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ASRR submission revealed in Sandilands article

The submissions that are to the ASRR inquiry, not being published by the ASRR. The most recent was by David Klein, personally placed on Ben Sandilands Plane Talking current post on the Hawaiian issue.

This is re-produced below:

David Klein

  • Posted April 17, 2014 at 11:44 am | Permalink

Ben, you are correct in commenting on the submissions to the Aviation Safety Regulation Review not being made available to the public being a form of suppression and for this reason my submission has been chapter and verse below:

AVIATION SAFETY REGULATION REVIEW SUBMISSION

As a retired front line CASA airworthiness inspector I wish to make a submission to the Aviation Safety Regulation Review panel based on my concerns for the significant shortcoming of the CASA regulatory oversight of Qantas. My experience as an airworthiness inspector from 1987 to 2008 involved over 10 years regulating General Aviation from the Bankstown airport office and another 10 years regulating Qantas with other regional airlines from the Sydney airport office. Unfortunately in my time there were a number of major restructures to the organization and from my observations it has only been the dedicated inspectors working at the coalface, despite ever changing politics and ineffective management of DOA, DOT, DOTC, CAA and CASA, that has kept the Australian aviation industry to even a reasonable level of air safety.

For many of my years working at the Sydney airport office I headed up the airworthiness inspection team to oversight Qantas and I found the limited resources and minimum unrealistic audit regime set by CASA management for the organisation almost beyond belief. At every endeavour when a head office manager from Canberra visited and engaged in an open question forum at the Sydney office I presented my concerns, as the head airworthiness inspector working at the Qantas coalface, but to no avail. After my retirement in 2008 I also made a formal submission to the Senate inquiry hearings on CASA management to again express my concerns regarding the lack of Qantas airworthiness audits, but from the information I have received recently the current regulatory oversight by the Sydney office may have been degraded even further.

As an example of my concerns, during my tenure at the Sydney office the CASA Surveillance Manual provided all airworthiness audit requirements, however the matrix in the manual to determine the size of a Certificate of Approval holder, which dictated the type and frequency of audits required was limited to a provision for either above or below 55 staff. There was no separate provision in the manual for Qantas with over 6000 engineering staff and this resulted in the minimum number of audits required in the manual being totally unrealistic for Qantas, given the massive scale of the organisation across Australia and it’s numerous overseas line stations. For the majority of my years at the Sydney office the total number of inspectors dedicated to the Qantas airworthiness team was only four, resulting in a very small audit sample of the organisation and most of the 24 Qantas overseas maintenance line stations rarely received an audit.

Also adding to my concerns is many of the Qantas audits and surveillance requirements took place at Sydney airport where the CASA office was located. Since my retirement the office at Sydney airport has been closed and all front line inspectors have been amalgamated with the Bankstown airport office inspectors to an office building in the Sydney Central Business District, as a CASA cost cutting measure to reduce overheads in administration. However as established in a 2012 Senates Estimates hearing the move into the CBD has been found to actually increase CASA costs.

The productivity now lost in travel to achieve the same audits and surveillance on each airport would be incalculable, not to mention the surveillance oversight benefits that are lost in not having a permanent CASA regulatory presence on site.

Trusting the members of the Safety Review Panel will give my submission due consideration towards improving the regulatory oversight performance and accountability of CASA under the “Safety related matters” terms of reference.

Yours sincerely,

David Klein

This is David’s submission to the 2008 Senate Inquiry:

The Secretary
Senate Standing Committee on Rural and Regional Affairs and Transport
PO Box 6100
Parliament House
Canberra ACT 2600
Dear Secretary,
Inquiry into the Administration of the Civil Aviation Safety Authority (CASA) and related matters

As a former airworthiness inspector, who retired recently from the Civil Aviation Safety Authority on 29 February 2008, after 20 years of service, I would like to make a submission to the subject inquiry, in relation to the regulatory oversight of Qantas Airways.
As an airworthiness inspector I was based in the Sydney Airline Operations office from November 1998 to February 2008 and for a majority of that time I was the principal CASA contact for Qantas in a team of four airworthiness inspectors, that reported to an Airworthiness Team Leader. During many of those years working at the Qantas coalface I attended various CASA forums attended by senior management and voiced my concerns about the unrealistic audit frequency level and very limited airworthiness resources being allocated in Sydney to oversight Qantas, as a Certificate of Approval (COA) holder in Australia and overseas.

Two of the most significant points of my airworthiness concerns with Qantas
Airworthiness oversight that were raised to CASA management at several forums were:

1. Qantas, as a CASA Certificate of Approval holder has over six thousand technical staff, an Executive General Manager, four Group General Managers, ten General managers and almost one hundred Line Managers. The CASA Surveillance Procedures Manual (SPM) compliance audit frequency requirement calls for only “one audit per year” for Airline COA holders with above 50 technical staff, which also captures Qantas with over 6,000 staff. I believe this was an attempt by CASA management to make “one size fit all” in the SPM, leaving Qantas with a totally inappropriate frequency level of airworthiness compliance audit, to meet the limited resources available in the Sydney office.
2. Qantas has around 24 overseas ports where aircraft line maintenance is conducted and is supported by it’s own engineers in less than half of those ports, with the remainder being handled by overseas agents. Due to financial constraints imposed on airworthiness overseas travel by management, barely 20% of the ports have been audited by CASA
in the past five years and total faith has been placed in the Qantas internal audit system for regulatory compliance. It should be noted that due to a number of significant CASA audit findings in the various areas of Qantas engineering maintenance locations, the rigor of their internal audit process has been reviewed.
In summary, after almost 10 years of Qantas airworthiness oversight experience, it’s my view that the level of COA audit and Sydney Airline Office airworthiness resources in terms of manpower and financial support are totally unrealistic, given the massive scale of the organisation with the logistics of travel requirements throughout Australia and overseas. The CASA introduction of Air Transport Inspectors to compliment airworthiness inspectors at Airline offices, with a focus of top level Safety Systems Management is not the ideal solution and a much greater oversight using on-site presence, with far more inspectors covering all Qantas maintenance locations is required.
Yours sincerely,
David Klein
06 June 2008