Originally Posted by
LeadSled
Folks,
If I was "in CASA", it would not be "objective truths", but for every rule proposed it would be a risk analysis process, and cost/benefit justification, and many of the "rools" would never see the light of day.
The 1998 draft of CASA Part 91 was an example of that process, if you can find a copy, you will be very surprised as what a concise and clear document resulted. Its page and word count is significantly less than the FAA or NZ CAA equivalents -- it is amazing what a bit of ruthless pruning (without the double p) can do, without reducing the utility of the document for its the core purpose --- General Operating and Flight Rules. Of course, in total contrast to the current draft, about five times the page count, and often bordering on the indecipherable.
Indeed, at one point, when I did have some influence, CASA did a very instructive exercise, in part with two performance based rules consultants from the ATO, of all places.
The rules set chosen for the exercise was a slab of the maintenance rules. Using outcome based performance criteria, risk analysis based on probable "air safety outcomes" and benefit/cost analysis, something in the order of 70% of the maintenance rules would have been scrubbed, leaving what "common sense" said most people would probably do, anyway, but things like "ICAO" still required a minimum.
Interestingly, in mid 1990s, "mandatory" fuel reserves were scrubbed, in favour of better education for both pre-flight planning and in-flight monitoring ----- but "mandatory" fuel rules remained in Operations Manuals.
The results were instructive. In subsequent years up to the post-implementation review, amongst non-AOC operations, fuel exhaustion accidents had a major and statistically significant reduction, in AOC operations, the numbers did not change. So much for the power of "mandatory". But FOIs hated the idea, so much less to "pingya" on ramp checks.
The big message here ---- for real risk management (aka "air safety") it is using your brains that counts, not slavish and mindless conformity with "the rules".
Tootle pip!!