SSB - Simple Stupid Behaviour

[LeadSled]

If the improvement trend is to resume,
industry consensus that it can happen only
when all nations, particularly those with
immature or developing economies, embrace
modern safety management methods rather
than hoping that regulation will enforce
standards. Presenting on pilot standards at the
Flight Safety Foundation [FSF) International
Aviation Safety Seminar in October 2010,
the Air Line Pilots Association International's
chief human factors spokesman Capt Charles
Hogeman summed up the limitations of
regulation to enforce safety thus: "Simple,
clear purpose and principles give rise to
complex, intelligent behaviour. Complex
rules and regulations give rise to simple,
stupid behaviour."Folks,

The above quote is from Flight International, 18-24 January 2011, p 23.

As to the safety benefits of performance (outcome) based regulation, as opposed to prescriptive regulation, I couldn't have put it better myself..

For those of you who denigrate performance based regulation ( as recommended by the ALRC, and more Commonwealth and State Governments than I can poke a stick at) I am afraid I can't help those who are determined to not understand.

Indeed, on another thread, one of you talks about more regulation to solve a problem of a LAME kinking a fuel injector line, if you actually gave it a bit of thought, and had a basic understanding of what "outcome" means, an "outcome" based regulation is actually easier to write and enforce.

Even the "Australian" approach to Safety Management Systems is "unique", bears little relation to ICAO recommendations, and with the "enforcement" mentality on view, is never going to be very effective outside major airlines --- where unions and the company legal department can keep CASA at bay.

As we see time and again (look at the top aviation problems listed in the last ATSB Annual Report) our complex, convoluted, contradictory and often indecipherable regulations continually lead to: simple stupid behavior.

The accident statistics are all public information !!!

Tootle pip!!

[Jabawocky]

And why do the yanks have a simple recipe book for rules and we have a whole library that only a lawyer can follow :rolleyes:

[osmosis]

There is more than one industry here in oz that has to have a book of interpretation for the masses cannot operationally follow the legal jargon. Such a silly people we are.

[Rose_Thorns]

There is a corporate and industrial will to affect change.

The bloody dinasours running the assylum could not care a frogs fart about Robin Speed or the FSF. Proven fact, not my dellirium.

On the positive side, they will, one day (Inshalla) have extracted enough public money to retire and live happily ever after.

Tell me why, in all the hells should they give a French flying (agrictural) about the flamming mess, left behind.

[Jack Ranga]

Indeed, on another thread, one of you talks about more regulation to solve a problem of a LAME kinking a fuel injector line


I actually agree with you Leadsled.

My comments were more along the line of playing devil's advocate.

I'm saying it's not much wonder CASA are going down this track when a handfull of monkeys ruin it for everyone. Law for the lowest common denominator.

Government has ruined initiative in this country by telling all our poor young dears that nothing's their fault. Now we are paying the penalty, no-one will take responsibility for their actions so organisations like CASA are going to make them.

[Andy_RR]

Well, you can never have enough laws to keep the stupid from killing themselves...

NEW YORK – After targeting distracted drivers, some New York lawmakers want to go after distracted walkers. They are looking to ban them from using iPods, music players and cell phones while walking and crossing the street


Sen. Kruger Wants To Ban Chatting On Cell Phones While Crossing StreetCBS New York (http://newyork.cbslocal.com/2011/01/25/ny-sen-wants-ban-on-chatting-while-crossing-street/)

[SgtBundy]

Hence the problem, laws can't stop behaviour for those that are too dumb to behave in the first place.

Take this example. Recently some guy drove himself to a Darwin cop shop demanding to be breath tested to prove to his boss he wasn't drunk. Not only did he blow over the limit, but he was working as a courier driver with a suspended license. The cops did their job on the spot, for two counts.

Man asks for breath test, arrested for DUI - ABC News (Australian Broadcasting Corporation) (http://www.abc.net.au/news/stories/2011/01/27/3122885.htm)

How do you stop stupidity like that with laws? If it wasn't for the fact muppets like the above take innocent people with them (or just take out innocent people) because of their actions, you could just allow a certain rate of attrition in society.

[maralinga]

And what is the industry doing to prevent being rolled over every other day?

Nil

Has the industry gathered together behind a representitive group despite their differences?

Nah

Where are the attempts to draw the behaviour of the regulator into the spotlight publicly (you know...political momentum...that ol'e chestnut)?

Nowhere

Only when aviation grows a spine will things change....until then.....Jellyfish

[allan907]

Nah. It'll never work. It's a well known fact that for every cock-up a subsequent written rule will ensure that that cock-up never occurs again.





It's amazing how many of our regulators still believe in Father Christmas and fairies. :ugh:

[peuce]

Leadsled,

I'm with you (this time).

I have often said on these pages that the optimum position is when we can get to a one page rule book ... "You shall provide a safe operation"

It's then incumbent on each operator (company or individual) to provide safety assurance ... sufficient to achieve that outcome

As others have said, you can never legislate out every little way in which someone can operate un-safely... so you have to put the onus on them to achieve the desired positive outcome.

However, the questions remain:


Do we monitor each operator's safety assurance plan?
If we do, who does it?
Against what criteria does that person judge the plan? (regulations?)


I can see a lot of implementation issues, but I still think it's possibly doable.

[triadic]

Sadly there is too much self interest and until the industry gets it's collective ducks in line and speak as one voice it will never change.

It worked for a bit in the mid '90's, but along came self interest and destroyed it all..................

CASA is not about safety... it all about regulation and enforcement! That is not the way to promote a safe aviation industry as the experts keep saying, but nobody in Government or CASA is able to understand that!

As as said before the greatest threat to safety in Aust is the AG's Dept.....!

:ugh::ugh:

[Horatio Leafblower]

* Do we monitor each operator's safety assurance plan?
Yes, I think if we licence operators then there must be oversight of how they do the thing we are licencing them for.

* If we do, who does it?
We could set up an independent office, funded by the federal Govt, made up of experienced pilots and Aircraft engineers to use their experience and judgement

* Against what criteria does that person judge the plan? (regulations?)
I am sure it would be a simple thing to write a set of rules that would provide guidance to operators. There would then be a set of manuals that guide the decision making of the experienced pilots and engineers in the Govt-funded regulator...

oh hang on... :ouch:

[601]

I am sure it would be a simple thing to write a set of rules

Why not write an OM (based on level of operation and type of equipment) that everyone has to operate by and be done with the regulations and the regulator.

Have peer review of operators to ensure they are operating iaw the OM. Not paper audits, but genuine operational audits.

[CoodaShooda]

Sgt Bundy

You could also use that case as an argument against over-regulation in our society.

The driver in question was obviously driving safely, or he wouldn't have made it to work or to the police station. He also had sufficient wits about him to seek advice from his union and to carry out their instructions to be breathalysed.

His sins are:

that his blood alcohol level was above an arbitrarily set limit that has no bearing on his physical capabilities. Not so long ago .08 was the allowed limit in the NT but we had to change to come into line with the southern states. Had we not changed, he would not have been over the limit; and

that he had apparently failed to respond to demands for payment from the Fines Recovery Unit and they had cancelled his license a short time before. There is nothing to say that he had received any advice to that effect or that he was otherwise aware of the cancellation.

Given that there are no requirements for recurrent training once you get a drivers license, you'd have to question the license's practical value with regard to safe motoring.

So it would appear his offences are due to administrative breaches rather than him being a genuine physical danger to society.

[Jack Ranga]

Only a Territorian could come up with a defence like that :D Well done :O

[Trojan1981]

CoodaShooda, are you a barrister? If not, you have missed you calling:D

[Andy_RR]

... a one page rule book ... "You shall provide a safe operation"

...

However, the questions remain:


Do we monitor each operator's safety assurance plan?
If we do, who does it?
Against what criteria does that person judge the plan? (regulations?)





Just add another rule that you must insure your operation against public liability commensurate with the cost risk you undertake.

Then the insurance industry supervises the safety assurance plan by requiring surveys in much the same way the maritime industry has historically operated. The judgement of the plan is then dictated by the insurance company, its survey requirements and the policy premium the operator is prepared to bear.

The advantage here is you get competitive tension in the regulatory environment. No one insurance company can place onerous conditions on an operator above and beyond what their competition will demand.

Proper market forces in action!

[Sunfish]

It is perfectly possible to comply with each and every aviation regulation and still be totally criminally unsafe.

Regulations do not make you safe at all.

You can see this behaviour on our roads every day. Everything perfectly legal, speed exactly within speed limit, only it's raining cats and dogs and any speed beyond walking pace is totally unsafe.

[LeadSled]

It is perfectly possible to comply with each and every aviation regulation and still be totally criminally unsafe.Sunfish,

As a previous Director of CASA (Leroy Keith --- the most able of CASA CEOs since the CASA was legislated into being) said:

"A compliant organization is not necessarily a safe organisation, a non-compliant organisation is not necessarily an unsafe operation".

The idea that you can legislate human frailty and human error out of existence is farcical.

Tootle pip!!