Does this sound remotely familiar to you? Is this not what all the safety programs we already have in place are supposed to do? Do we need more?
Sure, Continuous Analysis and Surveillance (CAS) FAR 121.343 applies only to air carriers. Other organizations also have their own safety and quality control programs that do the same thing. Ensuring safety and quality in product or process is standard procedure in our industry. The whole CAS concept and system can easily be adapted directly to other activities and or processes. Why start a whole new system?
If Bill O’Brien were still alive I am certain he would agree with most of my thoughts above. He believed in smaller is better and the fewer regulatory mandates the better. Let private enterprise do the job of supervising their safety culture. There are enough mandates out there to supply and structure such systems without adding more. And yes, who is going to organize and manage this huge effort? It is interesting that ICAO simply passes the job on to the member states, European authorities, and our own FAA. Just like ICAO’s Stage 3 noise standards which were passed on to the UK and other EU states to create and supervise.
Safety data management and collection programs
FAA already has numerous safety management programs in effect that it cannot effectively manage now. How can it add another system and expect to manage it? Will it turn out to be another pile of data collected to simply collect with the rest?
Only one of these safety programs is required by regulation … that is the Continuous Analysis and Surveillance (CAS) program under FAR 121.373 and its Part 135 companion FAR 135.431. As I have stated in the past on numerous occasions, one can only wonder what happens to all the data and required reports collected under this program and whether or not anybody at the FAA or the air carrier even looks at it and analyses it?
Questions have even been raised about whether or not the program is even effective. The Valujet, Alaska Airlines, and Chalks accident cases come to mind. Add the recent problems at Southwest and American and you see the trend.
Air Transportation Oversight System (ATOS) is designed to be sort of like a CAS system in that it is a continuous but broader program designed to detect weakness and predict an accident before it happens. This is also what CAS is supposed to do but has failed in too many cases. ATOS uses a systemic approach by attempting to evaluate all the elements of an air carriers operating environment and it is supposed to ensure that all the elements have safety built into their operating systems. (Sound familiar?)
Flight Operational Quality Assurance (FOQA) is a far-reaching attempt by the FAA to capture flight data and other operational information. Although there are many concerns raised over the collection and use of such data by flight crew personnel. This is a voluntary participation at this time.
Aviation Safety Action Parnership (ASAP) is another voluntary safety data sharing program that has been around for some time also. It shares the same concerns about the use of raw data without adequate protections from disclosure.
In order to be effective CAS FAR 121.343 needs to be expanded and SMS may be an alternative method to do the job. The NTSB, reviewing noteworthy accidents, has so stated and added that CAS is a one size fits all rule that needs to be changed. The Board said that the FAA should move away from the one size language and focus on a program that will aggressively uncover and address any structural and or other continuing airworthiness issues. (New SMS?)
A vigorous maintenance tracking process must be included in any overall quality control system. The Board cited insufficient FAA oversight. It suggested that principal maintenance inspectors should be more involved in the process and join in the overall analysis of discrepancies, maintenance, and inspection functions. The Board has clearly argued for more oversight. Just where are the inspectors going to come from when and if a completely new safety management system comes on line?
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