Let’s start with all due sympathy for all staff that had to work on the principal festive dates due to shift cover; the travelling public will no doubt be forever grateful. The New Year date change and a fresh year ahead means the restart of all the annual projects that a maintenance operation must consider: 2023 shelf-lives and calibration dates may have seemed a long way off towards the end of last year but some may now be imminent.

This year’s Recurrent Training also needs to be scheduled, hopefully with an inspiring instructor and not mind-numbingly boring CBT based on old familiar examples. As an example, Dangerous Goods Training needs to reflect the ICAO Technical Instructions (TI) using a Competency Based Approach to Training and Assessment (CBTA) and is now a mandatory requirement for those involved effective 1 January 2023 (see UK CAA Skywise Alerts SW2022/344 and SW2022/363). If you do not fall into the category of staff that require the revised training, do not think for one moment that Dangerous Goods are nothing to do with you. A customer’s spare battery deposited into the rear freight hold may be the same type of battery as one bolted and connected in the equipment bay but your act of assisting the customer just put the aircraft at risk and the regulations have been contravened.

The New Year requires that Risk Assessments will have to be revisited, although accepted wisdom suggests that risk assessment should be iteratively reviewed throughout the year. Areas with ongoing reduced staff levels may make risk assessments seem to be an unwelcome burden, or a luxury that can be skipped, but that approach must be resisted if we are to ensure the continued safety of our operations.

We all carry out risk assessments prior to undertaking an individual task, even if only subconsciously. How well placed is the organisation you work for to commence a raft of new risk assessments? For those staff who normally carry out formal risk assessments, how well prepared are you? Do you remember the difference between a hazard and a consequence? Could you still visualise your Risk Tolerability Matrix showing Severity against Likelihood? Has the company risk assessment process been changed since the last time to adopt modern thinking, including the documentation of assumptions, and how are surprises addressed?

Has the period since the last assessment brought about changes that the last assessment did not feature; IT changes for example or fleet additions perhaps? Have any Maintenance errors occurred in the last year that the risk assessment at the time did not prevent? Were there any Internal Reports that indicate last year’s risk assessment is now lacking? Have previously recommended actions been implemented and were they successful? Is your employer using the same service providers?

That newly contracted crane driver lifting off an engine may not possess the knowledge and experience of the previous contractor. If you query the fact that the crane is covered in building site debris that might contaminate the hangar, is the driver going to clean it off onto the ramp outside the hangar doors? This years’ supplier may be cheaper and therefore not as sophisticated as that risk-assessed last year. Plenty of risk assessments would have been carried out last year due to new staff joining an organisation but has an assumption since then been made that all new staff are genuinely up to speed, or are there still gaps in knowledge waiting to surface as a latent error?

Everything we do has some element of risk, and not all risks can be mitigated against. The aim is to get the overall risk ‘As Low As Reasonably Practicable (ALARP)’, also now referred to in some circles as ‘As Far As Practical (AFAP) in recognition of the highly subjective nature of the word ‘Reasonable’. We must calculate the Tolerability of accepting some of the risk/s and consider the balance of investment in production, versus the investment in safety. In doing this, there is great merit in conducting risk assessments with all staff. Who better to identify and analyse the risks than the staff members involved? This concept also contributes to an organisation’s Safety Culture, and brainstorming for a risk assessment brings staff together. To include many staff in risk assessments requires training which, needless to say, carries a cost but this could be part of recurrent safety training and could reduce staff spending time away from the work area.

Finally, whilst organisations are responsible for implementing and facilitating an effective Safety Management System (SMS), it is the role of employees to be mindful of, and operate within, the policies and procedures that are published. Perhaps the new year is the time to consider how well the SMS is performing. Is it a collection of procedures that simply satisfy regulations but have little real relevance to the operation? SMSs should be based on User-Centric Design (UCD) – i.e. be applicable to the work as actually being done rather than the work that management imagine or believe is being done. Just as our risk assessors are chosen for their task familiarity, UCD focuses on the requirements of the user of the SMS. Quality Control and compliance with the Company Procedures (SMS or other procedures) is the responsibility of the staff fulfilling the task, and the procedures should be regarded as belonging to the staff that use them, not solely the heads of departments. The SMS should provide a vehicle to allow staff to instigate changes to the current procedures. Perhaps we can make 2023 the year of all staff improving our organisations’ Safety Cultures and SMSs.

Have a great year and bear in mind that worrying about the post-Christmas credit card at work is a Human Factor issue. Roll on Spring.

Phil Young, Engineering Programme Manager

Comment No 1 – Sickness management

Glad you have finally woken up to this issue of pilots being pressured to work when sick [Editorial Air Transport FEEDBACK Edition 144]. I have written to you before about this and the reply I got was dismissive. Because of this pressure there are pilots and cabin crew everyday turning up to work when they shouldn’t. [Airline] has a desk of people whose sole job is to apply pressure to people who go sick. This is no secret, they are in the main crew check-in area. They of course will claim they are there to help but if you actually ask them for help they quickly fob you off. The fact that many people have reported this to you and nothing has been done is a disgrace. If you really mean what you say than this needs to be your top priority.

CHIRP Response: We’re grateful for any feedback on our work, be they plaudits or brickbats. In our defence on sickness policies, we’ve been representing the problem to the CAA and airlines since at least 2018 and probably regularly before that if I was to look up our files before my time as Dir Avn. Our problem is that we at CHIRP have no powers to fix anything and so all we can do is to keep banging the drum with airlines and companies to get things changed. Sometimes frustrations mount as we seem not to get anywhere and so that’s why I chose to make it a feature of my editorial to raise its profile again publicly. Perhaps encouragingly the CAA responded that they also think that there’s scope for doing something, but we’ve had false dawns before. At least they are talking with the likes of the UK Flight Safety Committee to scope the problem of absence/sickness management policies they tell me. Sickness and absence management is something bigger than individual companies and so that’s why we’re supporting their initiative to look for an industry-wide, best-practice approach but, as with most things, that’ll be a long-term solution.

Late-breaking news is that as a result of CHIRP’s representations, the CAA have been able to engage with one airline in particular about their sickness policy and that airline now has a revised attendance management scheme in place that takes a more enlightened approach to pay and days off when sick. Sometimes such successes are few and far between but this outcome illustrates the value of reporting to CHIRP when the usual avenues of engagement do not lead to a satisfactory outcome.

With regard to priorities, we try our best to keep things bubbling across the board but we’re largely a one-man/one-women band short on (part time) resources so pretty much everything becomes a top priority, especially at the moment with reports of fatigue, bullying, sickness/absence management, use of discretion, rostering, ground handling pressures, ATC resources, I could go on…  As we come out of COVID there are many ‘top priorities’ that we’re trying to champion and keep in the minds of the regulator and companies. To be fair to the regulator, they listen and say that they are engaging with the companies but tangible progress is sometimes slow, not least because they themselves are somewhat hampered by the regulations (carried forward from BREXIT for expediency) which, in typical European fashion, are vague and lack teeth in many areas; the CAA say they have aspirations to review and refocus them on UK requirements but resources to do so must compete with other priorities.

Comment No 2 – Living with COVID

I refer to your comments concerning positive Covid tests [Air Transport FEEDBACK Edition 144]. This needs some further explanation. There is no reason why you should not attend work having produced a positive outcome with a SARS-CoV-2 rapid test. It is really a matter whether the person involved has symptoms that are incapacitating or likely to be incapacitating. In terms of coming to work with a positive test this is a cultural and social issue. You should not lose sight of the fact at the present time the infection rate is currently 1 per 35 persons in England and increasing so it is highly likely that you are already in contact with an infected person. We are going to have to learn to live with Covid along with the Influenza/Respiratory Syncytial virus.

CHIRP Response: This comment again refers to the editorial where one of the quoted sickness reports mentioned that a Cabin Crew member had stayed away from work due to testing positive for COVID and had lost pay as a result. The background to this report was that it was received in early summer and, whilst we don’t know what the specific date of the Cabin Crew’s reported comments was, perhaps they were at a time when they were required by their particular company to stay away from work. Whether they were actually suffering from symptoms of COVID is unknown by us, and individual airlines have differing policies, but the underlying regulatory requirement is to stay away from work if suffering from symptoms that make you unfit to fly. The thrust of the editorial was to highlight company sickness policies and this particular COVID comment was just part of a wider piece about inconsistencies in the way that sickness and absence are being handled by companies. We hope that the comment about COVID didn’t detract from that particular aim.

Comment No 3 – Pronouns

The pronoun “they “ was used to refer to the captain several times in your response to a report [Air Transport FEEDBACK Edition 144, Report No 8 (FC5219)]. In one instance it was used when talking about the captain in a verbal dispute with cabin crew members. It was difficult to understand who was talking to whom. Please cease this politically correct idiocy and continue to use correct English. The use of “they” in this way is grammatically incorrect and potentially confusing. As you are no doubt aware it is also encouraged by the current gender hysteria. Why not simply continue to use the word Captain?

CHIRP Response: We don’t use the pronoun ‘they’ out of politically correct idiocy but as a deliberate policy to assist in protecting confidentiality. Many small airlines have few female captains for example and so if we used ‘she’ then it could narrow down the field if someone was familiar with the circumstances. Repetitive use of ‘the Captain’ or other titles can become stilted in reported speech so we’ll continue to also use ‘they’ in reports where appropriate but it’s a fair point that we need to make sure that in doing so we do not detract from the ability to understand the report itself.