UK CAA Performance Based Regulation Conference · • Our new owners took over in June 2012 - $1.2...
Transcript of UK CAA Performance Based Regulation Conference · • Our new owners took over in June 2012 - $1.2...
UK CAA Performance Based Regulation Conference Gatwick Hilton May 19th 2014
Agenda 10.00 – 16.00
10.00 - 10.10 Welcome, introductions and agenda review Mark Swan
10.10 - 10.25 Keynote speech: Performance based regulation Andrew Haines
10.25 - 10.45 The EASA ambition for performance based safety regulation Trevor Woods
10.45 - 11.00 The UK CAA’s transformation to performance based regulation Ben Alcott
11.00 - 11.20 Panel discussion and questions Andrew Haines (chair)
11.20 - 11.40 Morning Break
11.40 - 11.55 An airline operator’s perspective Garry Copeland
11.55 - 12.10 An airport operator’s perspective David Wilson
12.10 - 12.25 An ANSP (CANSO) perspective Jeff Poole
12.25 - 12.40 Integrating ground handling Kirsten Riensema
12.40 - 13.00 Panel discussion and questions Mark Swan (chair)
13.00 - 14.00 Lunch
14.00 - 14.45 Working Sessions – Benefits and Challenges CAA Facilitators
14.45 - 15.00 Afternoon Break
15.00 - 15.45 Plenary discussion and questions – Benefits and Challenges Mark Swan (chair)
15.45 - 16.00 Closing presentation Mark Swan (chair)
16.00 – 17.00 Afternoon Tea Reception
Keynote: Performance Based Regulation Andrew Haines Chief Executive CAA
The EASA ambition for performance based safety regulation
Trevor Woods EASA, Approvals and Standardisation Director Gatwick, 19 May 2014
Evolution of Safety
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Technical Factors
Human Factors
Organisation Factors
Considerations for the Future
Economic Pressures Air Traffic Growth New Technology New Business Models (multinational) Cooperative Oversight (EU/BASAs) Environmental Pressures Security Precautions Etc..
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“...improve the performance of the European aviation system with regard to safety, competitiveness, environmental protection and quality of air services provided to citizens, by setting appropriate regulatory framework.”
Ref: EC doc: “Policy initiative on aviation safety and a possible revision of Regulation (EC) No 216/2008…”, 26 March 2014
Commission Policy Objective
Layers
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ICAO
EU/EASA
National AA
Organisation
Performance Based Environment
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Safety Performance Measurement and Risk Assessment at a Total System level
Enablers for PBE
Data Driven Decision making based on SPIs*
Mature Safety Management Systems and State Safety Programmes Information Sharing Cultural Change Authority and Organisation Requirements Responsibilities and Enforcement Resources Common Terminology.
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* SPI: Safety Performance Indicator
Prescriptive Rules vs PBR
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PBR focus on achieving desired performance Improved understanding of risks Identification of mitigations Better targeting of resources Flexibility We need a mix of both.
Prescriptive Clear minimum Captures lessons from
history Interoperability Simple philosophy
Risk and Performance Based Oversight
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Relies on SPIs and PBRs
RBO: focus on risk PBO: focus on overall performance
Compliance Effective Compliance
Relies on available information
Continuous Monitoring
Organisational Risk Profile
Surveillance Interval /Target
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EASA Regs, SMS and RBO
Domain Reg./NPA/RMT SMS
provisions?
RBO provisions
?
ATM Reg. 1035/2011
Aircrew Reg. 1178/2011
Air Operations Reg. 965/2012
Standardisation Reg. 628/2013
Aerodromes Reg. 139/2014
Continuing Airworthiness (M/145) NPA 2013-01
Continuing Airworthiness (66/147) NPA 2019-19
Initial Airworthiness MDM 060
Reporting 376/2014 (from 15/11/15) Reg. 376/2014 Feed Feed
Example “Horizontal Rules”
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Authority Requirements NAA oversight programme to account for:
specific nature of the organisation complexity of its activities, results of oversight activities based on the assessment of associated risks
Oversight cycle may be extended (max 48 months) if: the organisation has demonstrated an effective identification of aviation safety hazards and management of associated risks
Organisation Requirements identify safety hazards evaluation, management of associated risks, verify effectiveness.
Occurrence Reporting Regulation
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Report
•Just Culture
Competent Authority
ECR
EASp
Network of Analysts
SSP
Key Ingredients
SMS/ Reporting SSP/ PBO PBR/ Standardisation ICAO Annex 19
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ICAO
EU/EASA
National AA
Organisation
•ECR •Network of Analysts •Reporting Culture •EASp •SPIs •Mix of Prescriptive and PBR.
Thank you for your attention
Additional Slides
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Standardisation Model overview
Time Elapsed
Output Levels
Determine
frequency and
scope of
inspections
Follow-up Indicators
Authority Indicators
Safety Indicators
Activity Indicators
1 100
0
Other
EASA
Authority
Data input Rating calculation Overlay indicators Output validation 2 3
A B C D
General Indicators
SIS
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•ANALYSE AND
PRIORITISE
•ACT AS APPROPRIATE
•FOLLOW-UP
•COLLECT INFORMATION
•Web-based •interface
•(Multi)annual •Programme
•The Model
Comprehensive Inspection
Focused Inspection
Ad Hoc Inspection
Off-site Finding
Continuous Monitoring
Status
New Risk Based Approach for Assessing Authorities [628/2013]
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Reorganisation of EASA
•Organisation setup based on the following principles: • Robust Product Safety function (integration of Certification and Rules);
• Strong Safety Oversight function (integration of Rulemaking and Standardisation); • Data driven Safety Strategy function; • Customer oriented administrative function;
• New Structure:
• Executive Directorate • Certification Directorate • Flight Standards Directorate • Strategy and Safety Intelligence Directorate • Resources and Support Directorate
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Delivering Performance Based Regulation in the UK Ben Alcott Enhancing Safety Performance CAA Programme Director
Transforming the CAA to a performance based regulator
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The drivers for performance based regulation
Transforming the CAA to a performance based regulator
The operating environment
The regulatory framework
The need to maximise opportunities from Industrys’ SMS
Delivery of the better regulation agenda
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What does CAA’s transition to performance based regulation mean in practice for you?
A holistic, “entity” based approach
Targeted, consistent, and proportionate oversight
New conversations based on risk and performance
Transforming the CAA to a performance based regulator
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Safety Review Board Safety Action Group (SAG)
Data Information Decisions Prioritised and Proportionate Actions
CAA Capability Areas
Industry Sectors
CAA Executive and Board
• Entity & Sector Risks • Better Regulation Opportunities
2. Safety Management 2 External information
3. Strategy and Governance 3 • Feedback and Direction
Industry challenge
1. Performance Based Oversight 1
Key Processes for the CAA
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The next two years……
Jan 14 Apr 14 Jul 14 Oct 14 Q1 (’15) Q2 (’15) Q3 (’15) Q4 (’15) Q1 (’16) Q2 (’16)
90 AOC led Entities Fixed: Phase 1
60 Helicopter Led Entities: Phase 1 Flight Ops led
Entities
50 EASA Aerodromes and 30 additional to be rolled out over 15 months
ANSP led entities (numbers/schedule to be determined in Feb)
AW led entities (numbers/schedule to be determined in Feb)
90 AOC led Entities Fixed: Phase 2
60 Helicopter Led Entities: Phase 2
Planning
Proportionate involvement; e.g. adoption of ESP principles
Entity Groups
Aerodrome led Entities
ANSP led Entities
Airworthiness led Entities
Other (GA, CPG, PPT).
Two year Deployment Schedule
Bus
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s ch
ange
driv
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SP
Pro
gram
me
Develop and implement Internal SMS (phase 1)
Developing and deploying the next generation of the tools to enable PBO ways of working Influence
tech roadmap, planning
IT Tools Project
Enabling the above rollout…
Mature SMS developing (Phase 2 assessed) Internal
SMS
Transforming the CAA to a performance based regulator
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Our Vision
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.
Transforming the CAA to a performance based regulator
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Thank you for your attention
Transforming the CAA to a performance based regulator
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Panel Discussion and Questions Chaired by Andrew Haines Chief Executive CAA
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Break
20 minutes
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An Airline Operators Perspective Garry Copeland Managing Director UK Operations British Airways
CONFIDENTIAL - Seasonal Readiness
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CONFIDENTIAL - Seasonal Readiness
• The aviation industry has traditionally relied heavily on auditing to deliver oversight, compliance, product quality and safety.
• Conventional auditing will likely remain a component of the oversight toolbox
• Conventional auditing at or beyond the limits of usefulness in continuously improving safety and performance
• As the industry strives to continuously improve
performance, conventional oversight processes giving repetitive, low level, findings drive an environment of preoccupation, distraction and complacency.
A tool at its limits.
CONFIDENTIAL - Seasonal Readiness
A burden beyond effectiveness?
• BA experience: • 'Its big, so it's got to be risky! • 'No one else's audits are good enough' • 'If all the boxes are ticked, it must be all right'
• In 2013: • External audits: 8 ACAM, 17 CAA, 5 foreign regulator, 109 SAFA • Internal audits: 82 physical, 53 desktop, 254 ARC's, 17 safety culture Zero level 1 findings, 117 level 2, 77 level 3 Generated 597 ASRs, 281 MORs
CONFIDENTIAL - Seasonal Readiness
Good or bad?
• BA experience based on: • 280+ aircraft of seven major types • Part M, Part 21, Part 145, Part 147, Flight
Training Organisation. • 250,000 cycles per annum • 362,000 flight hours PA. • 1,745,000 Engineering load hours ASR rate of 1.4/1000 hours MOR rate of 0.7/1000 hours How does we and the regulator use data to access and address risk?
CONFIDENTIAL - Seasonal Readiness
Technology and quality assessment?
• New generation aircraft and supporting ground technology
• Can audit be effective? • How do auditors stay current and
know what the risk areas are? • Do we know how increasing
automation and information integration will influence future risks?
• What information will guide us?
CONFIDENTIAL - Seasonal Readiness
Raising the bar and dealing with the future
• Conventional audit won't disappear, part of a risk based oversight tool kit • Intelligent and skilled use of data to identify and address risk • Huge challenges as technology evolves and drives different risks. • Huge need for constant skills development and familiarity with current
challenges and risks, not perceived risks based on out of date experience
• Paradigm shift will require knowledgeable and skilled people working in an open, collaborative environment
• Legal responsibilities of accountable managers and regulators will not go away.
• We welcome the opportunity to have a true Performance Based Regulation and oversight debate.
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An Airport Operators Perspective David Wilson Chief Operating Officer Edinburgh Airport
Facts and Figures
• We are the 5th busiest airport in the UK. • Our new owners took over in June 2012 - $1.2 billion.
• 9.8 million passengers in 2013. • Voted “Best European Airport: 5m - 10m Passengers” at the 8th
Annual ACI EUROPE Best Airport Awards for the third year in a row.
• 43 airlines – 130 destinations. • New long haul routes and growing with
existing customers.
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Voted Europe’s Leading Destination at the World Travel Awards 2012. Source: World Travel
Awards 2012
Voted Best UK City in the Guardian, Observer and guardian.co.uk Readers’ Travel Awards. Source: Guardian
The population of Edinburgh is expected to grow 10% by 2025. Source: Office for National Statistics (2010)
Source: ETAG Key Figures 2012
Edinburgh – the city • Scotland’s capital, home to half a million people.
• The UK’s largest tourist market outside London, over 3.69 million people visit the city annually – 2.35 million from the UK, 1.34 million from overseas.
• 41% of visitors to the city arrive by plane.
• Host of the largest annual ticketed event in the world world’s largest arts festival - almost 1.9 million tickets were issued for the 2011 Edinburgh Festival Fringe.
Growth Plans
• Flights to and from Edinburgh are expected to increase by 25% in 2020 carrying 29% more passengers than in 2014.
• £150m investment in the next 5 years.
• Introduction of Advanced Airfield and Airspace Management Concepts.
1. Loss of Control
2. Runway Excursion
3. Controlled Flight into
Terrain
4. Runway Incursion
5. Airborne Conflict
6. Ground Handling
7. Fire
CAA Significant 7
Significant Number CAA Response EAL Response
1. Loss of control
2. Runway Excursion
3. Controlled Flight into Terrain
4. Runway Incursion
5. Airborne Conflict
6. Ground Handling
7. Fire
CAA Significant 7
Performance Based Regulation
Less:
• Ticking Boxes.
• ‘One size fits all’ type rule making.
• Over compliance with European regulation.
More:
• Commercial Awareness.
• Focus on the significant risks – by sector.
• Sharing information and best practice.
Increase Effectiveness
• Focus safety management on the most important risks to our customers.
• Develop robust safety cases for advanced operations (e.g. reduced spacing via PBN).
• Gather and share information and good practice across the sector.
Increase Efficiency
• Use evidence to find the most cost effective way of mitigating key risks.
• Reward good performers and target oversight towards poorer performers.
• Track the costs to airports of regulation and look for ways to reduce them.
• Overall cost of operation matters and is uncompetitive in the UK.
• APD increase from £12 to £14 per passenger.
• Business rates are increasing……..£1 dep passenger
• Policing costs are increasing………£0.50 dep passenger
• CAA – Security charges
APD and cost of regulation
• The start of a more collaborative approach to enhancing safety.
• Less pass and fail, more targeting of resources to risks.
• More provision of intelligence to support Edinburgh to grow safely and efficiently.
• Recognition on the cost of regulation and taxation.
Conclusions
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An ANSPs (CANSO) Perspective Jeff Poole Director General CANSO
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Integrating Ground Handling Kirsten Riensema GHOST Sponsor CAA
Integrating Ground Handling into the total system risk and performance based oversight
GH is a significant part of industry overall performance
What is the Risk? • Severity x probability • Potential impact • Safety culture not as
mature as other sectors
How are we performing? • Evidence that reporting is
low • Are we measuring safety
performance as well as other KPIs?
• Do we actually understand our performance?
What is the size of the risk?
Improvement in reporting But not across the board
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Operator GH
Operator Operator Operator Operator Operator Operator Ground Handler
(GH)
Operator Operator
Pro
po
rati
on
of
Lo
ad
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Err
or
rep
ort
s re
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Top 10 De-identified Reporter for Jan-Mar over Five years
2009 Q1 2010 Q1 2011 Q1 2012 Q1 2013 Q1
Accountable Managers: Should you be concerned?
• Is there a Just Reporting culture in your Ground Handling activities?
• Do investigations determine root cause? • Do your teams fully understand the balance
between safety and punctuality? • Have we done sufficient to make ourselves aware
of the right information, or is ignorance bliss?
• Direct regulation of Ground Handling? • Via our current oversight of Airports and AOCs? • Improve integration of GH/Airport/AOC/ATM
safety management? • Combined metrics, leading to targeted campaigns? • Location specific entities?
How can we include GH in Performance Based Regulation?
Panel Discussion and Questions Chaired by Mark Swan Group Director Safety and Airspace CAA
• Three Breakout Groups in separate rooms
• Delegates allocated at random
• Identified by badge colour
After Lunch Working sessions start at 14.00
Lunch
1 Hour
Working Sessions: Benefits and Challenges CAA Facilitators Breakout Rooms
Break
15 minutes
Plenary Discussion: Benefits and Challenges Chaired by Mark Swan Group Director Safety and Airspace CAA
Closing Presentation Mark Swan Group Director Safety and Airspace CAA
Rules introduced by EASA set the context for the UK’s transformation to Performance Based Regulation.
Conclusion EASA Pivot to Performance Based Regulation
The new rules are driving a move from:
• compliance based activities over entities we traditionally regulates; to
• Target all areas that represent a major safety risk to passengers and the public;
• Which requires a risk and performance based approach across individual entities, sectors and the total aviation system.
Conclusion UK CAA Transformation Programme
Two year Transformation Programme is in the Deployment Phase. CAA is working with Industry to generate four key outcomes:
1. Demonstrably improve levels of aviation safety in the UK and of UK entities operating globally
2. Ensure all regulatory policies and actions are proportionate
3. Coordinate industry participation in safety improvement initiatives
4. Improve the value for money of Safety Regulation/Management
The safety regulator’s business is to relentlessly interrogate two key questions 1. What safety risks does aviation pose to the UK passenger and general public? 2. Are the risks being managed effectively?
Next Steps Outputs and Feedback
• Post conference eSurvey circulated tomorrow – please provide your feedback, its hugely valuable.
• Draft report describing the outputs of the conference for review and comment (June-6th).
• Deadline for feedback on draft report (July 4th).
• Final report incorporating delegates comments published on the CAA’s website (August 1st).