Complex Change in Practice - Regulation Harmonisation in Australian Aviation

If you attended the Australian International Air Show this year, it’s likely that you passed the stands for DASA and CASA (Defence and Civil Aviation Safety Authorities, respectively) exhibiting side by side. What you might not know is that behind the scenes, the two regulatory bodies have been working to pursue an integrated approach to Aviation Safety in Australia. A world first. Why is this happening and how is it going? 

Well, KPMG facilitated a public forum at the Show to explore just these issues.   

Why Change?

Back in 2016 DASA became a single integrated military aviation safety organisation as they worked to improve efficiencies within their business and provide a greater service to the ADF. This coincided with the introduction of a new set of Defence Aviation Safety Regulations (DASRs). The creation of DASA incorporated the three previously existing Defence aviation safety agencies into one that more closely conforms to internationally recognised organisational structures.

“An integrated authority makes it easier to identify and resolve gaps in our functions and helps focus us on tasks that cross agency boundaries.” Air Commodore Jason Agius, Director General DASA.

The change in their structure has not only improved efficiencies within Defence, but has also allowed for a greater opportunity to effectively collaborate with their civil counterpart CASA, with the pair now actively working towards a set of priorities to increase their integration and regulatory acceptance.

Why is this a big deal?

Well, currently in Australia there are two distinct airworthiness regulations – for civil and military certification, as is the case in most countries around the world. This means that industry players who operate in both the civil and Defence spaces, are required to be certified under two different sets of regulations, and that their certifications and design authority cannot easily be transferred. Often expensive and inefficient practice.

The two authorities have recognised a need to improve this and are now actively pursuing an integrated approach to an Australian aviation State Safety Program (SSP) through closer engagement and cooperation. An MOU between CASA and DASA was signed in November 2018. This umbrella agreement details how the organisations will work together. Subordinate agreements will likely be put into place in the coming months.

Air Commodore James Hood was the inaugural Director General of DASA and is a big believer in an integrated approach to Safety in Australia. “Greater alignment and less duplication will improve efficiency,” he said. “It will increase business opportunities for Australian Industry.”

 “Australia is known for being innovative, with high levels of safety and excellent quality in the aviation sector” Jonathan Aleck, CASA

So where are we now?

Since the MoU was signed an SSP CAT (Cross Agency Team) has been set up work together on the major risks, and to identify a set of priorities to help us move towards a more aligned regulatory system. So far 7 KPIs have been adopted, and issues such as Cyber, UAS and Autonomous Systems have been at the forefront of discussions.

A workshop, held during the Avalon Air Show earlier this year helped to clarify where the CAT should focus their attention, identifying four parts of the DASA regulations that, if aligned, would create the most opportunity and improvement in processes for industry. These are:

1. Production (Part 21J),
2. Maintenance Organisation (Part 145),
3. Maintenance Approval Recognition (Part 147), and
4. Licensing (Part 66).

DASA and CASA have since taken the areas of regulation and are prioritising their efforts to ensure the best the most important areas of concern will be addressed through targeted working groups – made up of staff from both parties.

With respect to maintainer licencing, DASA is already working using the EASA (European Aviation Safety Authority) requirements with exclusions and extensions. DASA also hopes to further improve understanding of and application of licencing requirements with the eventual aim of CASA and DASA recognising each other’s.

Realistically, it is unlikely that a fully integrated State Safety Program will be achieved in the medium term (due to the Chicago Convention) but there is a lot to be said for improving the alignment and creating a simpler space for industry to operate in, with parallel systems that work closely together. The Avalon workshop was another step on that path.

ARCDRE Agius said at the workshop “We want practical answers to practical questions. Part of the process involves identifying where the differences are. It’s then a question of why do those differences exist. We might find technical or operational reasons where the nature of military/civil operations don’t allow for complete sameness.”

“Harmonization is not everyone singing the same note but singing different notes that work well together.” Jonathan Aleck, CASA

Complex change in a complex world

The over-arching need behind this harmonisation is to enable the Australian industry to remain resilient and competitive globally, and to continue to build on the strong international reputation we have built.

In a time of huge disruption, with competing industries putting a strain on resources and with an aging LAME workforce, it is now even more important that the Australian Aviation industry can operate efficiently and collaboratively – sharing the best of each sector. While Regulation Harmonisation was once a distant dream, it is now a very real goal with a clear flight-path to take us there.

A massive thanks to Stephanie McMurray one of our fantastic management consultants at KPMG who did the hard yards pulling this blog together. Great to work with you Steph!