ML19312C972

Safety Role of Regulatory,Corporate & Personal Initiatives in the 1980s

ML19312C972
Person / Time
Site:	Crane
Issue date:	06/19/1979
From:	Bruggink G NATIONAL TRANSPORTATION SAFETY BOARD
To:
References
TASK-TF, TASK-TMR NUDOCS 8001170601
Download: ML19312C972 (7)

Text

_

-~

The Safety Role of Regulatory, Corporate,

~

And Personal Initiatives in the 1980's.

by Gerard M.

Bruggink National Transpor tation Sa fei, Board I have to start this discussion with two caveats.

First, as a result of my work experience over the past 27 years I am better acquainted with the reasons for f ailure than the elements of success in aviation.

Therefore, my outlook is one-sided and probably too skeptical.

Secondly, the views I express do not necessarily reflect those of my employer, the National Transportation Safety Board.

To illustrate what kind of hat I am wearing - or not wearing -

I should probably start with the statement that I am in full agree-ment with Rapoport's theory that there is "a residual level of ac-cidents whose causes are deep within us as individuals and as a civilization."

I realize that this utterance is contrary to the career enhancement of those whose job security lies in the notion that we have the technology to create a risk-free society.

However, I have never been able to preach what I can not believe in.

In the meantime, I appreciate the opportunity to address this I

GAO Transportation Symposium.

Ever. if I cannot make a measurable

~

contribution, I hope to encourage new perspectives by raising serious f

doubts about some of our traditional and institutionalized safety j

concepts.

The Record From the regulatory viewpoint there are three levels of safety in air transportation.

The underlying logic is that the more a particular segment of aviation serves the public, the stricter it Presented at the U.S. General Accounting Office O

Conference of Transportation Issues In the 1980's, Washington, D.C.,

19-20 June, 1979.

I i

8001170 g j ig

r -

i j

1

-l,

I l

should be controlled.

Thus, we see the highest standards with l

regard to the quality of equipment, personnel, and operations ap-1 plied to air carrier-type activities, and the lowest to personal y

- i t

flying.

Between these two extremes in regulatory controls we find

['

a. middle ground, a transition zone, in the form of Part 135 operations s <

J which apply to air taxis and commuters.

The question I will address ist How has our system of graduated safety levels worked in the past, and what can be expected from it in the future?

l During the recent 10-year period (1979-1978), civil aviation 1

H in this country produced 370 million flying hours.

There were 7048 fatal accidents in which 16,376 persons died.

General aviation, W

including air taxi and commuter operations, accounted for 82% of the flying hours, almost 99% of the accidents, and 85% of the fatalities.

l With these overall dimensions of the air safety problem as I

background, we can compare the actual sa fety performance,of specific l

operations with the level of safety intended by various regulatory 1

constraints and quality controls.

To make this comparison I have converted the fatal accident rate per 100,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> into a more 1

expressive terms number of hours flown between fatal accidents.

Furthermore, I have used the average of the two best years in each type operation in an attempt to arrive at a reasonable approximation of proven performance capability.

The following table shows the results.

Type Fatal Accident Hours flown between.

Operation 2 Best Years Ra t e/10Q,000 hrs.

fatal accidents Air Carriers 1975 & 1976

.057 1,750,000 (35)

Corporate /

1971 & 1976

.32 300,000 (6)

Executive Commuters 1977 & 1978

.68 150,000 (3)

Air Taxi 1975 & 1977 l'.02 90,000 (1.8)

General 1976 & 1977 2.0 50,000 (1)

Aviation d

.i

c,

y

_I

-M wnM Ete)eM_MMid}MM~u fgi6sihWs%M3%few#er,w@i@m@wgMEWg u

sa m n-

-mwa~ n una_

j

~,

T

~c t

L

2

• l

'T, 2.,

R Using general aviation (all Part 91,and 135 operat~ ions) as the 0

accident per 50,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />) this table shows that the index (one fatal air carrier record is better by a factor of 35.

(Number in brackets

~

in the last column.)

This large difference raises a questions are regulations governing air carrier' operations 35 times better than those controlling general aviation or are there other factors at work?

n Perhaps, a closer look at general aviation operations may suggest

(

P some answers.

As can be expected, the table shows that the air taxi and commuter records are better than the general aviation record, but by disappointing margins: 1.8 and 3 respectively.

However, the real message of this table lies in the apparent inconsistency in the rank order of corporate / executive operations; their record exceeds that g

of the commuters by a factor of two and that of air taxi operations j

by a factor of more than three.

We have to draw the conclusion that

[

stricter regulations per se, even when augmented by an elaborate, t

government-operated surveillance and enforcement system, did not have f

the anticipated effect on the safety level of Part 135 operations.

In other words, this table seems to belie the concept that safety can be legislated.

The fact of the matter is that any regulatory or standard-t setting activity is only part of the safety equation.

Regulations and standards - even when they are sound - are no more than ab-stractions.

They can only aim at a certain level of quality in design, manufacturing, maintenance, and operations.

The achievement of the safety level intended by rules and standards depends on the recipients' ability and willingness to satisfy regulatory intent.

Since the ability and willingness to operate within a regulatory frame-work are governed by a variety of factors, including the caliber of management, economic pressures, and corporate or individual in-tegrity, we have to allow for corporate and private initiatives in

.U the safety equation.

This means that a regulatory agency at best, l

can only set a potential safety level; the actual safety level is M,

determined by the realities of the market place.

1 (o

k I

l MJ l

NA N

. ww& % nkgg[&' WA9hM@[ MAW. n. ;Nby;?MMTdNMMwM%m#f3 d

[*;4*/@'i; ' 7hNE Mf

??

Q in.

n. U m. n 2my&:;%

g.;;a x

1

'1 s

_4_

Relating these observations to the apparent inconsistency between the safety performance of Part 135 and corporate / executive r"si operations, I suggest that the basic explanation lies in the underes-r:

timated role of managerial and economic factors.

Since I have no e

expertise in these matters, I dare not even speculate on the long-

.g term ef fects of deregulation and competive forces.

However, I have f

x no compunction about stating that a few unscrupulous or incompetent operators can ruin the reputation of many good ones.

In that regard, we should have no illusions about rooting out substandard managerial t

practices with a government surveillance system without real t.eeth in it.

To be effective - even on a sampling basis - a surveillance system has to be backed up by a rigourous enforcement policy that for the can impose sanctions severe enough to act as a deterrent violator as well as others in similar positions.

s As indicated earlier, the table reflects only the best safety It performance in certain operations during the last 10 years does not show the modest improvements in fatal accident rates when the beginning and end of that period are compared.

However, there are no reasons to rejoice.

On the contrary, there is some bad news in the fact that our best performance lies already behind us.

The fatal accident rates have bottomed out and present trends show an uphwing.

To further illustrate that we have no reasons to feel smug, i

even in Part 121 operations, I quote from a statistical study in the January 20, 1979, issue of Flight International: "Looking at air transport safety over (the past) 25 years we can say that the 4

top country is undoubtedly Australia."

The same study of national j

records lists 5 countries - including the U.S.

- as contenders for I

The irony of this situation is that many of the second place.

accidents that put us firmly in less than first place could easily have been avoided if key individuals had been more sensitive to the always-present risks of human failure.

Perhaps, management's ulti-I level of mate challenge is to instill and maintain the proper protective skepticism throughout the organization, despite a pleasing i

safety record.

i

,a

_ 3 m ~:sg 9i&.A l

Y

$h5{Q;b"$f fh;Q Q ls & y fi ijff,g;4hl._l m

-y h

4 4

• w a

U l

1; With regard to the safety record of the personal flying seg-j ment of general aviation, I should point,out that this is less than.

50,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> between fatal accidents, because that figure also in-7 cludes all part 135 activities.

Considering the continuing growth and popularity of personal flying, it does not seem prudent to be J

l critical of the underlying regulatory structure and democratic S

E concepts.

liovever, this kind of reasoning cannot offset the fact HI that most fatal accidents in this category have a common source region lack of judgment or competence.

The real safety problem in general aviation may be that we put too much technology in un-prepared hands.

I use the word ' unprepared' more in the attitudinal a

sense than with reference to the mechanical skills of flying.

It takes only average intelligence and coordination to satisfy, in a minimum of 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />, the regulatory requirements for a private pilot certificate.

Such a certificate is no more than a license to gain operational experience through unsupervised exposure.

The hallmark of good training is the transfer of an attitude that allows

\\

a green pilot to survive his further development by adjusting his

[

explorations to the limitations of his experience and judgment level.

As Charles Lindbergh put it 50 years ago:

"A pilot's real training begins in flying, as in other professions, after he has left school."

s s'

The Future f

The bottomline in safety is the degree of care exercised by individuals.

'Ihe responsibility for the ability and willingness to exercise the proper degree of care is shared - in a complex and overlapping way - by the regulatory agency, corporate entities, and

,f individual operators.

Whenever the balance between these three areas M

of responsibility is disturbed, we. can expect the safety problems

,r reflected in the present upswing of fatal accident rates, because l

g l

the imbalance brings erosion of individual accountability.

Where p

is the imbalance and what can be done about it?

[

As I see it, the imbalance lies in the disproportionate share f

of the safety role attributed to the regulatory agency.

There is qr g

a growing tendency to transfer to government even those safety M

p 9& weymn w uy p@;m W h gcagaw ugg;;g g g gguwwwwmmmm4a.aammg mmsateme

e j'

i e

h

~

responsibilities that are purely corporate or personal in nature.

n Perhaps, we should expect that in an age that encourages self-L a

indulgence and conditions the citizen to look at " Big Brother" for p

o solutions to self-induced problems.

To the extent that this is an p

irreversible process, the outlook for transportation safety, in general, is rather grim.

However, considering the manner in which the youngest and most complex mode of transportation established r

it self, and the caliber of the persons who made it what it is, I am confident that the balance between safety responsibilities in aviation can be restored.

I say this because aviation has always met its challenges.

Revitalizing the role of managerial accountability -

I corporate as well as individual - in the total safety ef fort is our introductory challenge to the uncertainties of the 80's.

Conclusions As stated in the introduction, the purpose of this presentation is to raise doubt about some of our traditional r,afety concepts.

Therefore, I pursue the same theme in some concluding comments and suggestions:

A.

Part 121 Operations 1.

We should not brag about our safety record.

Although L

the comparison may be unfair, there are other modes of transportation that have a better record, even with regard to fatality rates per passenger mile.

v 2.

Public acceptance of air travel may not have as much to do with a presumably good safety record as we I

i like to think.

In most cases, the public has no i

choice of an alternative mode of travel.

3.

We do not need a Tenerife to remind ourselves of the L

brittleness of our safety record and our dependence on the caliber of key individuals throughout the system; our own accident record is very eloquent in 4

t that regard, k

[3R, 'j%} w ad;W;~ ?gg dy, 4l y v.:,/ '%

, m : -)q ry;g,g y

qlqqyy a3 r

~-g

gj y;p.HQ

y; 3 al+ f3 o

I I ( fr 8 6. t B. Part 135 Operations k I can make only one statement with regard to this important fH segment of the air transport system When the promotion of aviation [ and the promotion of safety are treated as separate goals, it becomes [ fd dif ficult to cultivate one without penalizing the other. Ia O I C. Personal Flyinq \\- n 1. The standards of flight instruction and the experience i E requirements for a private pilot certificate have l changed little over the past 40 years, despite the-i rapid growth in aircraft complexity and the intricacy l of the air traffic system. I sucgest that we take a 1 serious look at the present economic status of the flight instructor and its relationship to experience i level and safety. The caliber of initial.arx3 re- } current training is probably the most important variable in general aviation safety. r b 2. Typically, it takes several years of user experience, and modifications. beforr an aircraft reaches peak l reliability and maintainability. One wonders to what p extent the yearly proliferation of new designs, and l variations thereof, affects the economy and safety aspects of general aviation. i I Finally, a word about the role of the National Transportation Safety Board in the promotion of aviation safety. Our air transport system is designed and structured to function without accidents while satisfying public and private needs or expectations. Accidents are symptomatic of deficiencies in regulatory, corporate, or personal performance. As an independent a'nd objective agency, the Safety 5 1 Board is in the best position to identify these deficiencies and l to make recommendations that strengthen the foundations of a viable I and safe air transport system without regard for parochial interests. l 1 I _a What this means is that the Safety Board is uniquely qualified to assist all responsible parties in using what is bad in aviation to make ? I what is already good about it better. l Y.~ l 9:L" m m % um s d s,agg.gg g~h h' $,k Y !h Y ggg%

9. -}}