Safety Spotlight: Just culture, safe skies

It would have been easy to dismiss the memo as bureaucratic pretense. In reality, the memo represented a significant change in attitude at the FAA. One that has been positive for general aviation safety, and an important part of the system that has brought three straight years of record safety performance. Today there are fewer than 0.84 fatal accidents per 100,000 flight hours. To put that in perspective, most general aviation pilots fly on average fewer than 75 hours a year. The GA community, in which the FAA plays a critical role, endorses a rigorous “even one accident is too many” mindset that has led to technological innovations, better training, and policy changes—such as the compliance philosophy—that have resulted in a continuous, steady decline in the fatal accident rate for decades.

The compliance philosophy is not in any sense a relaxation or softening of the standards. In fact, the compliance philosophy has resulted in more focus on adherence. The FAA has continued to take punitive action against willful, blatant, or careless disregard of rules, and FAA contacts with GA pilots, operators, and other certificate holders increased since the philosophy was implemented. A combined total of 5,854 actions were taken by the FAA in 2015. Following implementation of the compliance philosophy, the number of actions increased to 6,986 in 2016 and 8,243 in 2017.

The compliance shift meant that when deviations were observed, a focused, deliberate, and just response would ensue, rather than a knee-jerk reaction for punitive action. The compliance method strives to understand the deviation in context, the reasons for the error, and direct a response appropriate to the offense. Offenders are frequently required to undergo refresher training to update knowledge and skills, resulting in more knowledgeable operators across the national airspace system. Sometimes, ambiguity in policy is identified and corrected for the betterment of all, and both the pilot and FAA representative walk away more informed and able to communicate lessons learned.

Prior to the compliance memo, savvy pilots exercised caution in any conversation with the FAA, both airborne and on the ground. It was an “us versus them” mentality. Admitting a mistake, exposing an area of confusion, or expressing a need for better training was seen by many pilots as an admission that could prove damaging to one’s reputation, certificate, and career. Numerous important conversations were muffled at best, and, in some cases, avoided altogether. Under the compliance policy, pilots are less fearful of earnest conversations. Valuable exchanges can happen, even airborne, in critical situations where controllers and pilots share situational awareness and determine best courses of action.

The June 2015 memo references safety management systems, which have emerged as effective programs that provide overarching guidance and frameworks to help organizations implement robust safety programs. The first principle of a robust SMS program with teeth and effectiveness is a commitment by senior leadership to a strong safety culture. The foundation of a strong safety culture is transparency. Everyone in the operation must feel safe in reporting concerns, incidents, and especially in self-reporting mistakes from which others may learn, or that may over time indicate trends where new policies or new training is needed. Thus, the importance of the June 2015 memo. It was a critical statement that indicated the FAA truly was committed to its stated mission: “to provide the safest, most efficient aerospace system in the world.” The lead agency in the general aviation ecosystem was showing its commitment. Many of us raised an eyebrow in hopeful skepticism—did they really mean it? Time has proven they, in fact, did.

For safety practitioners, it’s difficult to point to the accident prevented, the life saved because of your efforts. But you can look at trends and know that, collectively, the efforts have had a positive impact. There are multiple layers and initiatives that contribute to the gains in aviation safety, and the implementation of the agency’s compliance philosophy is a key part of the success. The indicators are positive and keep getting better. The FAA’s compliance philosophy is working for GA safety.

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