Late last year, I posted that I was writing on another blog a complete series on an ISO31000 view of airport wildlife risk management. Well, that 7-part series is now complete and to view the whole series head over to my author page on New Airport Insider or you can read each post by clicking the individual links below.
The good folk over at the Australian Aviation Wildlife Hazard Group (AAWHG) have released their first Recommended Practice. It's still in draft form and comments are welcome. First off the block is a draft RP 3.2.1 - Firearm Safety. The document outlines a range of "shoulds" and is a great start, if not an end, for airport operators to get their own processes and procedures up to an industry standard - perhaps even, best practice.
Okay, I'm going to claim, tongue-in-cheek, that I told you so. Two years ago, I suggested that the next global initiative should be Taxiway Safety. While Runway Safety was getting and continues to get its due attention, there had been a spate of ground collisions involving large jets at US Airports.
I've been doing a bit of clearing of land at my airport to make way for a new fence. We've had to expand our borders to accommodate those new instrument approach procedures I mentioned a couple of weeks ago. Given that the airport is in "the bush", this meant knocking over a few trees to construct the new fence and make the new airside area completely manageable using tractors and mowers. So, we broke out the relatively cute D-6 dozer and set about clearing the new airport boundary and land.
This is probably my first real whinge post. But last week, I spent a good 9 hours on a Sunday in a training course that was a huge waste of time. And this was vital training - gun safety.
This post is just about me getting excited. Today, we had a visit from Radiola Aerospace (VH-VEH) as they validated the new instrument approach procedures for my airport. At the moment, we have just one RNAV GNSS approach from the north to a circling minima.
But soon, we will have two approaches, one from each direction, down to landing minima. This should go a long way to helping our airlines get in on those messy days during the wet.
Airports are at the nexus of high visibility and idle time. We invite people to transit through our facilities. We provide windows for them to watch the action. We make them wait (hopefully not too long).
And how do they reward us?
By watching us at work. And sometimes, if you're unlucky, filming us at work...
Well, actually, his behaviour isn't really defensible, is it? ;)
This is me coming up for breath. I've been in the deep-end of airport operations for the last 10 months or so and I'm only just getting my head above water. I think (or at least hope) I've achieved a lot over the last couple of months but very little has been blog-worthy. However, over the last week or so, I've been swimming in that lovely little pool called Wildlife Hazard Management. And while I was re-writing my airport's Wildlife Hazard Management Plan, I stumbled across something I thought worthy of a share.
The Wild Side of Risk Assessment
The crux of my previous post was that the risk assessment of wildlife sits within the risk assessment of safety and that they may use different techniques. The SMS-level might use a standard risk matrix (or not) and the wildlife risk assessment might use a different technique such as the Paton bird risk assessment model.
The Risk Management Process
The two techniques are really just tools within the fairly standard risk management process. As the global standard puts it:
I think that some of this stuff most of us do well but there is a step we've been missing. It's that dark green one - evaluation.
Here is how I see most risk assessment processes going:
- We identify the risks - in this particular case bird species at or likely to be at the aerodrome
- We calculate a consequence and likelihood score for each species
- We assign each species to a risk category according to the model used
- We treat the risk - we think of stuff to do to address the identified risks
And all that sounds great but there is, to me, something missing. We might very well devise risk treatments that are sound and effective. We might even target those species that appear high up the list (let's call that, risk ranking, which doesn't appear in the standard). But how have we actually decided to do those things?
Well, good ol' ISO 31000 defines risk evaluation as:
(The) process of comparing the results of risk analysis with risk criteria to determine whether the risk and/or its magnitude is acceptable or tolerable
and notes that:
(It) assists in the decision about risk treatment
So what are risk criteria? Again, ISO 31000 says that risk criteria are:
terms of reference against which the significance of a risk is evaluated
Damn it ISO, buddy, you went a bit circular there. So what do I think the risk criteria are?
I look to the note above, they guide you in the decision making process. You set up parameters, before hand, that tell you what to do with risk assessed at the various levels you've set.
Here's an Example
I've just put together the risk assessment framework I intend to use at my airport. I'm basing it on Paton but extending it to land animals as well. I describe the calculation of consequence and likelihood and then outline (via a matrix :( ) the calculation of the final risk level.
I define what must be done for each risk category/level.
Even before I've looked out the door to see what birds I have at the airport. These requirements are now set in stone. It holds me to a standard and allows for variations in the real-world context, which will occur, to be managed in a consistent and almost predictable way.
This standard allows my bosses, my airlines and my team to know what is expected if we encounter a situation where a species is assessed as "extreme" or "very high" or "negligible".
And for me, those standards are:
Applying the Standard
Now, I go and look out the door. I, with the help of a qualified ornithologist or biologist, look at the environmental, operational and historical contexts and come up with a list of species. We score them and categorises them and then we have to do what the above table say we are going to do.
Any species assessed as "extreme" get their own plan (luckily none of them for me at this stage). Those at "very high" get general strategies that target them (for example, I will be implementing a short-grass policy to reduce my kite numbers) and so on.
As things change, I can also change my strategies with confidence as I have a standard to hold on to should I wish to drop strategies or introduce strategies.
And I think this is a good thing. Yes, you might get pinned in a corner and have to act in some cases but that is the point. You will be held accountable anyway and not setting a standard will not protect you if it all goes pear shaped - touch wood.
I've just spent an amazing week in Bali1 workshopping with operators and regulators from the Asia-Pacific region (and some from further afield) on the issue of runway safety. We got a lot of good information from the Flight Safety Foundation, ICAO and COSCAP as well as airlines, airports and regional regulators.
The primary objective of the week was to provide information on and practice in the establishment and conduct of Local Runway Safety Teams (LRSTs). To this end, the seminars and workshop were great but I left feeling like one connection had been missed. The final question on my mind and many others, I am sure, was:
How do these runway safety initiatives integrate into my SMS?
I long time ago I blogged about the risk posed by unexploded ordnance. Well, last week Schiphol Airport in the Netherlands had to deal with that very problem. [youtube=http://www.youtube.com/watch?v=xAxoc2oCZwg]
After a year away from airports, I couldn't stand it any longer. So, I'm back and this time I'm actually working for an airport operator. As such, I'll be swimming in airport stuff again and as I hit something interesting, I'll post it here. I'll also be posting a few projects I'm working on and a couple of handy hints and tips from time to time.
While I've been away from here, I have been blogging on general, perhaps esoteric, subjects at theregulatorslot.com. I've hit subjects like risk assessment, logical fallacies and culture. I'll be keeping that up over there as well as posting airport-related stuff here.
Oh, it's good to be back.
As you can no doubt tell, I haven't been blogging much over the last couple of months. The reason behind this is that I went and got myself a new job. Same place but a new role. I'm no longer an aerodrome inspector. Instead, I've moved into a much more strategic role in the Safety Systems Office at the Civil Aviation Safety Authority.
This new job has left few mental cycles left at the end of the day to put fingers to the keyboard. In addition to this, I'm back working with the whole industry and airports have had to take a bit of a backseat while I get my head around the more general issues facing the industry at the moment.
I am ready to get back into blogging but with my change in job comes a change in focus. I'm much more involved in regulation and risk management on an industry-wide basis now and I'd like to blog on these subjects.
Therefore, I've started a new blog over at The Regulator's Lot.
If you are interested in these subjects and aviation safety in general, please come on over and have a look.
Here's a friendly reminder that comments on the recently resealed draft advisory circular regarding hazardous materials handling must be in by 3 October 2011. Submissions to Matt Windebank by then will be duly regarded - after that date, not so much.
Here is another chance to have your say - this time it's a revision of the old CAAP 89I-1(2) to match the more modern CASR Part 139 and associated advisory circular format. Draft AC 139-12(0) - Handling of Hazardous Materials on an Aerodrome "provides guidance to Aerodrome Operators on aerodrome administration andoperating procedures for the handling of hazardous materials on the aerodrome" as required by CASR 139.095.
Send your comments to Matt Windebank by 3 October 2011.
The ATSB has posted, today, a discussion paper and set of draft regulations covering its confidential reporting system. You can have your say on the proposals with submissions accepted until the 16th December 2011. Comments, questions etc. can be sent to firstname.lastname@example.org. The discussion paper covers the 'no-blame' and 'just culture' approaches to reporting systems - no, they are not the same. These are concepts I'm very keen to research more, so stayed tuned - don't hold your breath though, its pretty hectic over here right now but I will try to post a few more things this week.
A couple of weeks ago a question came into the Aerodromes Inspectorate at work regarding the accuracy of airline scales at airports. In Australia, that's not necessarily an airport operator's responsibility and is not covered by our aerodrome regulations. Anyway, that's not the point of this post. This earlier event made me notice this story from the LA Times on the same topic, so I read with interest to see what other countries do. I couldn't exactly work out whether it was the airport or airlines responsibility but in Los Angeles at least, a government department comes in to give the scales the big tick of approval. But the angle of the story was what really stood out.
The journalist writing the story and the policy of the responsible bureau puts the emphasis of the process on money - basically the airline's attempts to charge the passenger for excess baggage. While that is by far the most apparent effect of these scales that is not why they are there.
Switching back to Australia now - an airline is required to have scales at an airport thanks to Civil Aviation Orders 82.3 and 82.5. The need for accurate weight calculations is spread across a range of other regulations. They are a safety device designed to provide the airline/pilot-in-command with an accurate weight of what is being thrown on to the aircraft. Why? Well, in the first instance if the aircraft is too heavy, it doesn't get off the ground and in the second instance, if weight is not distributed around the aircraft appropriately, it may be or become uncontrollable in flight. Accident databases have plenty of records of overloaded and out-of-balance aircraft accidents.
Back to the story - here is what is required when a scale is found to be inaccurate:
"If a scale is off by more than one-tenth of a pound in favor of the airline, bureau inspectors put the scale out of service until it is repaired. If a scale is off in favor of the passenger, it can still be used but must be repaired within 30 days, said Jeff Humphreys, deputy director of the bureau."
So if the scale over-reads by 45 grams its instantly out of service - good, not extra baggage tax! But if it under-reads by any amount (no limit stated) the airline has 30 days to fix it, really? So overloading an aircraft is okay but overcharging passengers is not okay?
I see this type of thing a lot. People doing something which appears to be correct but on closer examination it's for the wrong reason. It is very important to ensure that what you do is for the right reasons because over time, the wrong reasons might mean something is missed or worse, your actions contribute to an accident.
An example from my recent experience goes like this:
An airport operator was not providing an aerodrome works safety officer for minor works (slashing, etc.). They got pulled up by transport security officials because at the same time they weren't providing the appropriate security escort. The airport operator's solution was to provide staff with the appropriate security card to supervise the works and lucky for me, those people were all trained works safety officers.
But what happens when someone working for that operator gets an appropriate security card but not the required works safety officer training?
If the operator is not doing the right things for the right reasons, they could easily end up with an unqualified person supervising aerodrome works with no understanding of the risks they are meant to be controlling. They might not even have the right equipment (e.g. an airband radio) because the procedure has morphed into a security role and safety has been forgotten.
Killing two birds with one stone is fine, but make sure you remember to kill 'em both all the time*
Something to consider when you do your next aerodrome manual review, right?
* I am not condoning violence towards animals - even though I'm under siege from swooping magpies at the moment.
Last week I blogged about the ACRP's new synthesis report on bird control techniques and on that very day, Airport International News reported on deterrent grass developed in New Zealand. This new grass is still being tested in NZ so its no wonder it didn't make it into the ACRP's report. The grass itself is bred with a fungus component designed to make the birds that eat it sick. Over time, the birds will move on and thus reduce the risk of bird strikes on the airport. My initial concerns regarding non-herbivorous birds were somewhat answered on the product's actual website where it stated that the same effect occurred in insects. I'm assuming the same for mammals (both as food-sources and hazards) - anyone know the answer?
It's an awesome idea and I can't wait to see some data from further trials. However, I think the article overstates the impact of a single risk control measure on the wide ranging problem of wildlife strikes. The problem of land side and off-airport attractants or even woodlands, swamps etc. still remains.
I'd love to hear more about how the product works. For me, it seems that the birds (maybe not individually but at least each population) must first consume the grass before it deters them. Therefore, every bird population must first visit the airport before they decide not to come back. I don't know enough about bird behaviour, society, learning etc. to pass judgement on that.
PS - I wonder if it will work out where I was last week?
* should I trademark that?
I know plenty of airport people who really don't care about aircraft. For me, it's the thing that sets our sector of the industry apart from the rest. A large portion of the airport industry, in Australia, are not in the aviation industry by choice. They are a council providing civic services of which one is the airport or they operate a mine or tourist venture which requires the airport in a support role. They come with little or no aviation experience, skills or knowledge and many would sooner gush over CAT's latest front-end loader than the new ATR 72 flying around Queensland. For those engineers, works supervisors and general road-works warriors out there, here is a cool new video of trucks, asphalt, men and some more trucks as they overlay one of Melbourne Airport's runways. Enjoy :).
I've seen my fair share of aerodrome manuals. Every audit begins with a review of an aerodrome manual and in my past life as a consultant, I wrote a few as well. Unfortunately, the state of the vast majority of aerodrome manuals I've encountered, including my own, could best be described as "needs improvement". But before we get to the tips, let’s just rehash the aerodrome manual rationale. Why do we have this document?
The easy answer would be to say we have aerodrome manuals because Civil Aviation Safety Regulation (CASR) 139.090 says we must - but that's not a real reason.
To me, there are two purposes to the manual. One, the more obvious, is that the manual is a set of procedures designed to ensure consistency, completeness and to meet the organisation's objectives. The other purpose is closely tied to the aerodrome certificate. The aerodrome manual serves as the "contract" between the certificate holder and the regulator. The certificate was granted, in a large part, because CASA considered the policies and procedures contained in the manual acceptable.
When the manual doesn't match reality, we got a problem. So, let's try and fix that...
By carrying out a manual review. Conducting a periodic review is a great idea. It’s not a mandatory regulatory requirement. It’s simply a great idea. If you want to make it a stellar idea - make a review a documented procedure in the manual itself. That's not to say that you need not update the manual as required (as per CASR 139.105) but a regular, comprehensive, structured review will help regardless of how "on top of it" you are.
Now that you're convinced of how good an idea this is (you are, aren't you?), here are five things you should think about when conducting your brilliant idea review.
1. Look for Changes
A lot of things change - people come and go, phone carriers are switched, critical aircraft and their operators and even government legislation and regulation. On every page look for things that are likely to change and check that they are still correct. And I mean check - call numbers and speak to people, visit websites and go watch the regular traffic for a week.
One of the more subtle changes in "recent" memory was the move from the Bureau of Air Safety Investigation and Part 2A of the Air Navigation Act 1920 to the Australian Transport Safety Bureau and the Transport Safety Investigation Act 2003. That's right, 2003. It’s been almost 8 years but I still spot the odd reference. What is even more subtle though is that many manuals simply replaced the titles of the acts and not the actual details in the manual. The powers granted to the ATSB were not the same as for the BASI. More than a "find & replace" is often required.
2. Who's who in the Zoo?
This one is more than just updating names. This is more about positions and responsibilities. Firstly, I often advise that aerodrome manuals refrain from using actual names of people anywhere other than in the master contact list. That way, when people do change, only one page needs amending. Now, which titles to use?
You could use the actual titles people hold within the organisation or you could use aerodrome specific titles. At many aerodromes, the aerodrome manager or the aerodrome reporting officer are not employed as an aerodrome manager etc. They are mostly likely the director, engineering services or works supervisor or even sanitation technician. On top of that, now consider that the one person may fill numerous roles at the aerodrome.
I don't have a definitive opinion on this one. Both could work if the approach is applied consistently and supported by external processes if needed. The main considerations to be made are qualification, future-proofing and clarity.
If you use non-aerodrome position titles consider how to comply with the training requirements contained in CASR Part 139. If the parks attendant is the aerodrome reporting officer is having completed an ARO course a requirement of that position, is it in the position description. If not, how will the human resources department know that the next parks attendant needs such a qualification?
By clarity, I mean that when you use aerodrome specific titles, do the words in the document make sense. This example I see often - the council CEO is named the aerodrome manager in the aerodrome manual, the council is named the safety officer in the aerodrome safety management system document and then the document says that the safety officer has a direct line of communication to the aerodrome manager. Well, of course he does, they are one and the same person! This tells me, as an auditor, that the aerodrome operator is relying on template documents too much and has probably not actually read their own procedures.
3. Do as it Says or Say as You Do
CASR 139.145 requires the aerodrome operator to follow its own procedures. Therefore if you are doing something or failing to do something in contravention of your own manual, you are in contravention of the regulations regardless of whether your action otherwise meet the rest of CASR Part 139 etc.
This means that if your manual says that airside drivers must wear a pink tutu and they don't, then you are failing to meet your regulatory obligations. Alright, that one's silly. Let's say your manual says you will inspect the aerodrome each weekday at 0600 but you only do it on the three days that an airline service operates and you do it at 0900. You are meeting the requirements of CASR 139.225. But by failing to operate in accordance with the manual on this count, it casts doubt on your application of the rest of the manual.
Its not all doom and gloom, just make sure that what you do and what the manual says you do are the same thing and they both meet the requirements contained in CASR Part 139 and the Manual of Standards Part 139. To do this you can either change what you are doing to align with the manual or change the manual to align with what you’re doing. It’s your manual after all.
4. Think Processes
When reviewing the manual, look to see that the entire process is laid out. Think about the who, what, where, when & how. Also think about record-keeping - remember: if it ain't recorded, it didn't happen! This doesn't mean that the simplest activity needs pages of how-to's. There is nothing wrong with keeping it simple.
Think about the following:
- Responsibility - Who is responsible for this process and what is the level of their responsibility? Do they actually do the procedure or do they ensure that it is done?
- Mandatory - Use the words "shall", "must", "is to" or "will" for mandatory procedures and "should", "can" or "may" for recommended actions.
- Detail - Consider less detail where procedures are covered by well-documented standardised training. For example - there is no need to include mandatory radio transmission phraseology in the manual because everyone using a radio has received training in accordance with Civil Aviation Regulation 83 (right?).
- Records - How are records created? Forms, logbook, database etc. and where are they to be found, say, during a CASA audit? For how long will they be kept?
5. Document Control
Now that you're ready to make some amendments, please consider some of these document control best-practices. Employing these will help manual holders identify the currency of their documents and identify the changes that were actually made.
- Dates - Most manuals are riddled with dates - one on the cover page, the checklist of current pages, every page footer. You need to make sure that they are consistent. Depending on how your electronic document is arranged this may necessitate the amendment of sections at a time and may require the introductory section to be completely updated every time as well.
- Mark-up - Black lines in the margins or even bold text on the actual changes helps readers to identify what actually changed. There is nothing more boring than receiving a manual amendment consisting of a ten-page section where only two words were amended yet the whole section had to be read word for word with its predecessor to find the changes.
Well, that's enough ranting out of me. I'll be at my desk tomorrow awaiting your latest manual amendments with bated breath.
* I'm actually in the field at the moment with a pretty poor internet connection, so I can't put in all the links I wanted to put into this post. When I get back to town, I'll update this post with appropriate links