Historic and comparative trends, assessed through 25 years of global auditing, has identified an insidious trend of declining ethical standards applied by some Corporate Executive Management personnel involved in aviation operations. It has been determined that this trend is increasing, in part due to cost cutting initiatives, without due regard to the aviation safety implications.
The question has to be asked - “Why have Corporate Safety Departments been decimated when historically the aviation industry deemed it appropriate to have a larger contingent of highly experienced safety personnel?”.
The answer is simple – safety is not the priority, cost in some instances has now become the priority. This practice has led to serious incidents and fatal accidents. The Flight Safety group of Companies has been, and currently is, directly involved in assisting with some of these investigations.
After a disaster occurs, as Aviation Safety consultants, we review and question what more could be done to increase aviation safety awareness and to prevent these accidents. However, when critical aviation safety advice is overridden in order to save money, for example changing Safety Standards in order to effect cost cutting strategies, this inevitably leads to compromised safety initiatives and processes. In these instances, the initial binding Non-Disclosure Agreements and Confidentiality Contracts between Consultants and AOC’s become null and void as Duty of Care reporting takes priority.
The CEO is the accountable manager in every AOC. Audit processes have identified that, in some cases, insight into the required roles & responsibilities applicable to the CEO position is lacking or misconstrued. The CEO may deem it acceptable to delegate the aviation safety responsibilities of the organisation to a Safety Manager, or some other member of the management team, without understanding the implications of this decision and their responsibilities as CEO.
The following guidelines will assist in establishing a small but effective Safety Department:
Corporate Management can have a positive or negative impact on establishing effective Aviation Safety Management oversight. Degrading or manipulating standards, put in place to protect organisations and their personnel, can contribute to accidents.
Accountable executives that are proactively invested in maintaining safe work standards, are the foundation of a strong aviation safety management system that will protect both the organisations personnel from harm and also the organisation from the legal ramifications following accidents and incidents.
Excerpt from ICAO, Safety Management Manual (Doc 9859) , 4th Edition, 2018
22.214.171.124 The accountable executive, typically the chief executive officer, is the person who has ultimate authority over the safe operation of the organization. The accountable executive establishes and promotes the safety policy and safety objectives that instil safety as a core organizational value. They should: have the authority to make decisions on behalf of the organization, have control of resources, both financial and human, be responsible for ensuring appropriate actions are taken to address safety issues and safety risks, and they should be responsible for responding to accidents and incidents.
126.96.36.199 The accountable executive is not usually involved in the day-to-day activities of the organization or the problems faced in the workplace and should ensure there is an appropriate organizational structure to manage and operate the SMS. Safety management responsibility is often delegated to the senior management team and other key safety personnel. Although responsibility for the day-to-day operation of the SMS can be delegated, the accountable executive cannot delegate accountability for the system nor can decisions regarding safety risks be delegated. For example, the following safety accountabilities cannot be delegated:
a) ensuring safety policies are appropriate and communicated;
b) ensuring necessary allocation of resources (financing, personnel, training, acquisition); and
c) setting of the acceptable safety risk limits and resourcing of necessary controls.
Economic pressure coupled with the inevitable retrenchment of skilled personnel often impacts corporate Safety Departments. This creates challenges for reputable aviation Auditors and Consultants and extends into the offshore Helideck Inspection area of operations.
With organisations focussed on tightening budgets, implementing and maintaining a Quality Management System (QMS) to industry standards, including using third party external ISO Certified organisations to conduct safety audits and inspections, is often the first area to be affected through extended conventional audit timelines and the utilisation of unskilled and uncertified labour to conduct safety audits.
This undermines the minimum acceptable industry safety standards and can place an organisation at real risk of serious litigation should an accident/incident occur.
An industry standard audit process will always include an unbiased third-party analysis by a certified organisation with qualified personnel that have years of experience in the aviation industry. This ensures the external audit result is not at risk of being tampered with or diluted in order to comply with budgetary or internal company influences.
Shortcutting the quality process of monitoring, reporting and responding actively to implement system improvements has been directly responsible for fatal accidents. The resulting outcome can end up costing a company more than the value of the company.
It is therefore imperative that the following guidelines are observed:
The audit protocol analysis provided, indicates that there is increasing evidence that these insidious system failures developing, are associated with inexperience and cost cutting practices.
Our previous newsletter (November 2018) provided an initial overview of differences between the latest versions of CAP 437. The practical application of the requirements has now been tried and tested and the following analysis identifies some of the in-field issues, both positive and negative.
It is apparent that industry pressure continues to play a part in the development of offshore standards and procedures in both a positive and negative way.
The almost indistinguishable balance between cost and safety, from a safety management perspective, is often misidentified and is influenced by industry pressure particularly when there is a decline in the economy.
Testing Regime for Profiled Helidecks
The following extracts from CAP 437 describe an illogical testing process that has created confusion and resistance amongst the industry. The general interpretation is that samples have to be taken from the helideck surface and sent away for testing. This is clearly impractical and counter-productive from both a cost and logistical perspective.
Also, friction testing, in only a parallel alignment with the ribs on profiled helidecks, is impractical due to common knowledge that the helideck is used for loading and offloading of heavy equipment and containers. This process damages the friction surface and therefore it follows that periodic testing is essential.
Legacy approvals or ‘Grandfather Rights’ are often the result of industry pressure and are usually justifiable if the associated risk is correctly managed and not simply ignored. Examples below:
Perimeter Safety Net
In previous versions of CAP 437, the perimeter safety net height was mandated at 250mm above the helideck height. Further analysis confirmed that this still held an unmanageable level of risk due to potential tail rotor strike, or in extreme circumstances dynamic rollover. The height was then reduced to the helideck height.
The latest version of CAP 437 has now reversed that decision and the 250mm height above helideck height has now been re-approved as a legacy consideration, but only for installations that precede an original manufacture date of the 1st January 2012. The following two extracted and highlighted excerpts identify the issue.
It is difficult to reconcile legacy thinking in this instance as we have two current, conflicting concepts that might not withstand the rigors of a Coroner’s Court.
In general terms there is no doubt that UKCAA CAP 437 is a very valuable document but there is still room for improvement with some of the practical applications identified.
The Flight Safety Group of companies is continuing to expand throughout Africa and into Europe with operations in Spain and the UAE, and contracts confirmed and pending in Libya and OMAN.
The acquisition of a third Findlay Irvine MicroGrip friction tester - adopted as the industry standard across the world and fully compliant with UK CAA CAP 437 - has positioned the Flight Safety Group as a global leader in delivering friction test services. This is the only CAP 437 approved friction testing machine (Reference Chapter 3, Paragraph 3.40, Page 58).
Findlay Irvine MicroGrip Friction Tester
The two South African companies – Flight Safety Africa and Helideck Certification – Africa, conduct the majority of helideck related training on the African continent, with national training carried out in Cape Town and Pretoria, and international training conducted in many other countries including Ghana, Mozambique, Namibia etc.
A new electronic database management system has been developed - this system is web-based and will ensure that all helideck inspections, friction tests, audits and helipad design operations are effectively managed in accordance with the Flight Safety Group’s ISO 9001:2015 Quality Management System.
There are significant changes with the latest version of CAP 437. We provide a detailed Gap Analysis with our Helideck Inspector Awareness Training courses, but the following identifies some of the more significant issues that need to be considered.
Flight Safety CEO, Colin Weir, recently presented at ROTORTECH 2018 on the Sunshine Coast, Queensland, on the subject of Safety Managment System (SMS) failings.
A significant discovery has been made, following multiple audits and accident investigations carried out globally. Traditional Safety Management Systems structured in classic format, although compliant with regulations, often have serious, insidious failure areas relating to the Human Factor interface, where the autonomy of the system is compromised by individuals (executive management/management) and oscillating economic changes, usually involving a CEO and/or Safety Manager who are untrained or weak, a Board that dictates aviation policy, or a client that influences the integrity of cost management processes.
Either one, or all, of these factors could be in play at any one time - this latent failure potential has been identified in multiple serious incident, accident investigations and is not usually fully recognised and documented.
Safety Management Systems should be investigated for potential failure in these areas using Human Factors Analysis and Classification System (HFACS) & Human Factors Intervention Matrix (HFIX) investigative techniques.
The Flight Safety Group of companies is consolidating and expanding, a reassuring development after the extended downturn in the economy over the last few years. As often happens there is sometimes a positive side to these downturn events as it introduces a natural selection process, in keeping with nature and the ‘survival of the fittest’ concept.
Flight Safety is expanding its presence in New Zealand with the registration of Flight Safety New Zealand Pty Ltd and the award of a second-long term contract in the New Zealand Oil & Gas industry.
The appointment of an experienced helideck inspector/auditor permanently based in Perth has allowed us to start regaining lost ground that has affected us due to the downturn in the economy and the complication of additional costs in flying personnel across from the East Coast.
Flight Safety has also become increasingly involved in specialist – ‘Expert Witness’ and legal consultative work with the legal fraternity throughout the country, with positive results.
The two South African companies – Flight Safety Africa and Helideck Certification – Africa, are an astounding success story, through multi-faceted training, helideck inspections and friction testing, the companies are experiencing exponential growth, and this trend is expected to increase as the previous more localised area has now expanded into the whole of Africa and the Arab States.
The South African companies are currently in the final process of Lloyds Register ISO 9001:2015 Certification, in keeping with the Australian companies.
The Flight Safety Group has a new addition. We are proud to welcome Flight Safety Africa to our excellence in aviation safety fold.
Our sister company, Helideck Certification-Africa (HC-A) was set up in order to fulfil an overwhelming need to assist in risk assessment and risk management of the aviation industry within the African continent and, in particular the offshore oil and gas industry, to ensure compliance to national and international operational safety standards.
Helideck Certification-Africa, is positioned to offer advice and certification to both International and UK CAP 437 standards for helideck and land based facilities on the African continent. As a member of the Flight Safety Group HC-A are able to provide every aspect of advice and information required for helideck compliance and certification and to carry out full audit services for the aviation industry, including friction tests with the only authorised friction tester – the Findlay Irvine Micro GT Friction Tester.
However, the Flight Safety Group still felt that there was a gap in the aviation safety auditing of fixed wing aircraft. Flight Safety Africa will fill that gap with ISO 9001:2015 qualified Auditors that will bring a new era of safety to the African continents aviation sector.
Flight Safety Africa will have the full support and access to the Flight Safety Group of companies’ knowledge and skills base which includes Flight Safety Pty Ltd, Flight Safety Helideck Certification Pty Ltd, and Helideck Certification-Africa.
Combined the Flight Safety Group has over 20 year’s global experience providing:
Between the Flight Safety Group members, over 2000 global audits, inspections and Friction Tests have been completed on rotary and fixed wing operations for charter/regional airlines, offshore Helidecks, Helideck Landing Sites and onshore Heliports. Flight Safety has extensive experience in military and police aviation safety oversight operations.
Current operational bases now include bases on the Sunshine Coast Queensland, Melbourne Victoria, Perth Western Australia. Flight Safety global bases include Christchurch in New Zealand, Pretoria and Cape Town in South Africa and Abu Dhabi in the United Arab Emirates.
All members of the Flight Safety Group are positioned to offer advice and certification to both International and UK CAP 437 standards for helideck and land based facilities and we are Lloyd’s Register ISO 9001:2015 Certified.
Utilising years of experience and qualified auditor’s and inspectors from within the Flight Safety Group, our newest addition, Flight Safety Africa can deliver a professional and competent aviation safety auditing service to the continent of Africa and surrounding countries.
8 Dec 2016
With the growing number of helideck-equipped rigs worldwide, now in excess of 4000, Investment bank Barclays expects a 6-percent increase in spending this year. Barclays forecasts that there will be 25 percent more "deepwater" rigs (operating at ocean depths of more than 1,500 meters) by 2016.
Decentralising certification is a practical means of opening up opportunity for knowledge and skill sharing at a competitive rate. It also will increase the opportunity for isolated areas to engage quality services which will have a positive outcome on safety overall and specifically encourage the global application of internationally recognised certificates.
The success of above-mentioned decentralisation is subject to a number of critical prerequisites, namely:
Flight Safety Pty Ltd and Flight Safety Helideck Certification Pty Ltd are Lloyd’s Registered - ISO 9001:2015 Certified.
Flight Safety refers to the Flight Safety group of Companies that include; Flight Safety Pty Ltd (ACN 108 080 208), Aeronautical Enterprises Pty Ltd (ACN 116 737 878) and Flight Safety Helideck Certification Pty Ltd (ACN 134 088 878), Flight Safety Africa, Helideck Certification - Africa, Flight Safety New Zealand Pty Ltd.
Flight Safety Pty Ltd, or any of its companies, are not affiliated with FlightSafety International.
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