SAFELY REGULATED?
Why the rules alone won’t keep you safe
As aviation safety professionals is not uncommon to hear the ‘money men’, the accountants who sagely guard the purse strings of every aircraft operator, say something like, ”Safety? Surely the regulator looks after that – if we stick to the rules we must be safe...”, and on the face of it that would seem a valid assumption. The relevant section of the UK CAA for example is called the ‘Safety Regulation Group’ and Europe’s regulator is the European Aviation Safety Agency, so you might reasonably assume - even expect - that their rules were written to keep you safe, and I would never suggest that it is not their aim to regulate aviation in such a way as to achieve the highest standards of safety.
However, take a step back and consider exactly what the regulations are; look at the UK Air Navigation Order for example, on avoiding aerial collisions. One rule says:
An aircraft shall not be flown in such proximity to other aircraft as to create a danger of collision.
Whilst this makes perfect sense, and the ANO elsewhere provides useful guidance upon how to comply with the rule (ACAS, ATM etc), on its own it will not make a flight safe. Rather like telling a child to “be careful!” on a climbing frame, the instruction alone may achieve nothing – in the case of the child he must previously know what it is he should be careful of, and precisely what care to take to avoid it.
This is because regulations must by their very nature dwell at the acceptable boundaries, which define what may or may not be done. They are quite simply the minimum acceptable standard; nothing more nor less. Any given act or action either complies or it doesn’t. Like the flight envelope of an aircraft we would not expect to operate at the very limits (although in theory we could) because experience has shown us that there needs to be an adequate margin to allow for unexpected variations in aircraft behaviour, the environment and the pilots’ competence. The magnitude of that margin is almost invariably dictated by historical knowledge of previous excursions or by informed assumption using extrapolation from what is known; but there always is a margin.
So whilst the regulator has kindly drawn the framework within which we must operate to remain safe (and of course compliant), it falls to the operator to design his system to function within it in such a way as to be sure that the chances of breaching a rule, of falling below the acceptable standard, have been examined, measured and minimised. As the organisation with the most intimate knowledge and experience of the specific activity, the operator is best equipped to define the margins to be allowed in each case and to write policy and procedure in such a way to ensure they are maintained. It is not a simple case of adding a bit for luck and it will require time and resources to ensure that it is done effectively but efficiently – in other words there will be a cost attached (sorry money men).
Funnily enough this concept is also required by the regulations; it’s called SMS...
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SAFELY REGULATED?
ReplyDeleteWhy the rules alone won’t keep you safe
As aviation safety professionals is not uncommon to hear the ‘money men’, the accountants who sagely guard the purse strings of every aircraft operator, say something like, ”Safety? Surely the regulator looks after that – if we stick to the rules we must be safe...”, and on the face of it that would seem a valid assumption. The relevant section of the UK CAA for example is called the ‘Safety Regulation Group’ and Europe’s regulator is the European Aviation Safety Agency, so you might reasonably assume - even expect - that their rules were written to keep you safe, and I would never suggest that it is not their aim to regulate aviation in such a way as to achieve the highest standards of safety.
However, take a step back and consider exactly what the regulations are; look at the UK Air Navigation Order for example, on avoiding aerial collisions. One rule says:
An aircraft shall not be flown in such proximity to other aircraft as to create a danger of collision.
Whilst this makes perfect sense, and the ANO elsewhere provides useful guidance upon how to comply with the rule (ACAS, ATM etc), on its own it will not make a flight safe. Rather like telling a child to “be careful!” on a climbing frame, the instruction alone may achieve nothing – in the case of the child he must previously know what it is he should be careful of, and precisely what care to take to avoid it.
This is because regulations must by their very nature dwell at the acceptable boundaries, which define what may or may not be done. They are quite simply the minimum acceptable standard; nothing more nor less. Any given act or action either complies or it doesn’t. Like the flight envelope of an aircraft we would not expect to operate at the very limits (although in theory we could) because experience has shown us that there needs to be an adequate margin to allow for unexpected variations in aircraft behaviour, the environment and the pilots’ competence. The magnitude of that margin is almost invariably dictated by historical knowledge of previous excursions or by informed assumption using extrapolation from what is known; but there always is a margin.
So whilst the regulator has kindly drawn the framework within which we must operate to remain safe (and of course compliant), it falls to the operator to design his system to function within it in such a way as to be sure that the chances of breaching a rule, of falling below the acceptable standard, have been examined, measured and minimised. As the organisation with the most intimate knowledge and experience of the specific activity, the operator is best equipped to define the margins to be allowed in each case and to write policy and procedure in such a way to ensure they are maintained. It is not a simple case of adding a bit for luck and it will require time and resources to ensure that it is done effectively but efficiently – in other words there will be a cost attached (sorry money men).
Funnily enough this concept is also required by the regulations; it’s called SMS...