Plane Conversations

Chris Davis is an aviation insurance specialist and Manager of the Light Aircraft Division at CS&A Aviation Insurance. He is passionate about aviation and active in the Experimental Aircraft Association where he currently serves as the Secretary / Treasurer as well as the Newsletter Editor for Chapter 863. He is also active in the Warbirds of America as well as holding the rank of Colonel in the Commemorative Air Force.  His lifelong passion for aviation and various experiences give him an advantage in an industry where aviation safety and risk management are the focus.

We love to hear stories from other aviation enthusiasts and professionals, so here is a blog Chris wrote from the blogsite www.clearontop.com.  

Planes, Training and $100 Pancakes by Chris Davis.

BEEP, BEEP, BEEP, BEEP! The alarm sounds so much louder at 05:30 on a Saturday morning than it does during the week, but what a sweet sound it makes. Today is the 3rd Saturday of the month and that means pancakes for breakfast. I ease out of bed, get dressed, kiss my wife goodbye and head to my sons room. Jacob is only 2 ½ , but he loves pancakes almost as much as he loves to fly…combine the 2 elements and it will wake him up faster than a double shot of espresso.

  The sun begins to rise over the hills as we arrive at the airport to drag our steed from it’s hangar. We begin our walk around and the chilly morning air sends a little shiver through my body. Prop; check…Tires; check…Leading Edge; check…Fuel; clean and free of water…Control surfaces; free and correct. My dutiful co-pilot follows my every move, double checking each item on the pre-flight walk around. He faithfully asks the inevitable question at every item we check. Daddy, why? With all items satisfactory we enter the aircraft and strap in. Master switch: ON…Mixture: FULL…Boost pump: ON…as I lean my head out the window to check for prop clearance my co-pilot beats me to the punch “Keer Pop” he yells, with a grin so big his headset falls down around his chin. As the Maule breaks the morning silence, we turn on the avionics and enter 3M5 into the GPS. “Let’s go to Moontown and get some pancakes daddy!” I wiggle the rudder a bit to lock in the tailwheel and we begin our journey.

Our trip to breakfast usually takes about an hour and (thanks to my co-pilot) is filled with many steep turns, stalls, and floaters…the floaters are Jacobs favorite since he gets to be weightless for a few seconds. Often times we will join up with a few buddies for our breakfast journey and we use the trip to brush up on our formation flying maneuvers. All too quickly we make it to Moontown and enter the increasingly busy pattern to land. After demonstrating the proper soft field landing techniques to Jacob we taxi off the active runway and proceed to park. Breakfast seems to hit just the right spot as we sit around the picnic table and play “name that plane”. I talk shop with other pilots as Jacob finishes his second round of pancakes and then we proceed to walk down the growing flight line for some more hands on education.

Hidden amidst the tailwheels, trikes, amphibs and warbirds are a multitude of questions just waiting to be answered. Daddy, what kind of airplane is that? Why? What is the little wheel on the back for? Why? What makes it fly? Why? Why does it have two wings instead of one? I answer the questions one by one, often repeating the same question multiple times. Upon reaching the end of the current flight line we sit in the shade of an old Stearmans wings and watch the new arrivals as they land. How appropriate that we rest beneath an old trainer as I teach a future pilot.

The phone rings…a call from my wife signals that our kitchen pass will soon expire. The time has come for the men of the house to return home, the ladies have made plans for our afternoon. On the return flight my co-pilot reaches his duty limit…eyes closed and leaning against the window, his headset slowly begins to slide down. It is a quiet trip back to the hangar. This has been a fun trip and a very educational one for both of us…only 4 more weeks until we get to do it again.

Often times I hear light aircraft pilots complain about their insurance company requiring completion of an annual Flight Review or X number of dual hours prior to solo in a new aircraft. Just like my son, I have to ask why? Why are pilots complaining about having an excuse to fly? Many of the pilots who complain about the training requirements are the same ones that I will see at a pancake breakfast or local fly in. If I was a CFI and Jacob was older, he could receive his flight review endorsement each time we head out for pancakes provided we follow a few simple guidelines.

FAR 61.56 states: a flight review consists of a minimum of 1 hour of flight training and 1 hour of ground training. The review must include: (1) A review of the current general operating and flight rules of Part 91; and (2) A review of those maneuvers and procedures that, at the discretion of the person giving the review, are necessary for the pilot to demonstrate the safe exercise of the privileges of the pilot certificate.

Get a little creative. Find a local CFI and offer to pay his way to a fly-in breakfast in exchange for a flight review. Combine free breakfast with free flight time and most any pilot will jump at the chance.   If a fly-in is not your thing, consider getting some tailwheel training or some formal formation training. Both of these areas will greatly improve your situational awareness as well as hone your flying skills. You will learn to anticipate and lead the aircraft to where you want it to go instead of directing its actions as you ride along. Tailwheel training will improve your precision on landings as well as focus your attention during ground handling. Formation training will teach you to plan ahead and to fly very smooth and precise as well as teach you how to pay close attention to detail.

No matter what form of training you choose, it is only as good as the effort that you put into it. Why continue to dread the flight reviews and proficiency checks only to forget what you learned before your next flight? Make the training something to look forward to…plan your next flight review around an upcoming event and enjoy the training. I guarantee you will get much more out of it and you will find yourself looking for more excuses to train.

Every time I take Jacob flying he is learning and asking why. In some ways he is my best little instructor. He reminds me that I should always be asking “why?” as I too am still learning to fly.

Clear skies and tailwinds!

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We recently posted an article on the new pilot duty rules that will address pilot fatigue issues. Hopefully, the Obama administration will take the politics out of it and focus purely on safety. That remains to be seen as they have involved the Presidents Office of Management and Budgeting in the process which, in my opinion, should be left up to the safety and flight operations experts in the industry and the FAA.  

I asked our Director of Fight Operations, Dwayne McMurry, to weigh in on the subject. He has been a pilot operating under Far 135 (Air Charter Rules) for 25 plus years and has served in a management capacity for FAR 135 operations with our company for close to 20 years. Dwayne holds an ATP with 8000 plus flight hours and type ratings in Learjet, Lear 45, Cessna 650 and 525, and Beechcraft BE300.  He continues to fly as a Captain and manages the flight operations for our company; so, he has perspective from both management and pilot viewpoints.

Here are Dwayne’s thoughts about the issue of duty time and pilot fatigue:

For the most part, regulations today only regulate what a flight crewmember does while on duty.  Rules for drug and alcohol use are in place regulating one’s actions outside of a duty period; so, they ultimately affect the periods during company duty assignments.  To my knowledge, there is no pre departure test that can be administered that indicates the level of rest a pilot has received.  

No set of regulations will ever eliminate fatigue in the cockpit.  Mitigation of fatigue starts with the pilot.  This should be complemented by a set of reasonable regulations.   A pilot should be professional and understand that he/she must present themselves well-rested, ready and able to perform all duties associated with fight, in both mind and body.  Does this mean commuting across the nation within 24 hours of a flight should be prohibited?   Maybe; maybe not.  What is the difference between commuting across the country, then reporting to work, or returning home on a flight across the country from a vacation and reporting to work the next morning for a flight?  It’s not about the commute.  It’s about the rest needed before flight. 

Then the big question becomes: what is rest?  Time away from the job is not necessarily rest.  I’ve heard more than one person say they had to come back to work after a vacation in order to get some rest.

Commuting … There are several stresses involved when a pilot commutes to work.  The pilots that commute know all too well that the airlines they fly are sometimes unreliable.  They are often late, sometimes flights are canceled, and, quite frequently, they are full or overbooked.  A pilot riding Space Available is typically placed in a state of stress hours if not days before ever reporting to work.   What time do I have to leave to catch a flight in order to make it to work and how soon before I have to fly will I arrive?  Can I get on a particular flight; will it be on time?  What if I can’t get on the flight; is there an alternate flight I can take?  What do I do if all my plans fail?  These are all questions that may go through the mind of a commuting pilot.  Needless to say, if he doesn’t make it to work, his job may be on the line.  A pilot may leave early enough, even a day before he/she is scheduled to fly, but by doing so could bring on stress because of the added burden placed on him/her by their spouse because they aren’t home.  It all adds up. And may I add that this will only get more stressful as airline load factors rise with the reduction in capacity of the system. When load factors exceed 80% the reliability of getting to work on your own airline is going to become increasingly risky.

The crutches we lean on ….I’ve heard several comments lately from other flight crewmembers as to how they combat fatigue.  Snacking, energy drinks, coffee, naps haveall been suggested to combat fatigue during a flight or a series of flights.  These really don’t combat fatigue; they simply mask it.  Before the flight, plenty of rest and nutritious food seem to be a reasonable preventative measure for fatigue.  Another crutch seldom mentioned is technology.  In today’s modern aircraft, the technology we have at our disposal relieves the fatigue of having to hand fly the aircraft, shoot instrument approaches, calculate performance, diagnose and solve system malfunctions.  We have more information at our disposal in the way of weather reporting, airport information, communications and automated aircraft systems monitoring than ever before.  When used properly, it all reduces fatigue during flight. 

Some of the things CFM does to mitigate fatigue ….We require our pilots to live within 45 minutes of the airport.  Fatigue from commuting is not an issue with us.  We fly 99% of all our operations with two crewmembers.  This reduces the workload associated with a flight, thus reducing fatigue.  We plan all our trips to begin and end within a 14-hour period.  We are realistic in our scheduling.  We consider that a pilot who has been on duty from 10 pm to 6 am may not be rested and ready to report for duty at 4pm that day even though he/she is legal to do so.  We provide day rooms for our crews during long days.  We provide a full staff of personnel including maintenance, dispatch and management, which are available to the pilot anytime to assist in the decision making process.  We are aware that major life changes such as the birth of a child have an effect on a crewmember’s performance,;so, we try to be flexible when it comes to these events with time off.  Ultimately, we give the pilot the final say in determining whether he/she is rested and ready to fly, even when the regulations say they are legal to fly. 

I appreciate Dwayne’s input from a professional pilot and flight department manager’s perspective.  

As I have stated in previous posts, I am a free market capitalist and believe the government needs to stay out of the way in most areas of business such as legislating whether you can charge for carry on bags. That is a market issue that needs to be left up to the airlines and their customers. Nobody gets hurt if Spirit Airlines charges a fee for carry on baggage.  However, when it comes to regulations of our industry that center on safety, the government needs to provide well thought out regulations that are evenly enforced across the industry. We are operating on a 60-year-old set of rules that are vague in their wording and no longer adequately address safety and the issue of pilot fatigue. The technology and capabilities of today’s aircraft and the air transportation system make this a new day and the new day needs a new and better set of rules. The pilots and traveling public deserve no less.   

What do you have to say about this?

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On January 25, Dan Robles suggested that Social Currency might be used to fight terrorism. Some of our friends on Linkedin joined the conversation. 

Greg Johnson, President, CEO and founder of OneSky Jets, says:

“I think there are a few interesting points of discussion in Dan’s latest post. The first relates to where we catch terrorists… Trying to stop them at the airport checkpoint is an effort in futility. Terrorists are a determined lot and as Dan states, they only have to succeed once. The answer lies in knowing more about everyone who elects to fly as personally invasive as that may sound.

The U.S. and other countries are already starting to collect more data from passengers…birthdate and place of birth in addition to name, even on domestic flights. There has been an ongoing debate about a federal ID card although my opinion is that an additional card would be redundant. The databases exist today to to give law enforcement a pretty decent ability to profile passengers and I only see that capability expanding.

The typical terrorist’s desire to keep a low profile works against them when they are attempting to blend in to an increasingly data-driven society. The absence of data or abnormal patterns will stand out.

I don’t believe that “social currency” on its own is enough. There are billions of peaceful people on the planet that are not actively engaged in social networking today. The fact that my Mother isn’t on Facebook, LinkedIn, or MySpace shouldn’t (on its own) subject her to an additional level of security screening, however a college student today without an online presence might throw a red flag or two.

Also, don’t think that law enforcement isn’t already leveraging social networks. I have an associate who has been involved in government facial recognition projects. When the government needed a database of names and photos to test this new technology, where do you think they went? The publicly available pages of Facebook!

So the net/net here in my opinion is that the publicly available data in social networks can and will be used by governments of the world as one facet in a multi-dimensional campaign to know who is flying before they get anywhere near the airport and in the big picture, that’s a good thing.”

Mike Osborne, Operations AME at Honeywell, shares this concern:

“How do you propose to ascertain their networks and claims? Either or both seem easy enough to falsify.”

My reply is:

“I believe that the idea is to go for a “preponderance of evidence.” Just as the lack of a credit report, utility bills or bank records casts doubt on the authenticity of an identity, the lack of social credit and social activity history casts doubt on the social interaction and perhaps even identity of the passenger. Certainly, just as false credit reports, etc. can be created to support an alias, false social backgrounds could be created to support it as well. I think the point that Dan Robles is making is that to create monetary history and social history that coincide is difficult and would make it more difficult for terrorists to support several believeable aliases.”

Kenneth J. Goldstein, President at KJG International Consulting, responds:

“No as left to their own devices, most would not provide a sufficient background to grant the rest of us security.”

What do you think?

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As the CEO of a Part 135 / 91 aircraft charter and management company, I can not proclaim to be an expert on SMS. There are people in our industry a lot smarter on the subject than I am because they have taken the time and energy to study, learn, listen, share knowledge, and attempt to develop systems that incorporate the best practices of the collective knowledge of our industry.

What I can proclaim is that Safety is critical to our company. The fact is that Safety is the most critical issue we face. We cannot afford to do anything that does not allow us to operate at the highest level of safety. The group of people I have worked with over the years will tell you that I support them in operating at that level. I have often said, and I truly mean it when I say it, that if we cannot make a profit and operate at the highest level of safety, then I will get out of this business and do something else to make a living.

So, I have taken the time to listen and learn SMS and, as a company, we have invested money developing the processes and taking the time to put a true SMS in place – and, more importantly, to actually use the system. 

Our industry and the consumers that use us have not always rewarded those who adhere to the highest level of safety. Some users of our services have either assumed that the FAA keeps our industry “safe enough” or they just don’t care, concerning themselves only with price.

Safety Requires Thought and Time Investment! Safety Costs Money!

The debate has gotten heated over the requirement to have a Safety Management System in place, even in operations that do not hold themselves out for hire. The NBAA Avmgr Forum has hundreds of emails over the past few weeks from flight department managers and consultants to the industry on the subject of SMS.  

There are two sides to the debate and some merit exists even on the side that I do not sit on.

Here are comments from the side that says we don’t need SMS in our world of flying aircraft:

• Common sense, good, real training and operational policies that make sense (not policies on what to do when the pencil holder fails) are what we need to improve safety.
• I have only been flying for 38 years and never needed a SMS manual to be safe. It might be a useful tool for larger operations but for a 2-5 pilot ops is simply a waste of time, money and trees.
• Having me write a SMS manual for my three pilot one aircraft operation is a waste of my time, but reviewing a good document on aviation safety and best practices could be a good read on occasion.  Such an approach could generate discussion among pilots, promoting teamwork and better understanding of safe decision making…  The bureaucratic approach to safety will yield lots of paper documents but I suspect it will do little to actually advance safe operations.

 And from the pro-SMS side: 

• Many in our industry are making IS-BAO a lot more complex than it needs to be. The discipline of having an outside perspective (auditor) is a generally accepted business practice.  It is designed to give you credibility as a leader, not talk behind your back.  ”Because I said so….” Is not an effective tool.  We do this in the cockpit and call it CRM, line checks, etc.  Why not with our overall operations?
• Yes, common sense is king. Commons sense is missing from allot [sic]of issues, in and out of aviation. Sure, he who flies with the most paper is not the winner. But neither is he who flies with the least paper the most competent and safe. It all requires balancing common sense, necessity, need and what really works.
• The concept of risk identification and mitigation is embraced in many industries…. We often like to think we are ahead of the pact[sic], but the reality is most of the world has left us (Aviation) in the dust when it comes to codification of best practices and risk mitigation.

From Dwayne McMurry, our Director of Operations, with whom I have worked side by side for over 20 years, the following observation:

 “If I were the owner of an operation that had a flight department with 2 or 3 pilots, I would suggest that the Chief Pilot is not guaranteed to be at my company forever and the airplane, pilots and flight department as a whole would most likely survive him/her.  I would certainly want an Operations Manual or SOP of some type and a Safety Management System in place to pass down established policy, procedure and history of my flight department to the next pilot(s) for the future of my flight department.

Sometimes pilots and flight department managers forget they work for somebody and feel they only have to answer to themselves.  If you wrote the check for the plane and fly it yourself, that’s one thing.  When someone hires you to do a job … most likely, some day, for some reason, someone will replace you and a legacy should be passed on.  What better way to do it?”

This is a complex debate that cannot be fully covered in one blog post or article. What I will say is this: that I would not want our company to operate on pure common sense alone and would also not want to operate strictly from the manual without common sense. What about a combination of good common sense and experience combined with a system that establishes processes, procedures and ways to measure safety? Could it be that we need both?!

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PBS  Frontline’s Documentary investigates the crash of the Colgan Air Dash 8-Q400 flight number 3407. 

http://www.pbs.org/wgbh/pages/frontline/flyingcheap/view/?utm_campaign=viewpage&utm_medium=toparea&utm_source=toparea

Reporter Miles O’Brien is a pilot and 20 year veteran of reporting on aviation issues.  He gives this story the time and depth it deserves, covering an issue that has long been brewing about the regional airlines hiring and training practices, as well as their dismal pay scales, all driven by the demand to offer seats at the lowest possible price.

No one in the airline industry or the private aviation side of air travel sets out at the beginning of each day making decisions that they believe will lead to a fatal crash of one of their aircraft.  So how does it happen, and what part can the NTSB, FAA, DOT and the industry play in doing everything possible to prevent it from happening again?

When is the consumer educated to the point they realize that the airlines cannot deliver increased safety at lower costs?  Safety costs money!

This story is worth an hour of your time to gain a better understanding of the issues our air transportation system faces with the economics of safety.

In a world where mainstream media sensationalizes everything and looks for the one minute stories to feed us in sound bites, the guys who have produced this have created a story that will, or at least should, make a difference.

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A  February 1 article by A. Pawlowski of CNN titled “How old is the plane you’re flying on?” says the following: “Few people expect luxury while flying, but these days, even the basics seem to be in bad shape. It’s not uncommon to find your tray table broken, the in-flight entertainment system not working and your seat cushion worn — all of which can make you think, how old is this plane anyway?”

“But for now, the reality for many U.S. air travelers is that most of their journeys take place on planes that have been in service for a decade or more and show it, though in ways that have no impact on their safety – like worn interiors, broken creature comforts and less than spotless conditions.”

Sounds more like riding on the metro rail than flying on an aircraft. Maybe that is what the experience ends up being in the future? Mass transit by Air! 

The average age of the fleet of the seven large U.S. passenger airlines – including American, Alaska, Continental, the merged Delta and Northwest, Southwest, United and US Airways – is about 14 years old, according to The Airline Monitor. It found American and Delta/Northwest had the oldest fleets, at about 16 years on average. As of the end of 2008, a small percentage of the merged Delta/Northwest’s planes dated back to the late 1960s.

U.S. fleets are among the oldest in the world, said Richard Aboulafia, an aviation analyst at the Teal Group in Fairfax, Virginia.

So all of this begs the question about safety and are these aircraft still safe?

Most everyone will agree, as do the experts quoted in the article, that the fleet of airline aircraft in the United States are maintained to the highest standards in the world and that they are safe. The safety record of US airlines have continued to improve each decade due to good maintenance, technology upgrades in the cockpit and better training of pilots and maintenance personnel.

I have no fear of getting on a 16-year-old aircraft operated by a major air carrier in this country and no worry about arriving safely. The professionals who fly and maintain these aircraft are the best in the world, in spite of the bad press of a very few isolated incidents where the pilots are “working on their laptops” and forget where they are.

The Airline Industry is Safe! But what about the experience?

Is the traveling public going to resign themselves to the idea that all they can expect is to safely arrive? That’s all you expect when you hop on the metro rail in any major city.

There is an alternative for the traveler - it’s called private aviation or business aviation and it’s anything but the same old experience!

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(Author’s note: The following is meant to engage new ideas rather than promote any specific scheme or ideology)

Given the events of the last few months weeks, it’s time to for the aviation industry to get serious with Social Media. This article demonstrates how an alternate currency can be used to severely reduce or eliminate terrorist risk in commercial aviation. Think I’m kidding, read on.

Obviously an airline will not let you board an airplane if you don’t have the financial currency sufficient to buy ticket. Why should an airline let you board an airplane if you do not have social currency sufficient to fulfill your social obligations while in the air?

People with extreme social currency deficiencies are routinely stripped of their rights by a jury of peers and isolated from society for a period of time (where they would not board an airplane anyway). While there are many systems in place to manage the various degrees of social currency deficiency, none appear to be able to identify a terrorist without also violating the rights of non-terrorists.

Human Writes

However, many people are willing to share information about themselves to associates with whom an economic benefit is shared or exchanged. This happens a billion times per week on Linkedin, Facebook, and Twitter – why not among fellow passengers? After all everyone is already connected by six degrees.

What would a terrorist’s Facebook profile say about them? Do they have a lot of referrals on Linkedin? Do they post great work on Flikr? Is their community orchestra featured on My Space? Are their posts popular on twitter?

Should a social currency credit score become imperative to social transactions as the financial credit score is for financial transactions?

Banks and Insurance companies already rely on a highly invasive “Credit Score” to establish financial risk profile as a means of protecting themselves and their other clients. Why wouldn’t an airline use a social credit score to establish a social risk profile as a means of protecting themselves and the lives of their other clients?

Ruse and lose

Sure, the bad guys can adapt to social media as they have adapted to all other measures. The problem is that the greater the size and scope of their social media ruse, the more difficult it is to maintain the ruse. A threshold score could be set to nearly eliminate this possibility. Those folks can then simply opt into the full body scan.

The Paradigm Shift

As the saying goes, the attacker needs to be successful only once, while the defender needs to be successful every time. The concept of a Social media credit score flips this paradigm on it’s head. The attacker’s social credit score needs to be successful every time. The defender needs to be successful only once.

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 Part 2 in a Series on Safety Management Systems for Business Aviation Operators

In a previous post on this subject, I suggested that Safety Management Systems (SMS) are good for business aircraft operators. I believe that business aviation as an industry does have a prevailing culture promoting safety but that having systems in place to document and measure safety takes it to the next level. I also suggested that one of the problems with the implementation of an SMS is the lack of consistent interpretation and enforcement by the worldwide governmental aviation regulatory agencies. If the International Standard for Business Aviation Operations (IS-BAO) is the standard that adopts the best practices to promote safety, as suggested by Aviation Research Group US (ARGUS) and the National Business Aviation Association (NBAA), then let’s embrace it.  

Further thoughts on this subject related to the adoption of safety management systems by operators, both aircraft charter (commercial) and business aviation  (company flight departments):

Buying an SMS manual from a consultant and putting it on the shelf to collect dust does nothing to further safety in any operation. All flight departments, no matter how small or large, can learn from documenting problems and analyzing them to identify their root causes. It doesn’t have to be an accident or major event to reveal hidden risks. Those who understand workers compensation insurance risks know that frequency of small events can be an indicator of an increased risk for a big event. How many times does a guy have to slip and fall on a slippery floor before he sustains a major debilitating injury? Can it be prevented by analyzing the minor incidents for cause and fixing the slippery floor before the major event happens? You bet  it can!

In a small operation without a lot of daily flight activity, the issues requiring documentation and analysis may be few and far between. In a large operation with a lot of varying activity both on the ground and in the air, the small issues happen more frequently.  Trends and risk concerns will become more apparent as these events are put into the system.

A good SMS also involves the senior management of the company whether that person is the head of an aircraft charter company or the CEO of a non-aviation company that owns a corporate aircraft. In our company’s case, I meet with our Director of Safety monthly for a briefing on all activities and concerns that have arisen since our last meeting. We also discuss causes and make decisions on changes in our operations to prevent future incidents. Our Director of Safety has direct access to me anytime without any fear of reprisal from other management. Senior Management must be bought into the idea and fully support it. 

Establishing a well thought-out SMS is music to the ears of the insurance underwriters. I believe that, over time, they will offer better rates to the insured risks (the operator) who have a good SMS in place. Some already do take this into consideration at annual renewal.  

Overall, our industry has an excellent safety record. It was better in 2009 than it was in 2008.  It improves with better aircraft, better training, and better systems for managing flight operations. The old saying that “if it ain’t broke, don’t fix it” does not work for us. By the time you find out it is broken it may be too late to fix and the cost of being too late is simply too high.

Bottom line: Maintaining the highest levels of safety by putting into place the best business practices on safety management is good for our clients, our jobs, our businesss and our economy.  

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Part 1 in a Series on Safety Management Systems for Business Aviation Operators

There has been a lot of discussion among business aviation operators and support organizations about Safety Management Systems. Much of the discussion laments the additional regulatory requirements that are coming down the pike for already highly regulated business aircraft operators. The question being asked is: do more regulations and formal safety management system requirements make an operation safer?

Many posit that there is already a strong safety culture among operators of business aircraft and requiring a manual system to formalize the culture of safety adds no value and only creates expense and more work.

A recent article in AIN Online by Chad Trautvetter says the following:

ARG/US Endorses IS-BAO as Charter Audit Standard
Aviation Research Group/US (ARG/US) is endorsing the International Standard for Business Aircraft Operations (IS-BAO) as the one standard that all operators of business jets around the world would be measured by and audited against. According to ARG/US CEO Joe Moeggenberg, The charter community has endured multiple standards and audits for many years, translating into significant time and expense. With one universally accepted standard, the burden of time and money would be reduced and charter customers would be provided with one standard of safety assurance covering all operators. He said that if the industry does not take this opportunity to make IS-BAO along with its safety management system (SMS) component the world standard, then each governmental aviation body could offer myriad alternatives or options for demonstrating SMS compliance. Under ICAO requirements, an SMS will be required for all operators of jet aircraft with an mtow of more than 12,500 pounds by November 10 next year. ICAO, IBAC, NBAA and its sister organizations are all behind IS-BAO, and some countries have already recognized IS-BAO as a means of compliance for various registration or operational related requirements such as SMS. ARG/US said it has modified the standards contained in its Platinum audit to be consistent with IS-BAO.

Over the years our business has seen an increasing burden of compliance with FAA regulatory requirements. It would be easy to become frustrated with this burden and to conclude that more regulation only leads to increased paperwork and the increased human resource costs that go along with it - all without any real benefit. I can understand how operators can think in this direction.

However I will say this: It has come increasingly clear to me that the problem may not be the regulations and requirements for implementation of SMS, but the lack of consistent interpretation and enforcement. Ask more than two FAA officials or industry audit groups to tell you how to comply with a regulation or required program and you will get as many differing answers as the number of experts you ask.  If Joe Moeggenberg’s statements are correct and IS-BAO could be the one standard by which all safety systems are measured, then I am for it.

It would be great if the FAA and its counterparts around the world could agree to standard safety practices and a uniform system of measuring and documenting that safety standard.  Let’s not look at the rest of the world, it would be great if United States governmental organizations could agree amongst themselves! Most days we can’t even get the FAA to agree with itself over the standard. What should be standardized and produce a standard level of safety among all charter operators is not working. The Department of Defense (DoD) recognized this over 20 years ago and created their own audit teams to inspect airlines and charter operators interested in flying DoD personnel. Being FAA certified was not good enough for the DoD because they recognized that two operators certified under the same rules could have vastly different standards when it comes to safe operations!

The lack of agreement between the powers that regulate business and commercial aviation both in the US and around the world does not serve as an excuse for everyone who operates business jet aircraft to operate at less than the highest level of safety. As frustrating as it is, the need is there to have a Safety Management System for operators of business aircraft in our industry. Everyone has an opinion about what constitutes safe operational practices and not all opinions are created equal. Operating at the highest level of safety by employing “best practices” can bring only good to all the stakeholders in our industry.

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Part 1: Degrees of Safety

Forbes.com in a recent article says that there are 2400 US aircraft charter operators to choose from - almost double the number from ten years ago and most of them are small operators with one or two aircraft.  With all these choices and no one-stop resource like Expedia to use, how do you choose the best service provider?

The assumption is that all operators are all safe; so, it comes down to the matter of price, service, and aircraft type to best fit the mission.

Let’s focus in this conversation on the safety aspect.  Having been in this business now for 27 years, I can tell you that the playing field in the area of safety is not totally level.  There are different levels of “safe.”  While I believe that, by in large, our industry provides a high level of safe transportation, I also know from experience that all charter operators do not operate at the same level of safety.

Safety costs money so cheaper is not always better.

The Federal Aviation Administration (FAA) is tasked with keeping our industry safe – from the largest airline to the smallest single engine charter operator.  They are arguably the best (and for sure the biggest) aviation oversight and regulatory agency in the world.  Other governments from around the world send their aviation counterparts to the FAA here in the US to receive training and to learn how we do it.  With the exception of the European Union and its FAA counterpart – EASA – there is no other aviation regulatory agency in the world that can compare to the FAA.

That being said, our FAA is understaffed and overburdened with their own bureaucracy of moving paperwork around (these days I guess it is more like moving electronic files around) and thus does not have the manpower to adequately oversee all of the 2400 charter operators out there across this vast country.  Even though their system for developing regulations and providing oversight is good, it is anything but perfect.  There is a human element to regulatory oversight and when that is injected into a system that is understaffed and overburdened you arrive at a situation where charter operators are not all held to the same standards.  The FAA has made a valiant attempt at making the safety oversight processes as objective as possible, but it still comes down to the day-to-day workload grinds for the inspectors, differences of opinion on how to interpret the rule book (Federal Aviation Regulations) and levels of experience and training between inspectors.

I hope I haven’t scared you off yet.  If it makes you feel any better the same situation doesn’t exist just at the level of charter operators.  It runs all the way to the level of the biggest airlines in the country.  OK, that didn’t make you feel any better so let me say a few things that will.

In today’s world of information availability, you have many sources that are only mouse click away from educating you further about the safety of charter operators.

Let me give you a few to start with:

The NBAA (National Business Aviation Association) has an excellent site and the link below gets you to a page that gives you a list of  screening questions to ask when choosing a charter operator: http://www.nbaa.org/admin/options/charter/pre-screening.php

Additionally, there are industry independent audit companies who audit charter operators and have ratings based on how the operator scores on safety records and systems, training, and experience. The best two that I know of are Aviation Research Group US (ARG/US) and Wyvern.  Both have been around for a long time and are used by Fortune 500 companies to vet charter services who supplement the company’s own internal flight departments.

There is more to say about safety and picking a good charter service provider.  Join us on Monday for further discussion.

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