ACSF March 2016 John Allen VP Safety

Transcription

1 New FAA Compliance Policy ACSF March 2016 John Allen VP Safety

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3 A New Day Dawns The New FAA Compliance Policy What It Means for the regulator and the Regulated 3

4 FAA Order (cont) 4

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6 Excerpt from the FAA Inspector s Handbook Order C. Most Deviations Can Be Effectively Corrected. Deviations by certificate holders often arise from factors such as flawed procedures, simple mistakes, lack of understanding, or diminished skills. The FAA believes that deviations of this nature can most effectively be corrected through Root Cause Analysis (RCA) and appropriate corrective actions by the airmen/entities involved, which are documented and verified by AFS to ensure effectiveness. Inspectors must contemplate all the tools available and apply the remedy most appropriate to the specific circumstances. Possible remedies to address deviations include, but are not limited to: open communication, training/education, on-the-spot corrections, counseling, and remedial training. Improvements to systems, procedures, or training programs for organizations may also be appropriate. The inspector documents corrective actions taken by the airman/organization and verifies the actions were effective through follow-up. 6

7 New Term In Compliance and Enforcement Guide Compliance Action is a new term to describe the FAA s collection of non-enforcement methods to correct unintentional deviations or noncompliance that arise from factors such as flawed systems and procedures, simple mistakes, lack of understanding, or diminished skills. It involves an open and transparent safety information sharing between the FAA and airmen/organizations. Its purpose is to restore compliance and to identify and correct any underlying cause(s) that led to the deviation 7

8 Speech "Another First in Our Safety Evolution" "Another First in Our Safety Evolution" Michael Huerta, Washington, D.C. October 6, 2015 Flight Safety Foundation Media Breakfast So what specifically are we doing on the FAA side? We have started training for all FAA employees on the new Compliance Philosophy, with detailed how-do-i-implement-it training for each Line of Business. We are using data, not calendar dates, to determine when and where to conduct surveillance and inspections. We are emphasizing that we expect our employees to use critical thinking, which is essential to successful implementation of the Compliance Philosophy. We want inspectors to use their judgment, experience, expertise and qualifications to identify risk, to work with the individual or operator, and to identify the most appropriate tools needed to permanently fix the problems. 8

9 Speech "Another First in Our Safety Evolution (Cont.) "Another First in Our Safety Evolution" Michael Huerta, Washington, D.C. October 6, 2015 Flight Safety Foundation Media Breakfast On the industry side, success requires understanding that compliance requires going above and beyond. The FAA expects certificate holders to develop and implement risk controls that are appropriate to their operational environment. That means thinking about outcomes and performance, identifying hazards, and mitigating associated risks, and implementing practices and procedures that encourage reporting. To get useful reporting, both regulators and operators have to understand the difference between accountability which accepts responsibility and looks forward and blame, which focuses on punishment for what s already happened. With accountability, the idea is to look at the operator s compliance attitude. 9

10 Safety Responsibilities and Organization Assume safety Philosophy want to not only be safe but also feel safe Public/Customers/Investors Assures safety of aviation industry Philosophy trust but verify (under SMS show me ) Tool: Safety Assurance System (SAS) Assures safety of airline Philosophy Assist company decision makers with: SMS management identification of hazards and appropriate risk controls Report safety issues, challenges and progress Tools: Evaluations of system designs Audits of Dept audit systems Investigate Incidents and accidents for root cause Collect data and analyze into actionable information Facilitate Risk Working Groups and SRB Ensures safety of airline Philosophy Take responsibility for:: hazard and risk controls management prioritization of risk-based controls manage effectiveness of controls Tools: Perform and comply IAW safe procedures Audit performance of processes Manage risk controls Promote safety situational awareness Facilitate frontline hazard reporting FAA Airline Safety Office Airline Operational Departments (Flt Ops, Sys Ops, Tech Ops, Inflight, Airports, Customer Serv) 10

11 Aviation Industry Safety Revolution Reactive and Forensic Reactive management vs. Risk-based and Predictive Risk management Crisis safety management Managed change Silos of knowledge Information sharing Data is used for reporting Data is used to report, forecast and manage 11

12 Aviation Industry Safety Revolution Reactive and Forensic Off with their heads vs. Risk-based and Predictive Just Culture and new FAA Compliance Policy Safety office responsible for safety Everyone responsible for safety especially frontline Regulator is dictatorial and despised Regulator is a collaborative and respected Safety expected by regulations Airlines expected to show how they manage their safety SMS 12

13 THANK YOU John Allen, VP Safety