AOPA Turbine Pilot Magazine - July 2018 - 26

SAFETY SPOTLIGHT

Just culture, safe skies
How a compliance philosophy encourages safety

RICHARD MCSPADDEN

is a commercial pilot
and CFI with more
than 4,500 hours.

26 | AOPA PILOT July 2018

IN A JUNE 2015 POLICY MEMO, the FAA communicated
a pivot to a new compliance philosophy, where its
approach to rules enforcement would focus on identifying and fixing the underlying safety concern, and
then directing what it called "compliance action." The
policy expressed the FAA's commitment to a "just culture" with an "expectation of and appreciation for
self-disclosure of errors."
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

BY RICHARD MCSPADDEN
Executive Director
AOPA Air Safety Institute

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. AOPA
EMAIL richard.mcspadden@aopa.org

AOPA Turbine Pilot Magazine - July 2018

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