How does Compliance relate to Safety and Risk?

Compliance vs Safety – Are we doing it right or are we heading for danger?

On the 20th July, the T-C-Alliance held one of their monthly workshops. More specifically, this workshop was titled “Aviation Safety Risk Implications”.

The main focus of the workshop was the question “How does Compliance relate to Safety and Risk?"

Before going into details, let us backtrack a little and answer the question “Why this topic?”. The reason we decided to have a workshop on this was due to market feedback and professionals raising questions on the effectiveness of aviation regulation compliance and if in fact it actually helped with safety or if it is simply a hindrance.

Now, straight away, as an aviation professional and having been in positions of authority and responsible for compliance in airlines, my initial thoughts were “Are these people crazy? How do they not get it?”

If I was going to continue down that route of thinking however then I wouldn’t be much of an ambassador of aviation safety now, would I? No, in order to have an type of outlook, we must firstly understand the opinions of others; question them; critically analyse them; and then for an understanding and tangible takeaway that is agreeable by the majority.

Therefore, we (the T-C-Alliance) opened up our monthly workshops for the public and not just for our members, as this is a very important (and serious) subject matter.

Context of the Workshop:

To have a truly objective view, the workshop was an open discussion. Free from pre-conceived viewpoints and everyone was openly encouraged to voice their opinion. In fact, we actively asked to be challenged and if anyone disagreed whenever an opinion was made. Just because we think we are right; does not necessarily mean we are and we have to be open to this. Questions and polls were conducted throughout the workshop with some insightful feedback (but we will get to that later)

Details from the Workshop:

First off was to establish what is meant by compliance. In this context, compliance is conformity to aviation regulations as per National Aviation Authority (NAA) auditing standards. For example, if you are a maintenance organisation, then you have to comply with EASA Part 145 requirements. (If you are under EASA jurisdiction of course).

Then comes the question of safety. “What is Safety?”; “Who is responsible for Safety?”. In this context, safety was regarded as both the Physical safety of the aircraft and the employee carrying out their role. Phycological safety was not really discussed or interpreted within the context of the workshop; which in itself is interesting and food for thought! (In my opinion).

Feedback from the Workshop:

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It was concluded from the discussions that there seems to be a disconnect by some senior and operational management as to the connection between compliance and safety. For some, the argument was that by being compliant, they have justified physical safety and their job is done; almost like a “tick-box” exercise. This brought into question, the roles of the senior management; ethical standards; cultural awareness and consideration; “Ownership” of standards and implementations; “Blame Culture” and pushing the responsibility to the NAA’s.

For the majority, it was understood that Compliance is the minimum standard that has to be adhered to. Being compliant does not equal Safety. Being compliant means that you have some kind of baseline and starting point in which to create Safety. Once you have Compliance, then you have to take into consideration the organisational culture, economic constraints, area and interaction of the aviation sector with others (the list goes on and on).

Analysis:

NAA’s have complied years of research reporting to create regulatory compliance that (if implemented corrected) is proven to reduce organisational risk and hence help towards Safety.

However, aviation is so siloed that every department and section has alternative views on the subject. Personnel who are new to the aviation community or new to roles of authority are finding it difficult to comprehend the balance between Compliance and how to proactively make a positive impact on Safety within their organisation.

Understanding of compliance is not necessarily disseminated corrected (as per the feedback from our polls) and frightfully the more compliance that is necessary, the less trust there seems to be within organisational cultures. For example, (from the participants of the workshop) there were those that indicated they did not see the coalition between Compliance and Safety because being compliant simply added to their workload and they felt that this actually had a negative impact on Safety.

Given that new regulations are coming into play this year, making SMS mandatory in more aviation sectors (Part 145 and PART 21 for example), are we in danger of making the industry less safe as there are those that will implement these regulations without understanding of the whole picture and how it all fits together?

My Opinion:

Compliance has almost become demonised in the eyes of aviation professionals as the pursuit of compliance by senior management outweighs the effectiveness of Safety Management. Aviation business models and employee roles over the years have had a negative impact on Safety Culture due to “Compliance for Compliance’s sake” and the “Tick-box Culture” that seems to have become a normality within certain environments.

Accidents are happening more often and people are more confused and scared within aviation, so to state that being in compliance is not acceptable anymore. Our roles as aviation professionals should not be to “tick boxes” but to strive for continuous improvement.

How can this be done? Don’t just take into consideration your role or the regulations you need to abide by, but try to have an understanding of the roles of others; the interactions. Forget authority and the “it’s not my job” mentality and take into consideration the fact that we all need each other in aviation in order to be safe. This can be done by continuous development; an understanding of unconscious bias; ethical thinking to the phycological safety of our colleagues; continuous training and dissemination of regulatory compliance for a deeper understanding and above all, questioning, discussing and critically analysing why and how we do what we do!