Speech by Steve Douglas, Director of Civil Aviation
Aviation Industry Association Conference Auckland
20 July
2007
Thank you for that introduction Rick, and good afternoon ladies and gentlemen.
I am pleased to have this opportunity to speak before so many key members of the aviation industry so early in my tenure as the Director of Civil Aviation.
This conference has for many years been an important fixture on the CAA’s annual calendar. Each year several CAA staff members commit the time to attend, and I have been pleased to contribute to it myself over the years.
I consider the AIA to be an important organisation, giving voice to a significant cross section of the aviation industry. Commercial aviation has been a feature of the early development of New Zealand and today it is key to our country’s economic success. A feature of our industry today is its diversity and innovation.
As Rick has said, I have been with the CAA for a long time, combining a technical background with management experience. During that time I have been part of the development of the CAA and its safety policies and systems. I intend today to reflect a little on that experience, and on some of the factors that have most significantly affected the way we manage aviation safety in this country today, and on the direction and priorities that I intend to set for the CAA from now on.
The most significant changes, of course, began in 1990 with the acceptance of the Swedavia McGregor report, the passing of the Civil Aviation Act, the beginning of the Civil Aviation Rules rewrite project, and the recertification of participants under the new Rules.
The regulatory model adopted by New Zealand is soundly based, and it has stood the test of time. My international relations experience has shown that there are three main elements to achieving mutual recognition agreements with overseas authorities. These elements are:
the regulatory system and its backing in legislation and rules, the performance of that system and the levels of safety achieved under it, and the relationships formed by the regulator.
I have already acknowledged the strength of our system, and as New Zealanders we have an easy ability to create good working relationships at all levels. It is the middle element – the performance of the system – that I will be paying attention to during my tenure as Director. This is the area where I believe improvements need to be made to ensure that the system operates in the intended way.
There have been a number of reviews of the CAA conducted over the last few years, some quite critical as you know.
The Auditor General and the Christchurch Coroner have criticised the way the CAA carried out its certification and monitoring roles.
And the ICAO audits in 2006 concluded that while our system is a good one, with strong and positive relationship with the industry, there is work to be done by the CAA to improve consistency and levels of performance.
In recent times, the CAA has been criticised for being too close to industry, and of having become overly reactive. I believe that this is true, and that it has been to the detriment of the CAA and to the aviation system as a whole.
The public wants a competent and effective safety regulator that will act in the public interest. It must be seen to be free of undue influence exerted by the industry that it regulates or any sector interest. From time to time the CAA must hold the industry to account for performance that falls below an acceptable level of safety, and this is what the public and parliament expect of us.
The industry today is in good shape. Activity is increasing and accidents are decreasing. So my changes are to shift emphasis and to re-prioritise, to make adjustments to improve the operation of the system and ultimately the levels of safety achieved under it. Much good work has been done, and is being done by the CAA and the aviation community and I want to build on that.
Since becoming Director, I have set out my programme and priorities for the CAA to our staff. My first priority as leader is to provide clear direction and a sense of purpose to the organisation, and this task is underway.
My intention here today is to provide you the industry with the same clear picture of my expectations and guiding principles.
The CAA’s primary focus is the safety achieved in the civil aviation system. For the CAA and everyone who works there it means having a clear understanding of what our job is, why we do it and who we do it for. Our customers are the travelling public and all who use the services the aviation system provides.
As regulator, the CAA must ensure that only those organisations that fully meet the safety requirements set by the Civil Aviation Rules are allowed to operate. It is also in your interest that this is so.
I want to emphasise the importance of the CAA’s core functions of entry certification and safety monitoring, and to ensure that we do them well. The most important of these functions in my view is entry control. It is at the entry control stage, more than any other, that the participant’s, as well as the CAA’s attitude to compliance is most clearly demonstrated and future behaviour is set.
There is plenty of evidence that the CAA’s entry certification processes need to be more rigorous. If an applicant does not meet all the requirements at entry into the system, it will be more difficult to do so once operations commence. My message to our operating groups is that if full compliance has not been shown the applicant is simply not ready to enter the system. CAA staff know they have my full support when it becomes necessary to hold that line.
Over the last year the CAA has been working on three major projects that will enhance the CAA’s functions of certification, surveillance, and risk assessment. These projects are designed to increase the efficiency of these processes including the use of new technology to capture information and data in the field.
In parallel with this I am advocating a shift in approach when it comes to the conduct of audits, to increase the effectiveness of audits as a safety monitoring tool. The routine audit and inspection should be the primary source of information about the state of compliance of individual participants, and ultimately of the safety of the system. There are a number of factors at play here. However that requirement cannot be satisfied by an audit of a medium sized organisation conducted by one CAA auditor in half a day. I am discussing with the operating groups ways to increase the effectiveness of audits, including longer duration visits involving larger audit teams. Such an audit conducted once in 2 years will be far more useful than two ineffective audits in the same period. The CAA’s risk assessment systems will be used to determine which organisations should be visited first.
I have also signaled that in order for the CAA to meet its strategic objectives it needs to make much better use of the safety information it gathers. The way the CAA collects, manages and uses safety information will determine how well it can do its job.
In the past, the end use of the data has tended to depend on how it was collected, and by whom.
We are now looking closely at how we gather information, analyse it and then act upon it. In future these activities will be guided by clear policies, rather than structural or other artificial boundaries, to ensure that the CAA has available to it the most complete information on which to base its regulatory actions and decisions. Those safety information policies will progressively be published on the CAA web site as part of my commitment to openness and transparency in our relationship with you.
Recent changes to the CAA organisation structure will bring together regulatory functions in a way that is consistent with these policies and strategic objectives.
The new structure, which came into effect this week, is fundamentally similar to what you have known most recently. The three main operational groups remain the Airlines Group, the General Aviation Group, and the Personnel Licensing and Aviation Services Group, with the latter including the aviation security team and a new addition – the Health and Safety in Employment Unit.
A change is the creation of a new Safety Information Group. This Group will include the functions of safety investigation, enforcement investigation, safety analysis and communications and safety education. The bringing together of these functions in one group and the clear policies governing them will ensure the CAA collects and uses safety information more effectively for its safety purposes.
Two other groups are the Business Support Group, headed by Tim Bowron, and the existing Government Relations Group which adds the business planning and reporting activity.
No address by the CAA – or me for that matter – would be complete without mention of Rules.
The new rules process is now well established and the various participating groups, notably the Aviation Community Advisory Group, are settling into their work. The CAA recently shared with ACAG some charts showing rules output over the last seven years – the size of the programme, the number of new projects added each year, and the project milestones achieved in each year. While the charts show an upward trend in Rules output it is our aim to lift this output significantly over the coming years.
The principal brake on output is lack of resources at the CAA. I don’t mean money - but people to do the job. The CAA has had difficulty recruiting suitable Rules Project staff over the years and still does. We are competing in a marketplace that contains fewer and fewer people and our operating groups report the same difficulty. No doubt you do too in your industry sectors. This is a problem that we will have to solve to allow a necessary improvement in performance.
I have also set the CAA’s relationships as a priority issue. Establishing and maintaining good working relationships is so very important because, ultimately, that is how things get done.
Each of us, the CAA and the industry participants operating in the civil aviation system, has our own role to play in achieving safety in the system. Those roles are different, but complementary. Neither the CAA nor industry has all the information required to address safety issues, so we must collaborate to achieve safety improvements – in the development of Rules, through safety education and information programmes, training, and the investigation of safety issues. There are many excellent examples of that cooperation in our daily interactions with our industry clients, including the sessions held during this conference.
In signalling more focus on the entry and monitoring functions, I am pointing up the importance of the CAA’s relationships with its industry clients. It is vital, though; that these relationships are based on a mutual understanding of the different roles we each play. While our staff members routinely provide support to participants, in the form of information and advice, the CAA is not in the business of assisting organisations to limp through the system if they are not willing to shoulder their responsibility for operating safely.
The CAA will also continue to work hard to be competent and reliable in our relationships with the Minister, parliamentary select committees, and the public.
Our relationships with these stakeholders are important because they provide the basis for cooperation and assistance when assistance is required to address regulatory issues outside the control of the regulator. Examples are legislation and transport policies that affect how the aviation system operates.
I have outlined to our staff the three values I will promote in all our dealings as a regulator.
These are independence, integrity and professionalism. I have called for openness and honesty in all dealings, both internally and with the industry. I expect all staff members to support their colleagues by taking individual responsibility and by doing their jobs well.
Much has been made of the importance of an aviation safety culture. And rightly so in my view. I believe that this safety culture must be evident within the regulator. I want everyone to see the CAA as an organisation that does what it does for the right reasons and where the core values of the organisation extend to every member of the staff. I want that to be the basis for the way we interact with the industry, and I would expect no less in return from you.
Internationally, our reputation is excellent and well established. This is evidenced by the number of mutual recognition agreements that have been concluded in recent years, some of them quite unique:
In 2006 we signed a revised Airworthiness Agreement with the United States Federal Aviation Administration that accepts repair designs approved under the New Zealand system and some modifications to large aircraft. The airline AOC mutual recognition arrangement with Australia has come into being, and a New Zealand operator is already operating under the arrangement in Australia. Last month I signed a full Technical Arrangement on Maintenance with Transport Canada that covers maintenance activity under a Part 145 certificate. The CAA will be talking to industry shortly to provide details of the new Arrangement.
New Zealand’s international status as a safe place to fly was recognised in the announcement last year by the Flight Safety Foundation that Oceania, – Australia, New Zealand, and the Pacific Islands – remains by far the safest place in the world to fly on a large airliner.
But improvements must be ongoing. A project was begun last year to determine what resources and capabilities the CAA is likely to need in the future, and to identify any shortfalls. The first phase of the project concluded that work needed to be done to ensure resources are more appropriately allocated to support the strategic direction and priorities of the CAA. Improvements are being made in this direction first before considering detail funding and resource requirements.
I would like to end this presentation by reiterating Rick’s words this afternoon. I have been given a clear mandate by the Authority to lead the CAA. I intend to do this, with the support of my Executive and with your help, to the best of my ability.
I look forward to continuing a productive and rewarding relationship with industry in the interests of aviation safety.
Thank you very much.