Originally Posted by
Flying Lawyer
NutLooseI'm not in a position to comment about engineers specifically but I wholeheartedly support the CAA moving further towards a safety management system which gives operators/organisations power to make responsible decisions in order to ensure an acceptable level of safety. That approach includes removing regulations where possible, regulating only where necessary, regulating proportionately and delegating where appropriate. Heavy-handed regulation often amounts to using a sledge-hammer to crack a nut.
Transport Canada was one of the earliest regulators, perhaps the first (1999), to start moving towards a Safety Management System approach, asking individuals, companies and organisations to put systems in place to identify, assess and mitigate risks, and to analyse whether they are meeting their safety goals and continuously improving safety performance. ie To be proactive.
As far as I'm aware, it has not been interpreted as "shifting responsibility' in a negative sense but widely welcomed and preferred to the previous 'traditional' approach to regulation.
It's possible that attitudes have changed since but my impression is based upon 10 days in Canada (Vancouver, Toronto, Ottawa, Montreal) in 2013 discussing flight safety issues and associated regulation with a wide variety of very different types of operators and sizes ranging from small GA to a regional airline and also an airshow organiser, as well as meetings at Transport Canada (with the Director General of Civil Aviation), the Transportation Safety Board (two members of the Board and several senior investigators) and ending with a meeting with the then Secretary General and two heads of relevant departments at ICAO.
The SMS method appears to work. Canada has one of the most successful and safest civil aviation systems in the world.
While it all seems fine in principal, one of my major concerns from all of this is without a clear cut, laid down and cast in stone set of requirements for airworthiness, the system is open to abuse where maintenance standards in smaller companies can become driven by pure financial reasons and not safety.
Through all of this and from what I have read from the AAIB reports so far on the Shoreham disaster, a lot of emphasis is being foisted on the likes of seat cartridge lives and the maintenance schedules, neither which I doubt had anything to do with the incident, but that will be seen when the final report comes out.
However maintenance systems failings are already being compounded by the CAA, under the previous system the maintenance was carried out IAW the manufacturers maintenance manuals and they were the basis that everyone had to adhere too, that has changed.
Now as an example of what I mean, Cessna worried about ageing aircraft began purchasing high houred examples of their product and strip them down, they would then identify problem areas to be addressed and issued Special Inspections called SIDS, these started with their twin 400 series and permeated down the 300 and 200 ranges, all being required by the CAA to be embodied. When the 100 series SIDS came out the CAA took the unusual steps in not making them mandatory and allowing individual companies to determine if they complied with them.
This then set a strange precedent, because in EASA which was brought about to create a level playing field it was left up to individual countries authorities to decide if they mandated them or not. Thus in my eyes obliterating the whole reasoning behind EASA.
Cessna then introduced into the 100 series maintenance manuals the SIDS and when querying this with the CAA I was informed only items in section 4 were mandatory, but as Cessna wrote the manuals prior to the ATA 100 system, their limits are in section 2... I was then told you could ignore those parts, and that in my eyes is where the system collapsed, prior to he changes where the book had to be followed to the letter, by saying parts could be ignored opened up the whole manual to individual interpretation as to what is required or not.
I was also told unofficially that Cessna will not rewrite the manuals as that then brings them back into the realms of product liability again for another 10 years in the USA, whether that is correct I do not know, but it sounds reasonable