them like the enemy and respond defensively? 5

6 Favorite FAA Horror Story You can t believe what they made me do He told me he would shut us down unless 6

7 Why have a good relationship with the FAA?

8 Mutual Goals A good relationship with the FAA can help both sides focus on the mutual goal of safety and compliance Safety Compliance Business Are these mutually exclusive?

9 Relationship Ingredients ITS NOT ROCKET SCIENCE

10 Trust Foundation Effective Communication Open Honest Mutual Respect Value input and ideas Promotes collaboration Solutions Accountability Responsible for words and actions Limits negative energy

11 Positive Relationships with the FAA FAA Input Collaboration Part of the Process Early and Often Communication No Surprises Understand Differences Conflict Resolution Remove Emotional Energy

12 Strategies to Make Life Easier MARPA

13 Know Your Stuff Submit documents in final form, Meet regulations and guidance material the first time Organized for easy to acceptance or approval Mitigate the Ping Pong game during the review 13

14 Get Involved with Industry Groups Stay Informed Number one thing you can do to see it coming Take the opportunity to help write the guidance/rules 14

15 Do Most of the Work First Send copies of the material with your submission Saves Inspector search time Be prepared know more about your business than anyone Be willing to explain the intricacies of your business in a non-confrontational manner 15

16 Golden Rule R-E-S-P-E-C-T Might keep your document on top of the pile Don t be afraid Difference in interpretation Don t get excited - ask for a meeting Benefit of knowing the management Know other avenues available-appeal, CSI 16

17 Section 1 Compliance Philosophy

18 FAA NEW Compliance Philosophy Intentional or Reckless Deviation Deviations from Regulatory Standards Voluntary compliance with regulatory standards Source: FAA Order , dated 06/26/2015 & AFS Notice N dated 2/2/

19 FAA NEW Compliance Philosophy FAA Order Based largely on, and dependent upon, voluntary compliance with regulatory standards - Statutory obligation to comply with regulations Includes duty to develop and use processes to prevent deviation FAA is implementing SMS based on comprehensive safety data sharing between the FAA and the aviation community Foster an open and transparent exchange of data, Supported by an established safety culture, Ensuring both compliance with regulations and the identification of hazards and management of risk 19

20 Deviations From Regulations When Deviations Occur FAA s goal use the most effective means to return an individual or entity to full compliance and to prevent recurrence Some deviations arise from flawed procedures, simple mistakes lack of understanding, or diminished skills These deviations most effectively corrected through root cause analysis training, education other appropriate improvements documented and verified to ensure effectiveness. 20

21 AFS Compliance Philosophy Solutionoriented Outcomebased Identify safety issues Correct noncompliance Resolve issue through compliance tools, techniques, concepts, and programs 21

22 Interdependence Professional difference of opinion, First understand the other perspective A clear reasoned concern about risk, Inspectors must work interdependently with colleagues ensure certificate holder sufficiently mitigates risk and meet compliance obligations If a proposed means of compliance appears to be safe and within the scope of regulations but outside AFS policy, inspectors should work through their management chain to obtain short-term policy relief (deviation to ) and seek appropriate long-term policy revisions CAVOK Oliver Wyman 22

23 Critical Thinking Fair Reasonable Just Good-faith effort understand position Communicate FAA position in a timely manner AFS leadership committed to improve efficiency, effectiveness, and organizational health

24 Consistency Does not mean that each entity gets identical results Tailored specific solutions Anchored in statutes, regulation, policy, and legal interpretation Means evaluating each set of facts

25 Achieving Consistency Inter dependence Critical Thinking Evaluate the facts of each issue against objective standards (regulations, legal and policy interpretations etc.) Explain differing responses to any stakeholder Based on the facts and standards used to make the determinations 25

26 Intentional or Reckless Deviation Intentional Or Reckless Unacceptable risk to safety - posing the highest risk to safe operation Require strong enforcement Regulatory violations involving law enforcement-related activities may be addressed with enforcement 26

27 Section 2 Compliance and Safety Information Sharing

28 NEWS FROM THE FAA The New Compliance Philosophy VS Aviation Safety Action Program (ASAP) Voluntary Disclosure Reporting Program (VDRP)

29 Notice Supplementary information Addresses change in Compliance Philosophy Eliminates the Administrative Action and the Enforcement Decision Process (EDP) tool 29

30 Section 3 What is SAS?

31 Safety Assurance System (SAS) What is SAS? Next Evolution of FAA Oversight Replaces existing oversight systems Initial certificate issuance Ongoing surveillance Changes to initial certificate SAS Concepts and Philosophies System Safety Safety Attributes Safety Management Systems Four Pillars or Components Risk Based Data Supported Source: FAA Order and FAA website AFS-900 Deployed in Two Phases Phase 1 - May 2014 thru December 2015 All part 121, 135 and 145 Phase 2 - FY 2018 All remaining certificates

32 Safety Assurance System (SAS) What is SAS? Standardized protocols to evaluate certificate holder programs required by regulations to be approved or accepted. Used in Certification and Oversight Verify safe operations and before issuing a certificate and approving or accepting programs. Periodic reviews verification compliance Validate performance of a approved/accepted programs for the purpose of Continued Operational Safety (COS)

33 Safety Assurance System (SAS) What is SAS? Goal to optimize safety by the identifying hazards and eliminate or control their associated risk. Perform Design Assessments (DA) and Performance Assessments (PA) Use of Data Collection Tools (DCTs) Element Design Assessments (EDs) Performance Assessments (PAs)

34 Safety Assurance System (SAS) What is SAS?

35 To Contact Us: Horde Street Silver Spring, MD USA (fax) gilesgroup.com

36 QUESTIONS? 36

37 THANK YOU! 37