Safety Recommendation
The Australian Transport Safety Bureau recommends that the Civil
Aviation Safety Authority review their Safety Trend Indicator
process, including with a view to developing a methodology to
assist in objectively assessing potential at-risk organisations.
That should include formal 'triggers' that enable the consistent
prediction of the requirement for additional surveillance until
CASR Part 119 takes full effect.
CASA response
As noted in the Authority's response of 6 February 2004, the STI is
used in conjunction with industry intelligence and other resources,
as a management tool to assist Aviation Safety Compliance staff
determine the planning and scope of surveillance activities.
However, the Bureau's report appears to inappropriately assume that
the STI is a direct measure of a company's safety, rather than a
means of prioritising resources to gain information by means of an
on-site audit.
The STI does not record the presence of regulatory breaches or
other hazards that must be corrected. Rather, it collects
information on factors that suggest the greater likelihood of such
hazards being present. For example, the fact that a company has
recently made changes to its organisational structure does not in
itself imply a decrease in safety. In fact some changes may have
been implemented to correct previously identified
deficiencies.
Nevertheless, the introduction of a new organisational structure
does increase the likelihood that there could be disruptions to
existing safety systems or see new, untested, systems introduced.
For this reason, the STI is used not to identify specific problems
but rather to prioritise companies for audits. In other words,
companies that have relatively high STI scores should receive more
frequent audits than other companies.
CASA is currently progressing with the implementation of Mark 2 of
the STI. However, this remains but one tool within a suite of
safety management strategies used by CASA.
In order to reduce the safety risks associated with flight
operations and related ground operations, CASA is currently
introducing a Safety Management Systems (SMS) approach for
passenger carrying operations. The new regulations will mandate the
implementation of a SMS and AOC holders will be transitioned to the
new regulatory requirements through a case management process.
Training sessions on SMS have already commenced and are attended by
CASA officers and industry personnel.
In addition, CASA's new surveillance procedures direct inspectors
to conduct safety auditing using the systems approach. The main
areas of significant change initiated recently include:
thorough pre-audit preparation and consideration given to safety
intelligence, audit objectives and targeted scooping;
recording and reporting of findings; and
follow-up and planning of subsequent action.
The Authority's systems approach and application of risk management
methods places greater emphasis on the notion of 'shared
responsibility' between the regulator and operator for safe
operations.
