Cabot, PM, strong views, but it would be unfair to cite the EU as the problem.
Whist the legal basis of the European Parliament could have influenced the style of safety regulation, it is the mindset that safety can be 'enforced' by regulation which is the real problem. Safety is not definitive, something which can be achieved; it is that which is done, an activity, a dynamic process which must continually evolve.
The EASA regulatory approach to safety is stalling; it is cluttered, a complex ineffectual bureaucracy, and out of touch with real operations. In its defence, the industry is changing faster than regulations can react; thus there is a need to consider a new view of safety, but is the view outlined above sufficient?
Will the change of emphasis towards SMS and oversight be sufficient for the industry's future safety needs? By the time that EASA implements the planned change the industry may well require even more advanced safety activities.
Thus it would be better for EASA to consider a more radical approach to safety, future developments of SMS, new ways of thinking about safety, and hopefully more instep with the practical industry.
Avoid 'catch up' management, set the future standard.
"Safety is a dynamic non-event" (Weick and Sutcliffe).
EASA requires radical change to avoid being seen as a 'non-dynamic entity'.