Flawed Safety Case
We have been encouraged to re-enter this discussion, and to provide further information.
We have been pointed to transcripts of your senate estimates committee in which testimony was provided by representatives from various organisations involved in the airspace reform debate. We found the responses both amusing on the one hand, and deeply disturbing on the other.
One point that appears to have been lost totally on your regulator – and we would argue that this is significant enough to call into question the integrity of your regulator as a whole – is the set of statements relating to the use of training and education as a major safety mitigation.
In and of itself, training and education IS a very good safety mitigator – but ONLY if it can be demonstrated to be effective.
We understand that the safety regulator has examined implementation safety cases provided by your service provider and airspace change proponents which contain such education and training requirements – and has actually sighted the training material has sighted and noted the training schedule for affected controllers, and has witnessed the delivery of that training, and has sighted the assessment material that demonstrates competence – that is, demonstrates that the training and education material has been delivered effectively, and has achieved the desired safety mitigation.
It is therefore reasonable to say that all of the safety obligations within the implementation safety case have been effectively discharged – BY YOUR SERVICE PROVIDER.
However, the service provider is but one element of the safety equation. Pilots are the other. Clearly, from the material we have seen, and from transcript evidence presented to your Senate committee, whilst several people – including a senior representative from your Department of Transport and Regional Services undertook to ensure training material was created and distributed – there is ABSOLUTELY NO EVIDENCE that the safety requirement for effective training and education – the CORE safety mitigator - has been met.
Has your regulator examined airline training records to ensure that the training material was appropriately tailored for their operations, delivered effectively, and that delivery recorded? Has your safety regulator examined the training records associated with charter operations, aerial work operations and general aviation operations to ensure that the training material was effectively delivered and understood? Has your regulator examined the training records of the Defence establishments in your country to ensure that training material was effectively delivered and understood and tested?
If the airline certification process in Australia is similar to other major countries, there should be a process that requires a proper “check and training organisation” within the airlines. BEFORE the changes were committed – as appears to have been the case in relation to a Sunday evening meeting referred to in the transcripts, your regulator should have been able to demonstrate – in fact should have required your airspace reform program managers to demonstrate – that airlines and other operators could effectively deliver training in the required time.
You CANNOT create a Safety Case that requires safety mitigation from ALL parties – and then measure its effectiveness by the compliance of one party. Neither can you say that simply putting the training material “in the post” satisfies a safety obligation.
We have to question the competence of your regulator. This is a fundamental failing and calls into question the whole safety case process for your airspace reform.