Risk Management

Complete Wildlife Risk Management Series

Complete Wildlife Risk Management Series

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.

Setting the Standard

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.

A long time ago, I wrote about integrating wildlife management and safety management with (as always) a focus on risk management. Well, I want to take this a little further.

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:

RMProcess

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.

In Practice

Here is how I see most risk assessment processes going:

  1. We identify the risks - in this particular case bird species at or likely to be at the aerodrome
  2. We calculate a consequence and likelihood score for each species
  3. We assign each species to a risk category according to the model used
  4. 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?

In Theory

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.

And then...

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:

Wildlife Evaluation Criteria

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.

Doing the Right Thing for the Right Reasons

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.

Runways Made Safer? Yeah but…

I caught this story on the web last week. According to the press release (eh, I mean) article, aircraft are falling apart during take-off and landing and the frontline of defence, airport safety officers, are prone to error. Enter the saviour – FOD radar. Okay, that's a cruel, exaggerated (mis)representation.

I will admit that Foreign Object Debris (FOD) is a very real problem for aviation and airports, in particular. Skybrary puts the yearly cost at $4 billion per year (including wildlife) and the list of FOD-induced crashes is often headlined by the 2000 Concorde disaster.

It's the mis-characterisation of runway inspections that gets to me as it seems that the article is trying to paint the following picture:

The first correction I want to make to the characterisation will actually make runway inspections sound worse. In Australia and under ICAO Annex 14, inspections are not required six-hourly but only once or twice a day. Well, at least once or twice a day. It's that "at least" which makes all the difference because at busy airports the expectation is that inspections are carried out more regularly based on the airport operator's assessment of the risk they are trying to mitigate.

Airport operators, in most jurisdictions now, are required to have a safety management system - a big component of which is risk management.  Below is another picture and this time, I've had a go at identifying the causes of FOD. Carrying out this type of exercise gives the airport operator a better understanding of the risk posed by FOD and the numerous options for control available to them.

Now its time to throw in a few more controls and treatments. The light green boxes in the picture below are preventative measures designed to stop FOD from being on the runway during aircraft operations. I've never actually seen all of these in described within the single risk scenario but they all contribute in their own way with varying levels of success. Remember, no single risk treatment is 100% effective (except maybe abstinence!). So multiple, in-line defences or defences-in-depth are essential.

The more interesting risk treatments, since it was the characterisation of runway inspections that got my goat in the beginning, are shown in light blue. These "as required" runway inspections are extremely important, maybe even more important than the standard regular inspections because they are specifically triggered when the risk is greater. Let's start with the bottom one and work our way up:

Rubbish + Wind = Bad - This inspection is actually already mandated in Australia. CASR 139.225 (3) (a) requires an aerodrome serviceability inspection be carried out after a gale. Following such events, it is reasonable to expect that stuff has been moved around and that some of that stuff might be on the runway. To combat this hazard, the scenario includes a rubbish control program (preventative) and an "as required" inspection (mitigative).

Engines that Blow, Suck - On narrow runways where outboard engines overhang the shoulder or even the strip, FOD from these areas may be blown on to the runway for subsequent aircraft to encounter. Again, the above scenario includes a preventative measure, erosion resistant surfaces, and another "as required" inspections as a mitigative measure.

Risk Control Gone Bad - Generally works are designed to make things better but as any good risk manager knows, sometimes controls become hazards themselves. In this case, FOD resulting from runway works is a very real problem. Tools are one of the big offenders, so the scenario includes a tool tracking procedure and the now familiar "as required" inspection to back it up.

Dodgy Bros. Airline - In some parts of the world, aircraft might have a tendency to fall apart or drop things. I'm going to put my hand up here and say that I've contributed to this one. Once upon a time, I left my fuel tank dipstick ( a cut-off broom handle) on my wing following my pre-flight inspection. Luckily it didn't do any harm as it fell off in the aircraft's assigned parking position but it highlights the point that some operations may have a higher likelihood of dropping presents on your movement area (in my case, low hour private pilots!). Other than banning such operations, I'm not sure what preventative measures there are but inspections after operations by known "dodgy" aircraft couldn't hurt.

Susceptible Aircraft - Critical aircraft operating at the edges of safety (maybe something like the Concorde) demand more attention. I don't think it unreasonable for runway inspections to be carried out before these aircraft operate.

I'll admit that inspections aren't perfect. A 2,000 metre long, 30m wide runway is 60,000 square metres - a lot of area to cover and a 3km x 45m is even bigger! Throw into the mix time pressures and poor weather and yes, effectiveness goes down. But using risk management to understand the complete (or at least wider) FOD picture helps to comprehend the risk and the controls already in place to deal or help deal with the problem. It also helps to make a sound purchasing decision when considering new equipment.

Don't get me wrong, FOD radar and detection equipment has a place and overtime, I'm sure its use will filter down to little ol' Australia. I, for one, will welcome its introduction as long as its considered within the total risk picture including an analysis of what new hazards are introduced by the new equipment.

Dilbert on Risk Management

Dilbert.com The ingenious Scott Adams definitely has a knack for breaking down business/social situations and highlighting the absurdity of all-too-common actions. I've seen this one quite a few times during safety audits and often, people show as little shame as you'd expect to see from the "pointy-haired boss".

I think this comes from a fundamental mis-understanding of the reason for risk management. It is not a task you complete to tick a compliance box - it is what you do to satisfy yourself that your plan is sound.

Enough preaching - check out this page for more of Dilbert on risk management.

Wildlife Management & SMS Integration

I may have suggested a couple of weeks ago that I was not going to carry on with material from my Indonesia trip in June but I really wanted to share this fictional case study with you. In order to highlight the interaction between strategic level SMS risk management and the more operational level risk management found in wildlife management plans, I developed the case study below. Its not really based on anything I've seen in action but more based on how I would approach the problem if anyone put me in charge. Background

Some sources put the cost of bird-strikes at $1.2 billion dollars per year. This makes wildlife hazard management a very important task for modern airport operators. It is however, a very big issue to tackle with a great deal of variety in operating environments, wildlife species, aircraft types and resources available.

This means that a single solution or prescriptive standard can not solve this problem. Instead, we turn to risk management as a way of reducing the chance and severity of wildlife related incidents to an acceptable level. PKPS 139 requires all airport operators assess the risk relating to bird and animal hazards and to implement controls to manage the risk. Even before any formal risk management process starts every operator already has people observing the wildlife on the aerodrome and reporting strike in accordance with the regulations. In SMS terms, major wildlife hazard management activities are usually initiated by safety assurance activities such as internal audits and investigations.

Strategic SMS Risk Register before Review

Beginning at the Top

In this scenario, an internal safety audit has identified a general increase in the numbers of birds on the aerodrome, plans for a garbage dump nearby and a couple of costly bird-strikes as concerns requiring formal risk assessment. The Safety Manager presented the audit’s report to the CEO and the CEO tabled the report at the next Safety Committee meeting.

The Safety Committee initiated the risk management process at the strategic level by reviewing its previous wildlife hazard risk assessments found in its risk register. The review found that a formal hazard management plan (operational risk management) was required.

Strategic SMS Risk Register after Review

As per the review, the Safety Manager engaged a qualified ornithologist with airport experience to develop a comprehensive management plan. This plan began with a full assessment of the wildlife on and in the vicinity of the airport and the environment on and off the airport. This assessment resulted in the identification of more specific hazards including each animal species – see below for an example of this type of risk assessment based on the model published by the Australian Aviation Wildlife Hazard Group. This assessment allows for the planning of allocation of resources to the most critical areas – for example, the grassed and wetland areas are more important than treed areas and ibis and galahs require more attention than quail, tern and swallow.

Species Specific Risk Register

From this point, the consultant works with the airport operator to identify potential risk treatments. These treatments cover a range of strategies including habitat control, feed control, harassment and reporting.

  • Habitat control – this strategy is targeted at the higher risk areas and species and includes longer grass in areas, filling in a number of ponds and the netting of potential nest sites.
  • Feed control – this includes efforts to minimise food sources such as removal of fruit trees, enclosed garbage areas, a mowing schedule to reduce grass seeding and a safety promotion campaign advising all airport users of the need to pick up rubbish.
  • Harassment – these efforts include a range of acoustic and visual harassment devises for airport reporting officers and a semi-irregular harassment schedule.
  • Reporting – two new reporting systems were proposed. The first consists of an external reporting system whereby significant wildlife hazards are reported directly to the aerodrome users’ safety/operations departments. These reports follow a standard format issued through the airside operations manager. The second system involves internal reporting of wildlife hazards according to specific risk-based triggers devised by the consultant. If during an inspection, the airport reporting officer notices a specific hazard in excess of these triggers, he/she submits a report to the Safety Manager. The regulatory requirement to report all strikes to the authorities continues to exist.

Monitoring consists of regular animal-counts typically carried out following the morning airport inspection. Tactical risk assessment consists of comparing this count results against the reporting triggers developed by the consultant (see above). Results below these thresholds are filed for future review.

These results plus records of wildlife strikes and any other report are reviewed annually along with the entire management plan. Deficiencies are identified and the plan amended as required. The results of these reviews are submitted to the Safety Committee by the Safety Manager.

More Information

There is plenty of information on the Internet on this issue. Here are a couple of links:

Indonesia, here I come...

I'm off to Jakarta next week to present a workshop on SMS to the Indonesian DGCA's SAG members from their Directorates of Airports and Air Navigation. It'll be my second trip to Jakarta and I'm really looking forward working with the Indonesians again - they are a great bunch of people, very friendly and polite. Anyway, I thought I would share the slides I'll be presenting - just for general interest's sake. I've had a go at translating most of the headings into Bahasa Indonesia using translated versions of their regulations and Google translate. I hope there are no major errors!

Some of the slides haven't converted as they will be shown on the big screen but I'm sure you get the gist.

Update - things rarely go to plan in Indonesia. In this instance, time was short and the direction of the workshop changed to focus on acceptable levels of safety and risk management. I also changed practical exercise around considerably as you can see in my post about it.

"a sweep of the runway collected more than 20 bird carcasses"

I spied a couple of news reports of a mass bird-strike at DFW Airport today and the above quote jumped out at me. The procedure for checking the runway following a bird-strike is not required under Australian regulations and is not always included in the aerodrome manual - despite being a really, very, really good idea. In this instance there were no injuries although there was some damage to the aircraft. But the concern is not the struck aircraft, it's what's left on the runway. Twenty dead birds present an attractive meal for a predator or scavenger (including domestic animals) and any aircraft debris is also a hazard to other aircraft.

A Really Old Bomb Scare

News out of Pisa over the last couple of days could give some food for thought for all those aerodromes built during WWII.

Pisa airport in central Italy shut down yesterday evening with all flights in and out cancelled after a World War II bomb was uncovered near the runways during maintenance works.

As I've travelled around I've heard my fair share of stories of underground bunkers, gun placements and even possible ammunition caches. Perhaps these stories should be included in the aerodrome's risk register which had been developed as part of it safety management system. For any WWII-era aerodrome, I don't think the above scenario is beyond serious consideration.

For those aerodromes, unexploded ordinance could be added to risk register as a newly identified hazard. The Safety Officer is then typically tasked with assessment of the hazard and the development of appropriate risk controls. They may be assisted by a committee of aerodrome stakeholders or other subject matter experts - in Australia's case, the Department of Defence. The treatments are then included in the aerodrome manual and other documents, airside/work-site induction etc., as required.

Given the level of works being undertaken at aerodromes across Australia and especially in the north, I'll be pushing this issue as I travel around.