In aviation policy, “safety” Is the most sacrosanct term there is. Around the world, it is the prime directive for regulators, operators and maintainers, not to mention a prime concern for passengers.
Each of the “quadrilateral group” aviation authorities—the FAA, European Aviation Safety Agency, Transport Canada and ANAC Brazil—places “safety” first and foremost in its stated missions. Many aviation businesses have the word front and center in their propaganda and strategic statements. The administrator of the U.S. FAA’s duties, as defined in 14 USC §106, include carrying out the authority required to oversee aviation safety.
It’s pretty clear, then, that the target of everything done by industry or agency should be somehow connectible to improving or maintaining safety.
Take a simple example: By design, airworthiness directives (ADs) provide a fairly straight line between policy and safety. The U.S. rules for ADs (14 CFR Part 39), which the agency wrote as part of the government’s Plain Language Program, state that an AD is issued when an unsafe condition exists that is likely to exist or develop elsewhere. The resulting rule must include inspections, conditions, limitations and actions related to resolving the condition. (Of course, the lines might get squiggly sometimes in practice, but the purpose as defined in the rules is clear.)
Other policy issues can require more careful thought to connect to safety. For instance, an industry-wide coalition of aviation interests is working in Washington to create a program to stimulate the development of aviation maintenance talent. Finding and retaining skilled workers may not seem like it has a direct impact on safety, but it certainly remedies an “unsafe condition” in the form of pressure on an overburdened workforce. It also helps industry mitigate the risk of lost experience by building a pipeline of talent and diversifying its human resources.
In other situations, “safety” can be the last stand against a new development. In its ongoing effort to improve guidance related to remote connectivity, ARSA has had to ease the concerns of many doubters asserting that using such technology for oversight or instruction will have an adverse effect on safety. How could that be, if the equipment in use provides “adequate coverage, fidelity and integrity” of experience to accomplish the task the same as it would in-person-on-premises?
Questioning safety effects is a reasonable and necessary step in aviation policymaking. It must, however, lead to a critical assessment of the factors at play and the potential effects of the issue being considered. The dots have to connect.
If someone defends a policy priority based on an inferred or imagined impact on safety, they are on shaky ground. No matter what our goal—simplifying procedure, clarifying instruction, making various mandates consistent, re-thinking enforcement—the work of pursuing it has to consider its impact on the continued safe flight of an aircraft and safe operation of an airspace.
Brett Levanto is vice president of operations of Obadal, Filler, MacLeod & Klein. He provides strategic and logistical support for the Aeronautical Repair Station Association.