An aviation company Operations Manual should be for the guidance of staff in the conduct of flying operations. However, public policy has changed to a place where regulators are extremely risk averse. Regulators try take an approach that limits their exposure to the possibility of any form of criticism in the event of an accident. The result is very prescriptive methods of compliance for regulation that is seen as ‘required’. In many instances, the safety case is slim… For example, the introduction of the new ATPL flight-tests.
Back to the topic though – A second purpose of the Operations Manual is a device that allows the regulator to regulate. The introduction of safety management systems has opened the way for risk assessments and hazard identification followed by the matching of procedures that address the risk in a way that gives the operation’s hazard profile as low as reasonably practicable [ALARP]. In theory, if an aviation operator has identified and assessed its risks and matched them with suitable procedures to bring the risk profile to the ALARP level, then the operator should be operating in a regime that is as safe as possible. Such procedures should satisfy the regulator because a risk level and the ALARP can be demonstrated.
However, CASA is in the cadre of risk averse regulators. As a result, a second we are yet to see an Operations Manual based on addressing the risk profile of the company. Operations Manuals required under Civil Aviation Regulation [CAR] 215 are ‘accepted’ as distinct from ‘approved’, despite the fact that CASA may give a direction requiring an operator to include particular information in the Manual. CASA publish a Civil Aviation Advisory Publication [CAAP] 215 that details how the suite of Operations Manuals must be constructed. Unfortunately, the current CAAP is very much aimed at the large airline and does not offer much to suit the small or mid-size aviation company. The difficulty of the CASA policy on Manuals is further complicated by the price attached to assessment. Any deviation from what has gone before is ultimately going to cost more in assessment fees. CASA’s approach stifles innovation in the process of satisfying the regulators whim to regulate through documentation.
The manual writing business moves with technology. So far, it has not moved to a web-based solution where there are choices of different sets of words that can be incorporated into a manual. However, there is a large body of work in Manuals that have previously been accepted by CASA that can be accessed through companies already in the aviation business. There are also generic Operations Manuals from industry consultants for bargain prices. These manuals generally cover all contingencies but tend to be far from how an operator would choose to operate efficiently. The content of manuals has been a cause of disagreement between CASA and operators for many years. It also leads to delays while CASA go through the process of ‘accepting’ manuals.
One of the solutions is in place with the Aerial Agricultural Association of Australia who has a Standard Operations Manual that has been authorised as a solution for a purely aerial application operation. It relies on a Schedule of Differences for particular features of individual operators. A similar approach could be used with flying schools but as the regulations become more detailed and prescriptive in approach, the possibility of a standard manual for other than aerial application becomes more remote.
What are the solutions?
The solutions to developing or maintaining an Operations Manuals are diverse. One of the keys is to match the manual to the operation. It is not much good having a manual that contains miles of information and procedures that are unlikely to ever be used. The best manuals are the ones that cover the operation with good, sound, risk assessed advice. There are basically three approaches – two of which are used frequently. They are as follows:
- Develop a manual with risk assessed procedures that absolutely fits the organization;
- Buy a generic manual;
- Cobble together a manual from information that has been obtained by intellectual beach combing.
We will discuss each of these three solutions in some detail.
Tailor Made – Risk Assessed
Developing a manual that absolutely fits the operation for which it is designed with procedures that are risk assessed is necessarily time-consuming and therefore the most expensive solution. The outcome of this approach is very much reliant on the skill base of the individuals developing the manual. It has the difficulty that the regulators who make the assessment on behalf of CASA may not necessarily agree with the opinions or the risk assessment process or that the approach gives a solution to the ALARP standard – The look and feel might be quite different from manuals that have been previously accepted. The regulators opinion may be formed by their own limited aviation experience before joining or the prevailing opinions within the regulator. As a result, the assessment process may be more expensive than otherwise would be the case for a generic manual.
Generic Manuals – One Size Fits All
Probably the worst solution is to buy a generic manual, which gets through the regulatory hurdles but does not reflect the operation. Accepting the generic solution will lead to a large procedures/practices gap and the possibility of individuals within the operator’s organisation making their own arrangements with the inherent risk and unpredictable outcomes. The mid-range solution is to take a generic manual and adapt it to the operations far as practicable. The question might well be asked; ‘if this is the worst solution, why does it get through the regulatory net easily?’ The reason is that the regulators are perhaps intellectually lazy and that they have seen the manual previously. While it may not reflect the way a particular organisation chooses to conduct operations, it does satisfy the regulatory requirements and shifts the ‘blame’ from the regulator to the operator for deviating from their stated method operating.
A well-used method of writing a manual is to borrow someone else’s, hopefully with his or her permission and adapt it to a new operation. Provided that the source information is good and it is truly adapted to meet the new circumstances, this method probably produces a reasonably good system for operations provided that the writer has the ability to pick out the relevant pieces. It has the advantage that the regulator may have seen the information previously and it may not be significantly different from the regulators expectation of what constitutes a reasonable manual. It has the downside that the procedures may not be risk assessed within the operation they are being utilised in. This is probably good place to start operations but continued work will be required on the manual to adapt and develop the procedures to a level where it can be demonstrated that the safety risk is to the ALARP level.Google+