Friday, December 13, 2013

When Regulations Are Performance Based, Make Safety Your Business.

When regulations are performance based they don't prescriptive describe what is required, but communicates what conforms to regulatory compliance. It might be tempting for an enterprise management to believe that actions are not required since regulation doesn't state what prescriptive action to take. If applying this approach the result might not be what conforms to regulatory compliance. 

Displacing the threshold 2000ft on a 4500ft runway might be what it takes to conform to regulatory compliance. 
Aviation safety has to be managed in a Safety Management System with a Quality Assurance Program where facts are analyzed. Whenever there are temptations to transfer responsibility and accountability from an enterprise to the regulations, that's when it is time to find out what went wrong with the processes.  

One regulation may say that airport operators are required to give notice of any known obstructions penetrating the protected Obstacle Limitation Surfaces. This could be cranes, trees or other objects being too high for the airport zoning.
An enterprise without a process to detect obstacles may believe that the obstructions were not known to them and therefore not required to give notice. This approach is an attempt to remove operational accountability and control from the operator and to transfer this  responsibility to the regulations. 

If an enterprise attempts to transfer responsibility to the regulations, what prevent pilots from taking the the same approach?
The proper CAP is to accept accountability and find opportunities to discover obstructions in the flight path. An enterprise needs to establish processes where obstructions that are "not known" to them becomes known.

Aviation safety is not to passively assume third parties to be accountable. Aviation safety is to actively seek out hazards, analyze and implement Corrective Action Plans.

When an obstacle violates an Obstacle Limitation Surfaces at an airport, someone accepted and allowed this violation to happen. This acceptance could be as simple as "it's not my problem" or "too much paperwork". When arriving at this fork in the road read the signs and chose a path  to aviation safety. 

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