The headline on
Australian Flying's article that summarises the AAAA’s WLR submission,is spot on…
Aerial Ag Gives CASA a Spray
The Ag crew do not hold back, the submission is akin to dumping water on Fort Fumble with a DC-10 fire bomber..
AAAA WLR Submission
Standby for some overspray quotes…
“Dear Miniscule, …noxious weeds are out of control”
CASA is now performing so poorly as to demand significant change of its internal management and its relationship with industry so as to implement practical systems that will lead to commonly accepted benchmarks of practice and outcomes. CASA is dysfunctional at nearly every level, its relationship with industry has been junked, and it is suffering from such a pathological culture that major surgery will be required to realign the organisation with the common hallmarks of a sound safety regulator. CASA must walk the talk.
There has been a complete breakdown in the relationship with industry at the highest levels, an example which has now cascaded throughout almost the entire organisation.
There are many good people working in CASA who are simply unable to make headway against the prevailing culture. They are increasingly isolated and powerless.
There are also some who delight in the culture of ‘gotcha’ that exists and is encouraged at various levels, where the ‘zero-sum game’ against industry is strongest. The lack of systems and confidence to allow the free flow of information both up and down the chain of command within CASA sustains the negative aspects of the CASA culture, and reinforces and encourages behaviour that in a healthy, open and just culture, with a clear focus on cooperation with industry and positive safety outcomes, would simply not be tolerated.
As with all cultures, the problem starts and is sustained at the top.
CASA demonstrates no strategic engagement, with industry withdrawing from meetings and discussions that involve senior management due to fatigue from being lectured to.
There appears to be a complete disconnect between words spoken by senior CASA management and what happens on the ground – with no consistency of policy or interpretation being a long-standing concern. CASA encourages industry to adopt sound management principles and systems such as SMS, ‘just’ cultures and strong executive control of aviation companies, but is hypocritical in not applying these same principles and practices to its own operations.
CASA does not have ‘aviation issues’ – it has management and cultural issues. A resetting of the CASA/industry relationship is critical to establishing a more mature regulatory safety culture in Australia.
“He’s not the Messiah..”
Many people in aviation believe that the critical component in sound aviation regulation is to have the ‘right’ person in key jobs, such as the CEO of CASA.
Unfortunately, this ‘messiah’ approach is fundamentally flawed if not supported by longer-term strategic approaches, systems and checks and balances, as demonstrated by the history of CASA and its predecessors.
When industry first heard of the shift of CASA to being a ‘Big R’ regulator, industry accepted that clearly that was the right of the regulator and, industry assumed, was being done with the support of the CASA Board and the Minister. What industry did not anticipate was that the move to a ‘Big R’ regulator was code for the introduction of a bullying and intimidatory culture that would lead to a breakdown in relationships between CASA and industry, a significant reduction in the focus on innovative safety programs and increasingly shrill policing activities that are not delivering real safety improvements.
As previously stated, no aviation association has the track record of AAAA of working positively with CASA for the improvement of aviation safety and regulation. But it is not possible to continue to return to the table when it is clear that there is no trust and no respect being shown for industry’s genuine concerns and its innovative suggestions for improvement.
On RRP spray ‘drift’ problems..
The regulatory reform program is certainly not ‘reform’ any longer.
There is no overall goal in play – ‘safety through clarity’ has been abandoned and there is no real reason for regulatory reform other than for its own sake. Key outcomes, goals, timelines (ie strategic planning) must be established.
Key goals for regulatory reform should include increased safety, reduced cost, simplification and harmonisation.
Key regulatory triggers or thresholds must be established – ie if CASA staff have a good idea, that does not mean, ipso facto, it becomes law. It should have to meet the key goals identified as a trigger for reform. Similarly, if it adds considerable cost for little or no safety benefit, it should not become law.
Regulation should be seen as the final option when other approaches have been exhausted – such as education and safety promotion including joint ventures with industry associations – rather than the default setting and starting point for guiding all aviation activity.
This is a fundamental shift in CASA’s worldview. It is the view of best practice regulators the world over. Of course there need to be rules, but there do not need to be rules for every possible eventuality.
I could go on and on (it's that impressive..
) but I guess the real message here is…
…“Dear Miniscule, noxious weeds eradication program urgently needed!!”