We take a look at the BALPA Most Wanted flight safety improvements C By BALPA staff OVID-19 has had a devastating impact on our industry, with the full scale yet to be fully realised and understood. However, what is crystal clear is the continued importance of flight safety and the health of everyone involved in aviation. The pandemic has arguably raised the stakes in terms of elevated safety risks associated with dramatically different modes of operation and the challenges of resuming operations after a prolonged layoff, with both people and equipment suffering from a lack of recency. Looming over is the spectre of commercial pressure, as organisations understandably fight hard for survival. At the time of writing, there were some major events on the horizon that could, depending on your perspective, present further threats or offer opportunities for safety improvement. For example, the UKs exit from the European Union Aviation Safety Agency (EASA). As The Log goes to press, it is hoped clarity on future arrangements will have been provided, and there might even be a safety agreement in place between the UK and EU. There is also the return to service of the Boeing 737 MAX a golden opportunity to learn from tragedy and improve the way that aircraft are certificated, how pilots are trained, and how the whole aviation system is overseen. With that in mind, BALPA has reviewed its safety strategy for 2021 and identified a list of Most Wanted flight-safety outcomes. There are 10 key subjects, all underpinned by commercial pressure, most pertinent to members (see image, below), and where targeted action would help protect both the future of the industry and its consumers through the prevention of accidents. This allows a more ambitious and wide-ranging approach to be taken in terms of the safety improvements BALPA would wish to see. The intention is to keep the document live and for BALPA to identify actions that it, and its members, can take to help achieve them. This involves an ongoing programme of promotion and engagement with members and other external stakeholders. So, why has commercial pressure been placed at the hub of BALPAs Most Wanted? It is the greatest danger to the integrity and resilience of safety culture. With increased threats to commercial survival, it is easy for company statements such as safety remains our top priority to become superficial platitudes. Through Most Wanted, BALPA will hold regulators, airlines and aircraft manufacturers to account in taking the actions necessary to uphold, and improve, the high levels of safety the aviation industry has worked hard to achieve. BALPA is keen for its members to contribute to the achievement of these outcomes. For commercial pressure, individual pilots have a vital role to play in reporting examples of where commercially driven decisions have had an adverse impact on flight safety for example, airlines working a smaller pool of pilots harder, leading to high levels of fatigue. Without tangible evidence, it is difficult to make a persuasive case for change. Ideally, company safety reporting systems and mandatory occurrence reports [MORs] for the more significant examples should be used. But for those who may feel uncomfortable reporting via their company, there is CHIRP (confidential reporting programme for aviation and maritime) and, of course, BALPA would be interested in hearing directly contact us at MostWanted@BALPA.org. COVID-19 will continue to affect travel in 2021, and potentially beyond. It has been demonstrated successfully that flying can be conducted in a COVID-secure way with, for example, a low risk of virus transmission while on board aircraft and the safety agenda will need to shift to tackle the many special conditions and exemptions that have been implemented to keep the industry operating. While it was entirely appropriate to take these measures at the beginning of the pandemic, there comes a time when they should be reviewed to ensure that any disproportionate focus on public health protection at the expense of flight safety does not persist. For example, fatigue-inducing rosters were deemed inappropriate pre-pandemic, so it is important that the COVID-related exemptions do not become normalised. BALPA will use Most Wanted to address these types of issues. Brexit has largely taken a back seat since the pandemic took hold, but the UKs imminent departure from the EASA system will result in the UK Civil Aviation Authority holding regulatory competence for rule making and oversight in all domains (flight operations, airworthiness, licensing, aerodromes, airspace, ATM/ ANS and security, including cyber) for the first time since 2003. While the scope of national civil aviation regulation is unlikely to deviate significantly from European rules in the short term, there could be an opportunity to review their continued relevance. BALPA will use its Most Wanted to explore what might be possible in this context. As far as the prospect of the 737 MAX returning to service, the underlying issues involved in the 737 MAX accidents of regulatory capture, aircraft certification and pilot training are key parts of BALPAs Most Wanted strategy. Actions to address these issues and the other subjects will be expanded upon in 2021, but BALPA has already engaged with the FAA via the public consultation on its proposed Airworthiness Directive and Flight Standardization Board report. BALPA will continue to engage with regulatory authorities in a constructive way to progress its Most Wanted objectives. Most Wanted subjects and desired outcomes Commercial pressure Strict enforcement by aviation authorities of regulatory controls to ensure that commercially driven decisions do not breach safety red lines REGULATORY CAPTURE AIRCRAFT CERTIFICATION PILOT TRAINING PILOT FATIGUE CABIN AIR QUALITY COVID-19 EFFECTS LITHIUM BATTERIES HELICOPTER OPERATIONS UAS SECURITY Aviation authorities to implement controls to mitigate the risk of regulatory capture1 within their organisations DfT/CAA to review the efficacy and relevance of national aviation safety and security regulations following the UKs exit from EASA, and to ensure they are fit for purpose Aviation authorities to require that substantial aircraft design changes result in certification as a new type, with a commensurate level of training required for pilots Aviation authorities to require that fundamental flying or handling quality deficiencies are aerodynamically designed out and not masked by flight control system augmentation Implementation by ATOs of smarter training to improve pilots ability to diagnose and manage complex technical failures Implementation by aviation authorities of more thorough typerating training requirements to better educate pilots on differences between aircraft Implementation by aviation authorities of a regulated maximum permissible level of fatigue beyond which flights cannot be flown UK aircraft operators to systematically schedule appropriate rest breaks for aircrew, as is required by the Civil Aviation Working Time Regulations, and aviation authorities to rigorously enforce these regulations Implementation by aviation authorities of requirements for the detection of contaminated cabin air and filtration of the cabin air supply prior to first entering the air conditioning system Aircraft operators to cover both aircraft and health aspects in their investigation of contaminated cabin air events, and to provide full disclosure to the pilots involved Consistent and thorough implementation of H&S measures by aircraft operators (in line with ICAO/EASA guidelines) and robust enforcement of H&S legislation by regulatory bodies Aircraft operators to implement controls to ensure that COVID-19related mitigations do not result in unintended risk transfer such that overall flight-safety risk is increased Aircraft operators to ensure that processes exist to ensure that redirected cabin baggage for the hold is assessed for lithium battery fire risk Prohibition of the carriage of portable electronic devices larger than cell phones in checked baggage Tangible improvement in the recognition and resolution of occupational health and safety issues affecting helicopter pilots Implementation by aviation authorities of certification standards for commercial aircraft resilience to UAS strikes (including ingestion into engines) Implementation by aviation authorities of appropriate separation standards for UAS, including wake-turbulence criteria Implementation of controls by the aviation industry to ensure the risk to flight safety-critical infrastructure and systems from cyber-attack is reduced as low as is reasonably practicable Safe flight that avoids conflict zones Table 1: BALPAs list of its Most Wanted Footnote 1 Regulatory capture is an economic theory that regulatory agencies may come to be dominated by the interests they regulate and not by the public interest. The result is that the agency instead acts in ways that benefit the industry it is supposed to be regulating. Industries devote large budgets to influencing regulators.