A Few Thoughts on Safety… Part 2

I’d like to continue sharing a few thoughts on Safety. I promise—next month I’ll switch topics, especially considering the feedback we received from last month’s survey (thank you again for participating! 😊 And feel free to continue sharing your views; the survey is still open—more info at the end of this newsletter).

That said, expect SMS to return in future editions. It’s such a broad and important subject that it deserves ongoing discussion.

Last month, I left you with a few thoughts on how we define safety and what we’re actually managing.
(If you missed the article, you can read it on our blog: https://www.cacglobalsolutions.com/blog/a-few-thoughts-on-safety)

 How Do We Manage Safety?

When it comes to management itself, the big question is: How do we manage safety, and what approach do we take?

Whatever approach we choose must be grounded in the structure that aviation organizations already operate within—whether you’re an Operator, an Airworthiness Organization, a Maintenance Organization, or anything in between.

Our starting point—our “Point Zero”—should be our policies and procedures, which are rooted in regulatory requirements. I often hear discussions about introducing more procedures to make sure we “get safety management right.” But I’m not a fan of adding endless layers of procedures. In my experience, many organizations are not even following the procedures that already exist in their own manuals. Adding more only increases rigidity and creates inconsistencies with what’s already in place.

 Let Me Explain with a few examples

When you bring your aircraft to a Maintenance facility, the maintainer must review the requirements applicable to your aircraft by referencing your company manual—including your policies and procedures. A simple example is the Certificate of Release to Service (CRS) statement. Managing aircraft on multiple registries, I can’t count how many times I’ve had to ask maintainers to correct the CRS statement.

Why does it matter?
Because if the CRS statement is wrong, the maintenance performed is not valid—and the aircraft is not airworthy.

You might say: “But they followed the AMM. Isn’t the AMM the same whether the aircraft is FAA-registered or Cayman-registered?”
Yes… but that’s a topic for another article.

The point is: if the CRS statement is wrong, it means nobody reviewed the company manual. And then the next question becomes: Where was Quality? Why didn’t they catch it?

Other examples include installing a modification that introduces equipment incompatibilities, not reporting defects, or failing to use the MEL properly. All of these create unsafe conditions.

But we already have procedures for them—don’t we? Of course we do. Manuals, customized MELs, defect-reporting requirements… these are regulatory basics. And yet, despite having the procedures, we still don’t always follow them. Meanwhile, we talk about implementing more procedures to improve safety.

Do you see the issue?

 A False Starting Point

We’re trying to improve safety based on a “Point Zero” that isn’t functioning. We’re using a false parameter. And what concerns me is that this approach risks making the system so rigid and so complicated that compliance becomes impossible.

So what if, instead of inventing new procedures, we focused on truly implementing the ones we already have?

Why don’t we start by understanding why we’re not able to follow our own procedures?

 A Parallel From Daily Life

We all know using a phone while driving is prohibited. It’s unsafe. Technology has even given us safer alternatives—Bluetooth, hands-free options, voice assistants. And yet, we still see people using their phones behind the wheel. I’m sure you do too.

So why does this happen?

Here’s my take: safety is about the management and improvement of human beings. No policy or procedure can fix that on its own. We have to work on ourselves—and on the society we’ve created, which often isn’t conducive to safety. Our behaviors, our pace of life, the pressure to produce everything yesterday, and the reality that so much still revolves around money… none of this supports a safety-conscious environment.

There is talk of achieving “zero accidents/incidents” by 2050. I don’t think it’s realistic. Why? Because we’re focusing on the wrong things. We need to focus on the people—and also accept that every aspect of life involves some degree of risk.

What Are Your Thoughts?

Why do you think we struggle to follow procedures?
How do we really embrace SMS?

Annalisa

Aviation Specialist - Aircraft Management