The Expert Interview: Managing Compliance

Gregg Brown, director of quality assurance at Southwest Airlines, talks to James Pozzi about the compliance side of the low-cost carrier’s operation and how the airline manages this in the face of changing regulation and standards.

For airlines functioning in the extremely safety-conscious world of commercial aviation, effective compliance is a vital component of any successful operation. When one of these carriers happens to be Southwest Airlines, among the world’s busiest in terms of passenger numbers and with a fleet just short of 700 inservice 737s, this is especially crucial. An airline industry juggernaut, Southwest has long been the benchmark for the world’s low-cost carriers (LCCs), remaining highly profitable despite operating in the very competitive North American market. But away from the balance sheets, its success also owes much to its adherence to the industry’s stringent regulatory standards.

The man tasked with ensuring its maintenance division follows compliance regulation while in the hangar is Gregg Brown, the Dallasbased carrier’s director of quality assurance. Overseeing a team of seven compliance professionals, Brown, whose career at the airline dates back more than 20 years in a number of technical roles, feels the compliance landscape has changed considerably in recent years. He pinpoints the period between 2008 and 2009 as a turning point, a time he felt spawned a “renewed focus” from airlines towards its regulators. This led to widespread changes to processes and compliance methods, which in turn, created challenges in itself.

“Change fatigue is something we’re constantly aware of and really trying not to inundate our technicians with over communication,” he says. In order to successfully adapt to the changing compliance landscape, Brown says
Southwest was proactive in its approach. “The major initiative we introduced was taking the time to step back and evaluate all of our processes, procedures and policy, instead of relying on tribal knowledge and memory to make
sure they were documented in a formal setting, which is our procedures manual,” he explains. “From there, we spent a lot of time working with the FAA, our regulator, and our certificate management office to ensure that our manuals
meet the expectations of the regulation and in some cases policy and guidance established by the FAA, the Air Transport Oversight System (ATOS) standards.”

Brown highlights Southwest going through an additional, similar exercise to that of ATOS when it acquired low-cost carrier AirTran in 2011. “As part of that merger process, the airlines had to reconcile differences between the manual systems and we chose to adopt a best of breed approach...We spent a lot of time evaluating the differences between our manuals and performing a risk assessment to ensure that the change wasn’t going to have unintended consequences. Developing a mitigation in the roll-out of those changes, whether that’s in training, equipment, additional resources or a form of communication, helps everyone understand the change and make sure it is implemented with as little unintended consequences as possible.“

Changing processes

In terms of technology, there have been few changes to the way in which compliance is met. One is that Southwest is increasingly relying on digital boards in the hangar and in the line maintenance environment. “These are essentially
large electronic monitors that constantly show information that we’re trying to put in front of our technicians, inspectors and material specialists.” Since their introduction around five years ago, Southwest’s digital boards have helped their technical staff keep updated in real time. “The boards show everything from company metrics to compliance initiatives and events that have occurred such as safety alerts,” says Brown. “That has been a great improvement over the old method of posting on bulletin boards. It’s really in front of technicians when they are at the control booths getting additional work cards and turnover.”

While technology used in compliance may not have evolved to any large degree, Brown feels the biggest changes have been on the process side of the compliance operation. “Around five years ago, we really made a concerted effort
to improve our continuing analysis surveillance system (CASS),” he says. “This involved Southwest taking a step back and looking at all the controls and procedures that exist within our system. After doing this, we then asked ourselves what surveillance either existed or needed to exist for us to understand if that procedure is producing its intended outcome — what process measurements can we put in place?”

Brown continues: “After that we started working on what is the best way to electronically capture that data in a manner that it can be analysed later so we began producing these paths. Today we have upwards of 20 inputs into
our CASS that provide information about how we are functioning. Some of that comes from the FAA in the form of letter of investigation or general surveillance letters, but the majority of it is produced internally from our audit teams and our internal evaluation process.”

Another area Southwest developed was its analysis portion once it had the data collection in place. “The analysis helps us to really slice and dice the data in a variety of different ways; to understand if a particular location is suffering, or if a particular procedure in the manual is suddenly not performing effectively or able to align with changes that may have occurred in the form of maybe a procedure revision...It helps us understand if that’s produced something that we didn’t envision,” says Brown. “This helps our CASS board develop corrective actions and then implement those actions and then we go into a loopback to the surveillance phase to assure ourselves we’ve corrected the problem.”

Southwest’s approach towards changing its CASS process has won admirers from regulatory boards and airlines alike. “The renewal of our CASS programme has been widely recognised as industry-leading. The FAA has sent people not on our certificate to look at our CASS as a recommendation and taken it back to their offices and
been very complimentary of what we’ve been able to achieve here. So we’re very proud of that.”

Relationship with the FAA

Complying with even basic FAA regulatory updates, such as the issuing of airworthiness directives (AD), can be a challenge in itself, Brown admits. “There’s always going to be challenges when the FAA is trying to write a regulation that can apply to all air carriers as we all operate so differently,” he says. “ADs are often very difficult to have a one size fits all language that works for everyone. One of the main challenges we have is recognising when our particular operation is unable to accomplish the requirements of that AD exactly as written and we have to work with the
FAA to pursue an alternative method of compliance. That takes constant vigilance and attention to ensure that we remain in compliance and it’s very taxing on our resources as well. To add to that, we have an AD compliance group within quality assurance consisting of 10 people and that is all they do 24/7 — ensuring compliance with airworthiness directives.

One FAA regulation predicted to have a major impact on the industry in the coming years is the introduction of a compulsory Safety Management System (SMS) for all US airlines from 2018. Despite being formally announced in
January 2015 with the ruling coming into effect two months later, the regulation had been long anticipated by carriers. Coming about after the February 2009 crash of Colgan Air flight 3407, which resulted in the death of 50 people, the ruling will see all US airlines and cargo carriers submit SMS plans within six months of the rule becoming effective in March, before implementing them within three years. Southwest is developing its plans through its safety teams in preparation for the submission deadline.

Brown says he strongly approves of the SMS programme, believing that a lot of its principle is evident in the already established CASS for technical operations. “The forthcoming SMS simply takes what the CASS has already done
and expands upon it for the entire air carrier,” he says. “It’s a great way to ensure the common issues that are occurring between different operating groups are addressed consistently as well and it gives the accountable executive the visibility he needs to ensure that the safety is never in question and that the compliance is
being carried out across the airline.” He adds: “The principle itself is not new but the formality and the structure around the programme is going to be new. There are obviously some requirements for record keeping that are hitting everyone and of course every air carrier’s programme is going to be a little bit different but the general principles involved with it are really not new to most.”

The human factor

When advising on successful compliance management, Brown believes the key fundamental element lies in the people executing the process on a daily basis. “Compliance doesn’t lie in the hands of quality assurance or management, it lies in the hands of the people who are turning the wrenches,” he says. “The key isreally educating staff on why a standard exists and why is it important that they follow this particular regulation. If someone understands why they are doing something, they are infinitely more likely to follow that than if they don’t. There are a number of regulations, policies and procedures that exist that quite frankly we have not educated people enough on and therefore they don’t really understand the importance...I’ve never had a conversation with someone where I’ve been able to give them the background to why we are held to a particular standard where they didn’t finally understand and walk out with a completely different attitude…My objective is to have a smaller quality assurance group in the hope that we just don’t need a larger one and that would be because everyone understands compliance, its importance and how it contributes to safety.”

Brown notes that the vast majority of compliance failures are brought about by human factors. “Many of those failures occur when an employee puts an undue burden on themselves to get something done on time,” he explains. He
places Southwest’s priorities in order and importance, and says the airline’s culture is to reiterate these points. “We have stated our operational priorities many times and it’s a matter of just reiterating constantly that safety comes first, compliance second, and customer needs third in terms of passenger convenience, and then on-time performance comes last,” he says. “We truly believe that doing the job right from a safety perspective is always going to take precedent and in all of my years in the industry, I’ve never seen anyone disciplined for doing the right thing.”

Managing voluntary compliance for client standards, a programme which allows a technician to be immune from disciplinary action if they come forward with a legitimate filing of a maintenance violation, differs from one used by Southwest to manage its legislative standards. Brown says one area Southwest garners a lot of information from is its aviation safety action partnership, a three-way agreement between the airline, the labour group of mechanics, inspectors and material specialists and the FAA. “The identified information makes us suffer; it contributes to a higher level of safety and compliance if we are able to get information directly from the people seeing concerns first
hand,” he says. “When those do come to our attention, or if someone reports non-compliance internally to the leadership, that does come to the quality assurance group and our regulatory affairs and investigations group. We will quickly determine if non-compliance exists and if it qualifies for disclosure to the FAA. There’s also an advisory circular that determines what information does and doesn’t qualify. We have a very high level of transparency with our certificate management office and we are able to work with them through pretty much any issue.”

Brown says among the most common mistakes in compliance are what he describes as departments “stopping at the first sign of the smoking gun”. “When they feel like they understand exactly what happened, they quit looking,”
he says. “They try to fix just that problem and it’s really akin to a band aid, and it’s a problem they are destined to relive again if it isn’t addressed properly.” Brown concludes that working closely and constructively with a regulator, like Southwest does with the FAA, is of great importance. “The FAA is open to working with you through pretty much anything that can occur, but the one thing there’s not much appetite for at the FAA is companies reliving something on a repetitive basis.”

With more than two decades of experience at Southwest, Brown’s says the advice he’d impart to new compliance managers is simple: focus on the root cause of a problem. “The root cause needs to be investigated as deeply as needed to establish what the problem is, but people shouldn’t stop there,” he explains. “Look for contributing
factors. Try and identify in the course of an investigation if there are additional hazards that haven’t been addressed. If you can do those things then you really set your company up for continuous improvement and reduced noncompliance in the future.”

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