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ASRR submission breakup – Why the large number of confidential submissions??

A look at the submissions to the ASRR, show that a large number of people [over 31% one in three] did not want their material made public.

One can very confidently assume that these people are concerned about retribution by the regulator. This was a feature of the Senate AAI review as well, where this issue was ventilated on a routine basis, given the questioning by the Senators of Dolan – ATSB and McCormick – CASA.

This comes out throughout the ASRR report and can be best described as a disconnect of the regulator and the investigator with the industry.

In the ASRR report, a common theme was the frustration of the aviation industry, which is likely to negatively impact aviation safety.

During the inquiry, the Senate Committee became aware of:

  • Concerns about the internal management and governance of CASA, and the internal culture within CASA that, in some cases, struggled to adapt to the new Safety Management System (SMS) approach;
  • The high level of frustration within industry with CASA’s regulatory reform process;
  • Problems with inconsistent application of regulations across different CASA offices.

Some comments were as follows by the Forsyth committee:

  • Analysis conducted by the Review of a sample of past Regulation Impact Statements prepared by CASA (and approved by the OBPR) suggests that CASA does not appear to always take full account of the impacts on industry.
  • Consultation revealed a widespread view within industry that the ATSB’s 2009 report of the investigation into the Pel-Air ditching near Norfolk Island was sub-standard and failed to adequately identify and attribute systemic causes to the accident.
  • Industry’s views on the effectiveness of CASA are mixed. It was evident in the Panel’s overseas consultations that CASA is well-regarded internationally. While some domestic submissions and consultations did convey positive comments about the regulator, the majority of industry feedback was critical, with the suggestion that CASA has become more combative and heavy-handed in its regulatory stance over recent years. There was a common view that CASA does not communicate or engage with industry as constructively as it could.
  • The Panel noted the clear message that industry is dissatisfied with CASA’s performance.
  • In the Panel’s view, CASA is falling short of the standards it ought to attain, judged by the ANAO’s six principles. Based on industry’s perception, CASA falls short on Transparency and Openness, being seen by industry as closed to engagement. CASA’s Leadership also appears wanting, with a failure to translate good procedures and policies on paper into effective behaviours across the organisation. While CASA appears to be trusted by many in government, the industry’s trust in CASA is failing, compromising CASA’s Stewardship, and industry perceives CASA’s Accountability as being compromised.
  • Although a majority of submissions suggested that CASA’s relationship with industry has deteriorated recently, many acknowledged that they have good working relationships with some of the staff in their local CASA offices, but find it more difficult to engage with the management and leadership team of CASA.
  • Among GA and smaller maintenance operations, frustration was expressed that it is not possible for industry to easily reach a CASA officer who is knowledgeable about their industry sector.
  • The combative nature of the relationship between CASA and industry was illustrated by the announcement of, and reaction to, CASA’s decision to defer commencement of the new licensing suite: CASR Parts 61, 64, 141, and 142. However, the overall message in the media release was that industry was to blame for the delay in implementation.
  • While CASA is clearly aware of specific instances of industry dissatisfaction, it does not appear to fully comprehend the level or breadth of ill-feeling across all industry sectors. This lack of comprehension is especially apparent at the senior leadership level, including within the CASA Board.

In fact, the report says in it’s recommendations that:

8d: [CASA] adopts the same Code of Conduct and Values that apply to the Australian Public Service under the Public Service Act 1999.

and at 17:

The Civil Aviation Safety Authority publishes and demonstrates the philosophy of ‘just culture’ whereby individuals involved in a reportable event are not punished for actions, omissions or decisions taken by them that are commensurate with their experience and training. However,actions of gross negligence, wilful violations and destructive acts should not be tolerated.


21. The Civil Aviation Safety Authority changes its organisational structure to a client-oriented output model.

22. The Civil Aviation Safety Authority establishes small offices at specific industry centres to improve monitoring, service quality, communications and collaborative relationships

32. The Civil Aviation Safety Authority reassesses the penalties in the Civil Aviation Safety Regulations.

34. The Civil Aviation Safety Authority’s Director of Aviation Safety meet with industry sector leaders to jointly develop a plan for renewing a collaborative and effective Standards Consultative Committee.


The ASRR said of the PelAir report:

The Panel considers that the Pel-Air report was an aberration, and not typical of the high standard that the ATSB usually attains. The Panel recognises that the ATSB is putting measures in place to prevent a reoccurrence. To improve the ATSB’s governance, the Panel recommends that an additional Commissioner be appointed, with extensive aviation experience.

In fact, careful diagnosis of ATSB reports show there have been serious concerns of both interference with reports and odd results since the discredited Whyalla report. It is a real concern the ASRR could come to the conclusion that this is an “aberration”, given the Senate’s careful analysis of what happened.

The Senate exposed interference with the reports process and development.

The following is a breakup of the submissions to the Forsyth ASRR:


asrr june 13th 2014

There are 15 days left to 30th June to advise Minister Truss that he must implement all the Forsyth findings and go further to ensure the aviation industry remains a viable and safety consious industry as it [in fact] is and has been in the past, but unlikely to be if the “fixes” are not made now.

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