1. Rotorcraft Industry Seminar Rotorcraft Risks and Issues 7 September 2017
OFFICIAL SENSITIVE

2. John Clark Safety Programme Manager & PBRIG Chair Carl Christian
Principal Airworthiness Surveyor
Rotorcraft
Mark Swan to introduce these
Invite Mark Bailey to say a few words

3. Update on the Transformation to Performance-based Regulation
To transform the CAA into a Performance Based Regulator, working with industry to demonstrably reduce safety risk across the total aviation system and develop the capabilities required for future regulators.
Mark Swan to introduce these
Invite Mark Bailey to say a few words

4. Update on the Transformation to Performance-based Regulation
Compliance is a great starting point….but is not enough!
More rules will not necessarily increase safety but can:
Increase regulatory burden (cost and resources)
Apply generically (even where performance is excellent)
Performance Based Regulation (PBR) is a response to the challenge of delivering continuous improvement in aviation safety in the context of increased aviation activity and future safety trends
Mark Swan to introduce these
Invite Mark Bailey to say a few words

5. Update on the Transformation to Performance-based Regulation
Mark Swan to introduce these
Invite Mark Bailey to say a few words

6. Update on the Transformation to Performance-based Regulation
PBR System
Privileges
Air Operator Certificate
Entities
British Airways
Sectors
Large Airlines
Total System UK
Europe
Worldwide
Mark Swan to introduce these
Invite Mark Bailey to say a few words

7. Complexity Matrix Rating
Update on the Transformation to Performance-based Regulation
Red
Amber
Approval status Green 29 23 17 13 8 37
Complexity Matrix Rating
Annual audit 4 days (FOI, IO, GS & CS) Check R x 2 (FOI +CSI)
Check T 1 per fleet (FOI) Check F 1 per fleet (FOI)
Check M 2 days (FOI/IO) Check C x 2 (CSI)
SAG >4 (FOI/IO) Cabin safety SAG x2
Annual audit 4 days (FOI, IO, GS & CS)
Check T 1 per fleet (FOI) Check F, min 2 (FOI)
Check M 1 day (FOI/IO) Check C x 2 (CSI)
SAG x 2 (FOI/IO) Cabin safety SAG x2
Annual audit 3 days (FOI & IO)
Check T & F, 1 day each (FOI)
Check M 1 day (FOI/IO) SAG x 1 (FOI/IO)
Annual audit 2 days (FOI & IO)
Check M 1 day (FOI/IO)
SAG x 1 (FOI/IO)
Check M ½ day (FOI/IO)
1 day audit per 24 months. (IO)
1 flight check per 24 months (FOI)
½ day desktop (IO)
“Continual oversight”
Monthly meetings FOI’s x 3
AA = desktop
Mark Swan to introduce these
Invite Mark Bailey to say a few words

8. Update on the Transformation to Performance-based Regulation
Performance-Based oversight (PBO)
Single process for whole CAA
Evidence-based
Holistic safety performance assessment
Subjective
Oversight Manager and Sector Manager
Mark Swan to introduce these
Invite Mark Bailey to say a few words

9. Update on the Transformation to Performance-based Regulation
Performance-Based oversight process
Audits
Accountable Manager Meeting
Mark Swan to introduce these
Invite Mark Bailey to say a few words

11. Update on the Transformation to Performance-based Regulation
The Purpose of a CAA Regulatory SMS
The purpose of the CAA Regulatory SMS is to ensure that the safety risks to the UK consumer in the total aviation system are being managed effectively and to provide assurance to the CAA Board that plans are in place to address those risk that are not being managed effectively.
Mark Swan to introduce these
Invite Mark Bailey to say a few words

12. Update on the Transformation to Performance-based Regulation
How is it different to an Industry SMS?
An industry SMS will focus on managing safety risks in their operations
Our Regulatory SMS needs to understand:
what the major safety risks are in the Total Aviation System and,
whether or not the CAA has the capability or capacity to help the industry manage them, through:
Safety oversight
Safety Improvement Projects
Changing regulations we control
Influencing change to regulations we don’t control (EASA)
Policies and guidance material
Mark Swan to introduce these
Invite Mark Bailey to say a few words

13. Sector Safety Risk Assessment ambition, framework & development approach
What does the sector do?
What hazards does it face?
What’s its safety track record?
01 Sector Description
Nature of the operation.
Number of operators.
Regional / airspace info.
Operational volume / frequency.
Passenger, flight crew and third party exposure.
02 Sector Hazards
Summarise the sector’s top hazards.
Describe the main threat factors.
Describe the potential negative outcomes.
03 Control Effectiveness
Summarise the sector’s performance in managing the hazards.
Include safety performance metrics where possible?
What is being done?
How does this create safety risks?
What are the gaps?
06 Action Plans
Summarise the cross-sector action plans undertaken by industry to manage the risks.
Describe the Regulator’s action plans to treat, tolerate, transfer or terminate the risks.
Mark Swan to introduce these
Invite Mark Bailey to say a few words
05 Risk Assessment
Produce a sector risk assessment (aligned to the Total System risk scoring method) based on the exposure, hazard, performance and weakness information described in 01 – 04.
04 Weaknesses
Assess the potential weaknesses in the sector’s safety performance.
Provide supporting evidence where possible.

14. Rotorcraft Sector Description
Onshore
CAT
Police & HEMS
SAR Ops
NCC
SPO
Offshore
Mark Swan to introduce these
Invite Mark Bailey to say a few words

15. Risks at the Rotorcraft Sector level - Competency
Total CAA Findings
145.A.30(e) – 350 Level 2 findings
M.A.706(h) – 7 Level 2 findings
M.A.706(k) – 37 Level 2 findings
Mark Swan to introduce these
Invite Mark Bailey to say a few words
Improving Supervision & Production Planning
Implementing a Safety Culture& Ensuring Engineer Responsibility
A31
Improving the Effectiveness and Adoption of Procedures/Processes/Task Cards
Improving Competency Assessment / Training & Induction

16. Risks at the Rotorcraft Sector Level - Competency
No process or procedure
No competency assessment, lack of records
Unclear what personnel could do
Not all areas of activity assessed for competence
No HF, continuation training, procedures training or competence assessment
Growing scope of authorisation without competency assessment
Assessment on paper only
Not meeting the medical req’ts for E.g. NDT
Light touch training and assessment – for important tasks (VHM)
No follow up training – staff were not competent
Lack of training
Evidence of experience lacking or missing
Not everyone assessed for competence E.g. Managers
Improving Supervision & Production Planning
Implementing a Safety Culture& Ensuring Engineer Responsibility
Improving the Effectiveness and Adoption of Procedures/Processes/Task Cards
Improving Competency Assessment / Training & Induction
Mark Swan to introduce these
Invite Mark Bailey to say a few words

17. Risks at the Rotorcraft Sector level
- Part M sets up the Part 145 to fail
Poorly managed AMP
Poorly managed record system
Part M personnel competency and number
Part M oversight contracted maintenance
Part M oversight sub-contracted activities
Poor planning – unachievable workload
Owners/lessor – arranging own maintenance
Mark Swan to introduce these
Invite Mark Bailey to say a few words

18. Summary - Next Steps PBR in progress Entity level performance
PBO and RSMS
Entity level and sector level
Entity level performance
Sector level performance
A31 – data aligns to A31
Challenges
Align with Flt Ops
Keep valid and up to date
Deal with the issues –
Communication and actions
Mark Swan to introduce these
Invite Mark Bailey to say a few words

19. Thank you & Questions Mark Swan to introduce these
Invite Mark Bailey to say a few words