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Truss: Aviation Safety Regulation Review

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Truss: Aviation Safety Regulation Review

Old 11th Mar 2014, 10:03
  #461 (permalink)  
 
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the problem is easy to see. the nutters in the government agencies are so effing cluelessly incompetent that they are totally unable to understand what needs to be done.
kick into the mix an unspoken fear of death by flying, illusions regarding terrorism and the need to be seen to be doing something (we don't know what but for christs sake do something!!!) and you have what we see.
a clueless minister
ineffective politicians
an embuggerance of a statutory authority.

it is the incompetent leading the fearful in an endless milling frenzy.

as a guy who flies an aircraft he maintains himself and has absolutely no fears from a sound understanding of aerodynamics and aeronautical engineering, I must seem like a martian to these people.
we all know that martians are to be feared and need to be killed.
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Old 11th Mar 2014, 10:48
  #462 (permalink)  

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17 out of over 230 something?? = consensus, you must be a sctrutineer for the Greens

just saying. Now for the usual suspects.
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Old 11th Mar 2014, 11:07
  #463 (permalink)  
 
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You're being a little naughty, Gaunty!

You don't know that the content of the other 220 submissions is supportive of the output and direction of the regulatory reform program. Given that Mr Forsyth has already stated that everyone's agreed that the output of the program is "a dog's breakfast", it is reasonable to assume that not many of the 220 describe the current output and direction as a good idea.

Or do you disagree? If yes, on what basis do you disagree?
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Old 11th Mar 2014, 11:22
  #464 (permalink)  
 
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Given that Mr Forsyth has already stated that everyone's agreed that the output of the program is "a dog's breakfast", it is reasonable to assume that not many of the 220 describe the current output and direction as a good idea.
Are the 17 submissions listed actually the first 17 out of the 220 to be submitted? If so, that would explain why only 17 have been made publicly available for scrutiny/review. The AG, AMROBA and Pro Aviation submissions were enough for the Miniscule to react in the way he did and ensure any other damning comments were put under lock and key. This would be totally in line with Liberal party tactics and the tactics of an old dog Miniscule who has been around the block a few times during his career
One can only imagine what is contained in the other 203 submissions, but of course Miniscule Truss, Mrdak and the assorted advisory turd polishers know exactly what the context of those reports say about Australia's aviation bodies and their Government masters
Somehow I think Gaunty and Creamy already understand this
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Old 11th Mar 2014, 13:32
  #465 (permalink)  

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Snoop

Creamy me old, who me, naughty ?:roll eyes:

I agree, my point was ONLY that the conclusions drawn by Up into the Air, are not based on a large enough sample of the total to be statistically significant.

And no I don't know the content of all of the other submissions.

I absolutely agree that in terms of regulatory reform and the regulators behaviour it has been like watching a train smash of epic proportions in super slo mo with a peripatetic in charge of the jogging control with a melange of Groundhog Day thrown in for good measure.

I don't believe ANY of the other like minded or culturally aligned NRA suites are fully compliant with the ICAO, nor do not, in one way or another, have maybe a similar number of oddities as does the CASA suite.

So grabbing at any of them holus bolus is not IMHO the answer and would bring more trouble than in we are already.

Difference is and its only IMHO, the other NRA's (definitely not EASA) at least share a coherent structure with a reasonably rational philosophical foundation for their being.

They will all have what they will tell you, justification for their differences to the ICAO to which they are all signatories, how does that work?

We here have been endlessly educated and berated about the fact that Australian air is somehow different to that in North America and Europe and that we are a world leader.

it is not and we are not, by any definition.

What we do have is a reasonable base from which to work. Its not perfect but we know which bits work and which do not and where to go for the missing bits. We can not nor should not throw 20 years and $250M in the bin, some of it is usable,

Its not rocket science, nor beyond the people it affects most and that is the industry who have actual real world experience.

Fox's and chickens you say? Not if it is constructed by industry people who understand that unless the result has a clear and demonstrable safety benefit, and after all thats why we have regulations, it will not work.

At the end of the day you have to have trust that good people with good will, will want to do good things. We trust our "licensed" personnel to exercise the privileges of heir "license" to do the right thing. its how its supposed to work.
We're not quite there yet but with CRM and SMS now taking firm hold with higher supervisory responsibility and an increasingly transparent economic imperative that requires this behaviour is exercised to a very high level the responsible operators are almost self saucing.

My personal view from here is that we can take the overall numbering suite 1 thru 198 or so with Headings, work through them against what we already have use the best of the rest for what we haven't and the make them ICAO compliant and SMS based or justified, then we will have a world class system.

All reviewed and written in "plane talk" by a panel of industry peers and free of tortuous legalese. Most importantly simple enough for pilots, users and the public to understand, that you don't have to go hunting through a dozen different documents to find that there as actually 2 or 3 different answers, then you can shop for the result you need.

Existing CASA staff may contribute for their individual expertise but the final result must be driven by the industry in compliance with Government policy.

The industry has some seriously competent and experienced people whom led competently can be trusted to get it right.

i think maybe there has been a sufficient flushing out of the dodgy bros operators and general maturing, that we can reset the enforcement regime to a more tolerant one by changing the mindset from offence to violation and placing the liability where it belongs.

Trust, the fundamental basis on which this industry works, must be restored.

Otherwise a certifying signature is not worth the paper its written on?

Confrontation has no place in the safety agenda under any circumstances.

This will of course require a pretty vigorous retraining and re education of a goodly number of the staff, but given the will and full Government support i reckon 12-18 months to finish the process to everyones satisfaction would not be out of bounds.


Rant off.

Last edited by gaunty; 11th Mar 2014 at 13:38. Reason: syntax and explication
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Old 11th Mar 2014, 14:07
  #466 (permalink)  
 
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it was put to me in a conversation that the ministerial staff were absolutely afraid of some aspects of aviation.
this casa embuggerance and smoke and mirrors complexity was a deliberate government driven ploy to stifle the life out of aviation.

I'd love to know what they are actually afraid of.

do we have some cocaine snorters in the halls of power?
that would explain a lot of the senseless paranoia.
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Old 11th Mar 2014, 23:42
  #467 (permalink)  
 
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… They will all have what they will tell you, justification for their differences to the ICAO to which they are all signatories, how does that work?

We here have been endlessly educated and berated about the fact that Australian air is somehow different to that in North America and Europe and that we are a world leader.

it is not and we are not, by any definition. …
The ‘air’ may be the same, but Australia’s topography and climate are not the same as other countries’. Consequently, for example, there is no safety justification for Australia to strictly comply with ICAO runway width standards that are designed to deal with ice, snow and other contaminating phenomena that are rarely, if ever, encountered at Australian airports.

Nor is Australia’s health system the same as other countries’ and (with the stark exception of CASA recently) health risk decisions in Australia are based on truly expert opinions and truly objective data. Consequently, for example, there is no safety justification for Australia to strictly comply with ICAO colour vision standards, which are merely a hangover from the purely coincidental adoption of the maritime ‘rules of the road’ and navigation aid system for aviation, over a century ago.

I started singing ‘Kumbayah’ by the end of this paragraph:
All reviewed and written in "plane talk" by a panel of industry peers and free of tortuous legalese. Most importantly simple enough for pilots, users and the public to understand, that you don't have to go hunting through a dozen different documents to find that there as actually 2 or 3 different answers, then you can shop for the result you need. …
How could we have been so stupid? The solution was staring everyone in face! Just get “a panel of industry peers” to do a “review” and all will be solved.
[I] reckon 12-18 months to finish the process to everyones satisfaction would not be out of bounds.
I reckon you’re deluded.

The RRP has been 12-18 months from completion for over a decade.

CASA’s left all of the hardest bits to last. For example, if you think classification of operations rules are going to be agreed and tied in a nice plain English bow by ‘a panel of industry peers’ this side of the end of the decade, if ever, I’ve some cheap shares in the Brooklyn Bridge for you.
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Old 12th Mar 2014, 00:01
  #468 (permalink)  
 
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'gaunty, me old' eh!


It's good you stick your head up every now and then to remind us all how your input helped inflict 'strict liability' upon us all. It's amazing you, of all people have the hide to even pass yourself off as some sort of expert on CASA regulatory matters, let alone pass on any unbiased opinion. I also vaguely recall creampuff being some sort of 'strict liability' advocate at the time.


It may be of interest to you, gaunty, that your efforts will be mentioned in dispatches in the upcoming Attorney Generals Inquiry, as that piece of bad historical legal bastardry fits well within the terms of reference.


11 December 2013?New Australian law reform inquiry to focus on freedoms


Unfortunately you will have to wait for those submissions to be published and hope there is no 'privilege'. As my submission will be but one of many based on fact it will be interesting to see the fallout.


The Truss 'review' may well account for some slaps with a wet shoelace and some upper and mid level bureaucrats getting a DCM with bar, but it could well lay the foundations to challenge 'strict liability' offences as illegal and lay waste to everything CASA has regulated over the last decade.


It may come to pass that if that were to occur, you would have done us a great service albeit with a lot of flotsam and jetsam along the way. Whatever, there is then a real chance that we will have to adopt a form of the FAR's for immediacy of safety, as tearing up the existing Reg's will effectively ground every aircraft in Australia.


The Brandis Inquiry has more teeth than the Truss 'review'. Whatever sample you now wish to ridicule as inadequate, they will be bookends for the paperwork to come.
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Old 12th Mar 2014, 00:15
  #469 (permalink)  
 
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Strict liability has been and continues to be fact of life. (Do you drive at all?)

It’s just that spelling it out repeatedly in the civil aviation rules (as a consequence of the requirements of the Commonwealth Crimes Act 1914) has upset the bliss of ignorance.
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Old 12th Mar 2014, 01:24
  #470 (permalink)  
 
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Strict liability: Well, just because it's law doesn't make it a good law. Many aviation administrative actionable offences have been made criminal offences. I believe road laws, even electronic speeding devices and alcohol instruments are open to challenge in a Court of law without seeking redress from the AAT.


Things are made complicated by the application of over regulation. An example, the Hamilton Is PA-32 fatal crash where the pilot was found to have a Non-therapeutic drug indicator after a considerable time, (weeks), from ingestion. Not only are the inclusions of this finding irrelevant in the final cause determination but was the main catalyst for the now disgraced drug and alcohol testing regime now foisted upon us.


Strict liability is abused by the CASA and the Brandis inquiry is focused upon this plus other matters that have been taken to like a duck to water by the same collective of dungeon dwelling, dysentery spreading amoebae's lurking under and around the CASA umbrella.
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Old 12th Mar 2014, 01:38
  #471 (permalink)  
 
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creampuff and gaunty you guys have destroyed your credibility in one post each.
congratulations.

but hey I'm a martian with a 41 year history of safe illegal aviation.
wtf would I know.

when are you people going to recognise that CASA has assembled together a mutually self supporting group of utter nutters.
all with the sincere stare, the concerned look on the face and utter nonsensical logic.
the snow job has seen $240,000,000 of taxpayers money evaporated with nothing acceptable as even the interim result.

ministers, there is nothing wrong with admitting that you were victims of a snow job.
the blatant waste of taxpayers funds must be put to a stop.

kill off the Clueless Arseholes Screwing Aviation bullshit. bring in the New Zealand FAR's and get some sense back into aviation.
the lawyers aren't the way to make aviation safe.

me maintaining my aeroplane is the only safe way to fly the damn thing. thats why I do it. why the hell would you make it illegal. haven't you got a bloody clue??
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Old 12th Mar 2014, 01:38
  #472 (permalink)  
 
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But Frank, Brandis is a Laborial. He’s one of the people who’ve presided over the inexorable increase in regulation of every aspect of your life. He ‘knows’ that ‘safety’ depends on ‘strong’ regulation.

Good luck! Let us know how you go.

W8 - thanks; I think ...
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Old 12th Mar 2014, 01:51
  #473 (permalink)  
 
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sorry creampuff I read that post as you advocating the nonsense

I see that you merely state that it exists and give the enacting law.

you get another chance
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Old 12th Mar 2014, 04:10
  #474 (permalink)  
 
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Creampuff;


Safety depends on common sense and that can't be regulated. Senator Brandis knows that, and may well be a laborious, Liberal Party lawyer, however he knows how lawyers think. I don't, always thought they were a peculiar lot and not to be left alone with cats.


Do you consider he would call an inquiry into the whole $hitfight if he thought it was going hooters?
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Old 12th Mar 2014, 05:00
  #475 (permalink)  
 
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We all know why politicians call inquiries, Frank …

BTW, I agree with you in principle. All of the penalties in the civil aviation rules could be changed to “Death” and it wouldn’t make a schmick of difference to the accident and incident rate.

If I recall correctly, part of Mr McCormick’s self-serving but mercifully-curtailed spray at the start of the last round of Estimates hearings included a reference to having civil penalty rather than strict liability offences in the rules. I was reminded of that song lyric: “too much; too little; too late ….
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Old 12th Mar 2014, 08:52
  #476 (permalink)  
 
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Folks,

I note the SAAA submission, the contents of which comes as no surprise for a bunch of, in my opinion, rent seakers, tryingt to, once again (there have been many attempts since 1998) for a return to the glory days of their CAA/CASA etc guaranteed income - a setup that, in my opinion, grossly impeded amateur building in Australia.

In short, in my opinion, SAAA want all the pre-1998 red tape and restrictions reintroduced, plus a few more sources of red tape revenue that didn't exist pre-1998.

The US style Experimental categories, including the Experimental Amateur Built have been a resounding success in Australia, why would we want to revert to the old, restrictive, and Oh! So Expensive red tape bureaucratic nonsense of the AABA system --- ????

There is certainly no safety justification, not even in terms of S.9A of the Act.

What SAAA is proposing, in my opinion, is a solution looking for a problem, and a guaranteed very expensive solution for amateur builders, to a problem that clearly does not exist. Any aviating is already expensive enough, without adding substantial extra costs.

The real problem for SAAA, in my opinion, was that they lost a significant regulated revenue source in 1998, and have been trying to get it back ever since.

Tootle pip!!
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Old 12th Mar 2014, 10:50
  #477 (permalink)  
 
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And there you have it, gaunty.

Any ‘panel of industry peers’ would be at each other’s throats before morning tea on the first day…

Agreement on e.g. classification of operations? Snowflake's hope in hades!
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Old 12th Mar 2014, 16:06
  #478 (permalink)  
 
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Agreement on e.g. classification of operations? Snowflake's hope in hades!
Creamie,
Actually, a very reasonable Class. of Ops., with no industry dissenters, was finally completed during the time Byron was Director.
The incoming Mr. McCormick tossed it, just as he tossed Byron's directive that mandated government policy on Cost/Benefit justification and outcome based regulation.
Tootle pip!!
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Old 12th Mar 2014, 20:41
  #479 (permalink)  
 
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Actually, a very reasonable Class. of Ops., with no industry dissenters, was finally completed during the time Byron was Director. …
Actually, there wasn’t. (But it does depend on one’s potentially self-serving definition of ‘industry’).
The incoming Mr. McCormick tossed it, just as he tossed Byron's directive that mandated government policy on Cost/Benefit justification and outcome based regulation.
That’s because Mr Byron’s directives were all vacuous motherhood statements that reflected existing vacuous government policy. If only he’d published a ‘Directive’ to ‘cut red tape’ as well…

But I could be wrong, and maybe I’m a glass half empty guy as guanty suggests, despite my having been spot on with nearly every prediction I’ve made in the last decade about the regulatory reform program.

So, time to put up or shut up, 'industry peers': Please cut and paste into this thread the very reasonable classification of operations rules that have no industry dissenters, all reviewed and written in "plane talk" by a panel of industry peers and free of tortuous legalese.

Please do it or please STFU.

My prediction: You won’t do it, because you can’t do it.

The 'industry’ is not agreed on an underlying philosophy for classification of operations. Anyone who’s read and understands the implications of the publicly available submissions to the ASSR Panel should already know that.
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Old 12th Mar 2014, 23:22
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Angel An academic contribution.

The Australian School of Business (IRRC) is nearing the end of a three year research project into the Future of aircraft maintenance in Australia:
Located in the world's fastest growing aviation region, Australia's vital air transport industry faces a shortage of skilled aircraft maintenance engineers that may increasingly be solved by moving much aircraft maintenance offshore.

This project will examine the options for this industry's future, exploring the safety risks of offshoring, and the costs of developing or losing a skilled national aircraft maintenance workforce.

It will develop a method for forecasting aeroskills requirements, explore new approaches to workforce development, and analyse the costs and benefits of allowing the industry to decline, rather than contributing to a strong national aerospace and technology sector.
The study report is due to be released later this year but in the meantime, using interim findings, the research team has made a submission to the WLR.. Although I am yet to track down the actual submission, the following article perhaps highlights the finer points of the ABS submission to the WLR panel :
Sky Wars: Why Offshore Aircraft Maintenance is a Flawed Strategy

Published: March 10, 2014 in [email protected] School of Business

Aluminium smelting, oil refining, car making – the list of Australia’s vanishing industries grows longer. Among reasons for ceasing Australian operations, Holden, Ford and Toyota cited fierce global competition, a small local market and a relatively high wages bill. Now Qantas, in announcing plans last month to cut a further 5000 staff in the face of financial losses, has added arguments about the ‘unfair’ requirement that it service its aircraft in Australia. It's rival, Virgin, relies on overseas workshops.

Australian aircraft maintenance has been moving offshore for some time. This increasing trend has been put under the microscope by the Australian School of Business (ABS) during the past three years in an Australian Research Council study – The Future of Aircraft Maintenance in Australia: Aviation Safety, Workforce Capability and Industry Development.

The key researchers – ASB professor Michael Quinlan, associate professors Anne Junor and Ian Hampson, senior lecturer Sarah Gregson and research associate Doug Fraser – were inspired by concerns about the strategic and economic costs of offshoring, possible threats to passenger safety and a declining skill base in the Australian aircraft maintenance, repair and overhaul (MRO) industry.

The full study will be released later this year, but the researchers have utilised interim findings in an ASB Industrial Relations Research Centre submission to the federal government’s Aviation Safety Regulation Review, due to report in May. A key point in the submission is a looming skills crisis.

As local maintenance jobs have been cut, such as the 1000 positions Qantas is reported to have shed during 2012, the training capability for the next generation has gone into free fall. Junor has mapped MRO organisations and found as many as 50% have closed down in recent years and that difficulties in finding staff are prevalent among remaining providers. Defence facilities now account for about 75% of apprentice completions. One of the two civilian NSW centres presently approved by the Civil Aviation Safety Authority (CASA) to train aircraft engineers has 10-15 students this year. In 2013 it had 30. During the past 10 years it had about 100 per year.

Global Opportunity

According to Fraser, fostering MRO should be a no-brainer for Australian industry strategists.

“It’s no longer just a sideshow of running an airline. It’s a big global industry in its own right, worth around A$70 billion a year and likely to at least double during the next 20 years. It utilises the kind of highly skilled blue-collar labour that Australia has traditionally been good at developing. It offers many specialist areas of work where Australia’s comparative wage costs don’t seriously limit our competitiveness,” Fraser says.

“Above all, international authorities expect most regions of the world to fall well short of the training output needed to meet their own MRO requirements over the next decade.”

Fraser puts the decline in MRO skills down to a series of policy oversights by successive governments.

“Australia traditionally relied for the bulk of its technical training on big public-sector organisations such as the railways, Telecom and Defence establishments, and a few of the largest private companies,” he says. “In the 1980s we had Qantas, TAA and Ansett all running substantial apprenticeship programs. Qantas absorbed TAA, Ansett went out of business, and nobody else has stepped in to fill the gap.

"In effect, Australia's MRO training effort has been allowed to become hostage to the strategies and fortunes of a single company. If that company now can't look after itself, how is it going to look after the future needs of the Australian industry?"

The skills drain could leave the fledgling Australian aircraft-component industry in the same situation facing the car-component industry.

Says Junor: “At the moment, Australia is the biggest components supplier to Boeing outside the US. Running down the capacity of our automotive and aero-skills training facilities is hardly the way to ensure our continued integration into this large global market.”

Profits and Safety

And what impact will the cost-quality trade-off of offshoring maintenance have on Australia’s enviable airline safety record? Hampson sees gaps in the safety surveillance systems.

“There are doubtless many offshore shops which give top-quality service that Australian consumers can rely on,” he says. “We know from experience that there are some which definitely don’t. The problem is that we don’t have enough good information to tell which is which. Australia doesn’t even keep public records of which maintenance goes offshore, never mind where it goes. Once it does go offshore, no public records are kept of where the work has fallen short of standard, or what rework is needed in Australia when the plane comes back.

“The risk then is that because there isn't enough information about quality, choices will be made on the basis of price. This is a classic ‘market for lemons’ situation, where quality providers get driven out of the market and many others survive who don't deserve to."

Hampson believes market forces alone are unlikely to address this threat. Airline profits need to be balanced against the probability of a major accident. While any such incident would have fatal consequences for the business as well as for human life, it might or might not occur, and if it does, it will be at some unknown point in the future, possibly only once the aircraft has been sold on and become someone else’s worry.

“An Asian airline Boeing 747 in 1980 suffered a tail strike from landing too steeply. It was not repaired properly and cracks appeared and 22 years later the plane fell out of the air. Aircraft maintenance can be a health risk but it is difficult to know the extent,” Hampson says.

Relaxed Approach

The researchers note “a contrast between Australia's relaxed approach to the supervision of overseas repair shops handling Australian work, and the increasingly stringent regulatory approach which public concern in the US has obliged Congress and the US Federal Aviation Administration (FAA) to apply to offshore providers”.

The FAA is subject to political supervision and accountability in ways that Australia’s CASA is not. The FAA was recently compelled by congressional legislation to tighten up its regulatory and supervisory practices. In Australia, the trend is for CASA to offshore its responsibilities to foreign aviation authorities to ensure safety standards. This leaves the certification of maintenance on Australian aircraft to the safety oversight, training and licensing procedures of another country.

“We wonder how consistent this is with the Australian safety program, as well as International Civil Aviation Organisation requirements that the State of Registry be responsible for the safety of maintenance performed on aircraft even in another country,” say the researchers.

Back of the Queue

The expected worldwide shortage of aircraft maintenance engineers is likely to increase offshore wages, negating much of the cost advantage of offshore maintenance and affect the viability of relying on offshore maintenance as the primary means of meeting Australia’s airworthiness requirements. Australian carriers may find themselves relegated to the back of the maintenance queue by other players with considerably greater political and/or market power.

Junor predicts a dissipation of Australia’s aircraft maintenance capability will have particular impact on the general aviation sector – regional airlines, commuter operators servicing fly-in fly-out, tourism ventures and the transport, freight and emergency services that support rural and remote communities. The major airlines may be able to rely on offshore maintenance but the general aviation sector cannot.

The submission argues that in the interests of the safety of the travelling public, Australia will need to rebuild its MRO capacity and the workforce to support it. This would require extensive structural reform, well beyond what the present market is likely to bring about.
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