Safety Officer Teleconference (6)

• The call started with an issue brought up by one of the callers. James said his organization is about to go through an ARGUS Platinum audit and asked for tips as to how to handle the audit.

o Rick replied that they have been through 3 ARGUS audits. That ARGUS will go through everything. They are stricter than an FAA audit. But he recommended to “stick to your guns” as to how you do things – you don’t have to change your process just because the auditor may want it done another way.

o Walter replied that it is important to be doing what you said you would do, as it is written in your ops manual. It’s a bit of show-and-tell. Also remember that the auditor is human and has opinions. If he challenges you on an issue, ask him where it says you are to do a particular function some particular way. Where is it written in the standards. Speak in terms as to whether the task is being completed, the process is “effective”. Sometimes the auditor may only be talking about his opinion to make it more “efficient”.

o Tom mentioned that the auditor should be discussing industry best practices, not a procedure that is just his opinion.

• New topic brought up by Walter Kraujalis. Here is something I’ve been saying for some time now. Let’s take “Safety” out of Safety Management Systems. You heard me right, let’s take safety out of SMS. Now that I have your attention, my point is that the term “Safety” is a rather powerful and emotional term in our industry, and when it comes to working with safety in an SMS environment, using the word Safety can get in the way. People may be reluctant to change or improve their processes because it implies that if we make a change, does that mean what they are doing now was “unsafe”? Or another way of saying this: Some think, we aren’t “unsafe” now, so why change? But if we substitute the word “Safety” with “Quality”, it is easier to understand and accept how an SMS works. In fact, the SMS framework is exactly the same as all the quality improvement programs out there, such as TQM and Six Sigma. Maybe start thinking of SMS in terms of improving quality. I try to avoid using the word “safe” or “safety” any more – what does it mean – it can mean different things to different people. Rather, I use the term “identify hazards and mitigate risks” whenever I mean to say “Safety”. …Thoughts?

o Mike replied to say that they call their SMS a “Risk Management System”, to purposely avoid the word “Safety”. This program name also fits better with corporate headquarters because that is how they refer to similar programs within the company.

o Mike continued to say that their dispatcher comes up with a “risk value” for the day. It depends on weather, the length of day, etc.

o Drew mentioned that they use the term “risk” in their department too. They mandate the use of a FRAT for every flight. They use ARINC Direct for flight planning and then the FRAT process associated with the flight plan. They rank issues as a 1,2, or a 3, or as low, medium, or high. If the total risk comes to a 2 or a 3, the ops team knows about the higher risk and will mitigate.

o Mike said that they avoid using a number score. They just use “low, medium, or high”. If a particular operation is identified, they mitigate. He used the example that if the weather at one of their destinations will likely result in needing aircraft de-icing, they make sure to build more time into the schedule to allow for that.

o Another Mike replied to say that risks are scalable – they could be something simple or very complex like an accident. They use a blog site to identify risks. No numbers are used, just high, medium, or low risk rankings. This keeps it more subjective, to get into shades of grey, things aren’t always just black and white. Twice a month they hold an “all hands” call, in which the risk assessments for the past two weeks are discussed and dealt with. They also sanitize, or de-identify, their reports.

o Rick said they do a FRAT for each leg. They message to the dispatcher and charter broker what the risk value is for each FRAT. Fi they see any high numbers, then management can step in and question a specific flight.

o Tom said they use debriefings after a flight as a risk evaluation tool. They compare what the FRAT forecasted the flight was supposed to be, to what actually happened on the flight. Things change and it is important to understand why they change. This information helps with being more accurate with future FRATs.

§ Walter Kraujalis said he like this idea. One gauge to use as to what is a reportable event, is anything that happened that was unplanned or unexpected should be reported. It is important to understand why it was unexpected or not planned for.

o Liz said they use the FRAT for briefing before each flight.

§ Tom said try using that same process for post-flight. This is also a way to get pilots involved in the SMS.

§ Rick mentioned that the Coast Guard Auxiliary using a pre-mission evaluation that is communicated to mission headquarters.

• Liz brought up a new topic. She asked how many operators were using FOQA? She thought the cost was prohibitive and wanted to know people’s opinion as to the value from FOQA.

o Drew said that they are a Part 91 operator but have their aircraft available for charter under a partnering vendor’s 135 certificate. The charter operator has been going through a tremendous growth spurt with adding a lot of aircraft and new pilots. They decided that they wanted to use FOQA to be used to assess and train their pilots, as well as enforce standardization. He said the data feedback from FOQA for them has been helpful, but not really all that enlightening for them. Their 91 operation is a close-knit group and only have their planes on the charter certificate for revenue purposes. He guessed that the value of the FOQA data feedback would depend upon the type of operation. For the charter operator, it has been very helpful. For his 91 operation, not so much. He said that if it were just for them to decide for their own operation, they would probably not bother with FOQA.

o Walter Kraujalis gave a brief background on FOQA for those on the call that may not be familiar with FOQA. He said that is clearly more beneficial for the larger organizations. As you get smaller, it becomes harder to justify the cost for the value. He also suggested that there are cheaper alternatives becoming available, that are like FOQA in providing feedback for standardization and training. He mentioned that with his safety engineering relationship with Allianz aviation insurance, they are keen on the Appareo Vision 1000 (see http://www.appareo.com/primarymenu/products/alerts-flight-data-monitoring/appareovision-1000/). It is being used by flight schools and now helicopter EMS operators, to capture flight and cockpit data for tracking purposes. He feels this same or similar system could be used in business aircraft. Sure there is the issue of a camera in the cockpit, but aren’t we to the point in our industry that we are all professionals and having a camera in the cockpit is soon to be expected. Maybe just have it on for the 20 minutes of takeoff and climb and 20 minutes of descent and landing. There can be a process of sanitizing the information.

§ One caller responded that it is important what is being done with the data from such a device. Management needs to understand the privacy issues. One wouldn’t want it used for disciplinary actions.

• Walter agreed. But that is the very idea behind a “just culture”. Management, and/or the safety management staff, understands that if something happens to any one of our pilots, it could happen to any of us.

• That concluded the call. It was 30 minutes in length. Next call is Tuesday, April 22nd, at 11:30am Eastern time. Thank you for your participation. Please let other Safety Officers know of the opportunity to join the call or to access these meeting notes.

​• This was an interesting question about how many folks are using FOQA. I have posted a question poll on the AeronomX website at http://www.aeronomx.com/safety-officerteleconferences.html. Please try to go there in the next two weeks and give your simple “yes” or “no” answer. Try also to leave a quick comment as to why you do or do not use it. I will give the results of the poll in a future conference call.