“Just what constitutes the problem is an area of contention, though…”
Just Culture and the Role of Accountability
Benjamin J. Goodheart
Aviation Business Journal
3rd Quarter 2018
While the fundamental objectives in the culture that aeronautical organizations must undertake to achieve efficiency and effectiveness in their organizational safety, which I already demonstrated in several of my previous publications, let us also review the executive culture that we develop in the Approved Maintenance Organizations (AMOs).
The pillars of Positive Safety Culture
That culture that gently breezes and directs all of us toward part numbers, ladders, benches, corrosion levels, problem solving, constant and (sometimes) inevitable resource cuts, as well as seeking technical expertise, knowledge, and qualifications to “release” the aircraft into service. These constitute our executive strengths, which are far from those managerial in many AMOs, since the main thing is to issue the Maintenance Conformity Certificates (CCMs) and return the aircraft to the flight line. There are no requirements that would define culture in the AMOs, except that now ICAO’s Annex 19 and Part 145 establish the concept of Positive Safety Culture. The latter mentions such a culture only once and very briefly and without much light on the matter. This has been the case for years in Maintenance Organizations and the operational context does not deserve much reflection regarding the requirement of culture in the AMOs or, in any case, no preparation or planning. The objective is to complete the tasks required by the job cards, to sign the logbook (or RTV), to issue the CCMs, to fill out the electronic forms of the application contracted by the air carrier and to deliver the aircraft to operations of the airline.
Let’s take a view back to make a regulatory review or Statement of Compliance project to focus on this foundation: The Culture, which we have not typically identified to make up an organization that is going to deal with technical issues and requirements and make their own business decisions in this environment: (i) people qualified to carry out planning and maintenance tasks, including the necessary training, (ii) equipment and the controls to manage them including calibration carried out by qualified entities, (iii) facilities to carry out the maintenance tasks, and (iv) the technical documentation required to perform the tasks and return the aircraft to an operational status equivalent to that under which the manufacturer received the type certificate and put it on the market.
What is then the executive culture in the AMOs? Such a culture is featured by the absence of managerial fundamentals and resources to the detriment of technical activities and requirements or to enhance the latter, because it is thought (or considered) that there is no need for other types of requirements but of a technical nature. And if they were in the mise en place and earlier in the planning of the AMOs’ operations, we would avoid re-processes, lose fewer resources, optimize management, better orient ourselves towards objectives and be able to render better services in both the quantitative and qualitative fields. That is to say, would we stop losing or would we start winning with rationality and in balance with quality and safety? The answer is obvious, although always hidden by all the activities that are undertaken in the AMOs: The option lies in not being satisfied with losing as little as possible. We must aim to build profitable businesses, based on effectiveness, efficiency, objectives and monitored goals and with decision making that lead the AMOs towards continuous improvement.
In this way, the technical resources, as established in RAP Parts 43 and 145, are starring in aircraft maintenance management and not only in our country. Another aspect of the aviation culture of our country (and others) that wants to take the cake and even the biggest prize can be graphed with the question: Is this a regulatory requirement? Yes, considering the level of regulatory burden and how it has shaped the culture in aviation, this question seeks not only the requirement but also defines the resources and, in some cases, avoids them in the absence of clear and specific requirements, such as the case of what is established in RAP 145.205(a)(2)(i) which prescribes that “the safety policy must reflect the AMO’s commitment to safety, including the promotion of a positive safety culture”.
And now we have to deal with an unknown or little-known fundamentals for AMOs. What are the components of this positive culture that should be fostered? This question leads us per se to the main question, is this a regulatory requirement? of the aviation regulatory culture. We do not find the requirements of this culture until they appear in ICAO’s Annex 19 and the Fourth Edition of ICAO’s Document 9859.
What do the regulations tell us? Let’s see: “A positive safety culture relies on a high degree of trust and respect between personnel and management. Time and effort are needed to build a positive safety culture, which can be easily damaged by management decisions and actions, or inactions”. This statement, prescribed in paragraph 3.2.4 of the Fourth edition of ICAO’s document 9859, implies a two-way traffic between management and staff where the aforementioned respect does not alienate production conditions and upsets the relationship as little as possible, along with the trust that must exist between both levels and, when this happens, negatively influence the final product as little as possible: The quality that will produce safety in operations.
Taking into account that ICAO’s Annex 19 does not define what a positive safety culture is, we wonder how this type of culture is configured. Making a comparison between the aforementioned ICAO’s Annex 19 and the fourth edition of ICAO’s Document 9859, we find its three pillars: (i) Personal and organizational commitment, (ii) Sharing safety information, and (iii) Safety reporting encouragement. Being able to identify these pillars, aiming to achieve them, and measuring the effectiveness of the processes to fulfill them will constitute a true way of generating a positive safety culture, of a functional nature, that achieves a balance between production, its conditions and safety without this balance being neither invasive nor pretentious, so that the AMO is able to fully comply with its Capability List, because it has the necessary resources (equipment, people and processes), based on the provisions of RAP 145.125 and to be able to render services by virtue of which there is a proactive identification of hazards and consequences, and the investment made to comply with the safety policy and objectives of a RAP 145 AMO. Let us develop these three pillars in the AMOs and the idea or foundation on positive safety culture will not only be very clear, but will produce qualitative, safe and profitable organizations.
