Rotorcraft Industry Seminar Rotorcraft Risks and Issues 7 September 2017 OFFICIAL SENSITIVE

John Clark Safety Programme Manager & PBRIG Chair Carl Christian Principal Airworthiness Surveyor Rotorcraft Mark Swan to introduce these Invite Mark Bailey to say a few words

Update on the Transformation to Performance-based Regulation To transform the CAA into a Performance Based Regulator, working with industry to demonstrably reduce safety risk across the total aviation system and develop the capabilities required for future regulators. Mark Swan to introduce these Invite Mark Bailey to say a few words

Update on the Transformation to Performance-based Regulation Compliance is a great starting point….but is not enough! More rules will not necessarily increase safety but can: Increase regulatory burden (cost and resources) Apply generically (even where performance is excellent) Performance Based Regulation (PBR) is a response to the challenge of delivering continuous improvement in aviation safety in the context of increased aviation activity and future safety trends Mark Swan to introduce these Invite Mark Bailey to say a few words

Update on the Transformation to Performance-based Regulation Mark Swan to introduce these Invite Mark Bailey to say a few words

Update on the Transformation to Performance-based Regulation PBR System Privileges Air Operator Certificate Entities British Airways Sectors Large Airlines Total System UK Europe Worldwide Mark Swan to introduce these Invite Mark Bailey to say a few words

Complexity Matrix Rating Update on the Transformation to Performance-based Regulation Red Amber Approval status Green 29 23 17 13 8 37 Complexity Matrix Rating Annual audit 4 days (FOI, IO, GS & CS) Check R x 2 (FOI +CSI) Check T 1 per fleet (FOI) Check F 1 per fleet (FOI) Check M 2 days (FOI/IO) Check C x 2 (CSI) SAG >4 (FOI/IO) Cabin safety SAG x2 Annual audit 4 days (FOI, IO, GS & CS) Check T 1 per fleet (FOI) Check F, min 2 (FOI) Check M 1 day (FOI/IO) Check C x 2 (CSI) SAG x 2 (FOI/IO) Cabin safety SAG x2 Annual audit 3 days (FOI & IO) Check T & F, 1 day each (FOI) Check M 1 day (FOI/IO) SAG x 1 (FOI/IO) Annual audit 2 days (FOI & IO) Check M 1 day (FOI/IO) SAG x 1 (FOI/IO) Check M ½ day (FOI/IO) 1 day audit per 24 months. (IO) 1 flight check per 24 months (FOI) ½ day desktop (IO) “Continual oversight” Monthly meetings FOI’s x 3 AA = desktop Mark Swan to introduce these Invite Mark Bailey to say a few words

Update on the Transformation to Performance-based Regulation Performance-Based oversight (PBO) Single process for whole CAA Evidence-based Holistic safety performance assessment Subjective Oversight Manager and Sector Manager Mark Swan to introduce these Invite Mark Bailey to say a few words

Update on the Transformation to Performance-based Regulation Performance-Based oversight process Audits Accountable Manager Meeting Mark Swan to introduce these Invite Mark Bailey to say a few words

Update on the Transformation to Performance-based Regulation The Purpose of a CAA Regulatory SMS The purpose of the CAA Regulatory SMS is to ensure that the safety risks to the UK consumer in the total aviation system are being managed effectively and to provide assurance to the CAA Board that plans are in place to address those risk that are not being managed effectively. Mark Swan to introduce these Invite Mark Bailey to say a few words

Update on the Transformation to Performance-based Regulation How is it different to an Industry SMS? An industry SMS will focus on managing safety risks in their operations Our Regulatory SMS needs to understand: what the major safety risks are in the Total Aviation System and, whether or not the CAA has the capability or capacity to help the industry manage them, through: Safety oversight Safety Improvement Projects Changing regulations we control Influencing change to regulations we don’t control (EASA) Policies and guidance material Mark Swan to introduce these Invite Mark Bailey to say a few words

Sector Safety Risk Assessment ambition, framework & development approach What does the sector do? What hazards does it face? What’s its safety track record? 01 Sector Description Nature of the operation. Number of operators. Regional / airspace info. Operational volume / frequency. Passenger, flight crew and third party exposure. 02 Sector Hazards Summarise the sector’s top hazards. Describe the main threat factors. Describe the potential negative outcomes. 03 Control Effectiveness Summarise the sector’s performance in managing the hazards. Include safety performance metrics where possible? What is being done? How does this create safety risks? What are the gaps? 06 Action Plans Summarise the cross-sector action plans undertaken by industry to manage the risks. Describe the Regulator’s action plans to treat, tolerate, transfer or terminate the risks. Mark Swan to introduce these Invite Mark Bailey to say a few words 05 Risk Assessment Produce a sector risk assessment (aligned to the Total System risk scoring method) based on the exposure, hazard, performance and weakness information described in 01 – 04. 04 Weaknesses Assess the potential weaknesses in the sector’s safety performance. Provide supporting evidence where possible.

Rotorcraft Sector Description Onshore CAT Police & HEMS SAR Ops NCC SPO Offshore Mark Swan to introduce these Invite Mark Bailey to say a few words

Risks at the Rotorcraft Sector level - Competency Total CAA Findings 2013-2017 145.A.30(e) – 350 Level 2 findings M.A.706(h) – 7 Level 2 findings M.A.706(k) – 37 Level 2 findings Mark Swan to introduce these Invite Mark Bailey to say a few words Improving Supervision & Production Planning Implementing a Safety Culture& Ensuring Engineer Responsibility A31 Improving the Effectiveness and Adoption of Procedures/Processes/Task Cards Improving Competency Assessment / Training & Induction

Risks at the Rotorcraft Sector Level - Competency No process or procedure No competency assessment, lack of records Unclear what personnel could do Not all areas of activity assessed for competence No HF, continuation training, procedures training or competence assessment Growing scope of authorisation without competency assessment Assessment on paper only Not meeting the medical req’ts for E.g. NDT Light touch training and assessment – for important tasks (VHM) No follow up training – staff were not competent Lack of training Evidence of experience lacking or missing Not everyone assessed for competence E.g. Managers Improving Supervision & Production Planning Implementing a Safety Culture& Ensuring Engineer Responsibility Improving the Effectiveness and Adoption of Procedures/Processes/Task Cards Improving Competency Assessment / Training & Induction Mark Swan to introduce these Invite Mark Bailey to say a few words

Risks at the Rotorcraft Sector level - Part M sets up the Part 145 to fail Poorly managed AMP Poorly managed record system Part M personnel competency and number Part M oversight contracted maintenance Part M oversight sub-contracted activities Poor planning – unachievable workload Owners/lessor – arranging own maintenance Mark Swan to introduce these Invite Mark Bailey to say a few words

Summary - Next Steps PBR in progress Entity level performance PBO and RSMS Entity level and sector level Entity level performance Sector level performance A31 – data aligns to A31 Challenges Align with Flt Ops Keep valid and up to date Deal with the issues – Communication and actions Mark Swan to introduce these Invite Mark Bailey to say a few words

Thank you & Questions Mark Swan to introduce these Invite Mark Bailey to say a few words