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Old 10th Feb 2014, 21:31
  #316 (permalink)  
Sarcs
 
Join Date: Apr 2007
Location: Go west young man
Posts: 1,732
Thumbs up Bravo AFAP!

Blue Ruin thank you for that, not being a member of the AFAP I was unable to access what appears to be another significant contribution to the ASRR... {Q/ BR what is the current membership number for the AFAP?}

IMO AFAP members should be (especially given the short time to prepare) suitably happy with the end result, as the submission appears to encompass many of the main membership concerns while providing historical, simple examples and practical solutions/recommendations with strong adherence to the ToRs...so bravo AFAP...

Supplementary to BR quotes (same hymn sheet..):

7. Alternatively, we believe that the Director of Aviation Safety should not be able to operate independent of a Board structure.


8. We consider it imperative that all senior appointments to any agency with a safety related role should have significant prior experience in a relevant field.
Further to CAsA, other than Avmed debacle (my bold):
11. Policy changes aimed at greater industry self-regulation than currently exists should be opposed. In a climate of reduced resources a philosophy of self-regulation may appear to be an attractive short term option. However, self-regulation is a self-fulfilling principle; the more that CASA devolves to industry, the less expertise resides within CASA to identify shortcomings, the less CASA is seen as ‘the Regulator’ and the less it accepts that responsibility.

12. The perception of CASA by our members is one of constant change, characterised by high staff turn-over and low morale from within. Whilst we understand any regulatory authority will continually review its internal policies and administrative operations to improve service delivery and efficiency, there is a need for a clearly articulated long term goal of what the Regulator wants to achieve and how this will be done.
On the ATsB & PelAir report:
16. We support legislative immunity for flight crew who raise safety concerns and measures that allow flight crew to report directly to a better resourced and independent ATSB.


17. We oppose any relaxations which may allow greater access to information obtained by the ATSB during safety investigations.
25. We note that the Minister whilst in opposition supported demands for the immediate implementation of those recommendations and request that this Review revisit the findings of that inquiry and recommend the implementation of those recommendations as a matter of priority.
28. This is contrary to the intent of ICAO Annex 13 which states that "the objective of an investigation of an accident or incident is prevention of future events" and the ICAO Safety Management Manual which states that "information should be collected solely for the purpose of aviation safety and information protection is essential in ensuring the continued availability of that information". It follows that ATSB reports on accident or incident investigations or any information from the mandatory reporting process should never be made available for regulatory enforcement purposes or civil actions.


29. For a safety reporting regime to operate effectively people must be confident that disclosure will not result in punitive action unless the action was deliberate or reckless.
Finally on RRP, I could quote the whole lot....but to summarise:
41. In contrast to Australia’s CASRs 1998, the New Zealand Civil Aviation Rules are clear and comprehensible. While in no way endorsing the content of the New Zealand legislation, we would support clear plain English regulations aimed at and comprehensible to the industry, not just lawyers.


42. We therefore request that the regulatory development process be reviewed in the interests of achieving the goals of clear, concise and unambiguous regulations delivered in a timely manner.
{Comment: Especially liked the 'Aeroplane' definition example from para 35-39..}

I could go on cherry picking but this submission has already got the IOS tick of approval...again bravo AFAP!

Note: AFAP sub quote at the end...

"...As previously stated, the Federation would welcome the opportunity to supplement the above written submission via verbal submissions to the Review Panel..."

Although the time frame is still limited, it would appear that the panel would be willing to accept further supplementary submissions in support of original submissions, see here...

Submissions are now closed
The formal submission period has now closed. However the Panel will endeavour to consider late submissions.
To make a late submission please use the
Aviation Safety Regulation Review Submission Form.

Addendum: Noted this short summary article from Australian Flying on the RA-Aus submission, where it seems the primary membership concern is the imposition of the ASIC: RA-Aus Weighs into ASIC Debate
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