The introduction of ICAO Annex 19 paved the way for Risk Based Surveillance (RBS) in aviation. The new Annex describes how the regulator and industry should address safety risks proactively and introduces the concept of overall safety performance in all domains of aviation.
EASA has also made some changes to its existing rule set by introducing rules according to which the oversight programme for an organisation must be developed. These rules take into account the specific nature of the organisation, the complexity of its activities and the results of past certification and/or oversight activities. In addition to which it shall be based on the assessment of associated risks. This changing regulatory backdrop has a significant impact on the approach and behaviours of the regulatory staff.
To make the best use of the changing regulatory backdrop and to become a Risk Based Surveillance, transformation is required on many levels. A regulator needs to work closely with industry to demonstrably reduce safety risk across the total aviation system and develop the capabilities required for future regulators to succeed in the changed environment.
The natural focus of any implementation or transformation programme is to focus on establishing the processes and the systems required. This is important, yet it is the people that will work in this new approach to regulation and they are the key to any successful transformation to RBS. They will be the ones living and breathing the newly designed processes. Therefore, ensuring that everyone understands why you are transforming and what the benefits are, is essential.
When rolling out RBS in the UK CAA, the regulator soon recognised that key to achieving its vision depended on the investment made in their people. The UK CAA believes that when transitioning to RBS, regulators must not underestimate the people aspect. Some of the key questions to ask are:
- Do you know what skills your new organisation will require?
- Do your staff have the skills required?
- Specifically, do they have both the hard and soft skills that will be required to deliver RBS?
Embedding RBS into any regulator’s organisation relies on assuring that the staff in place has the right skills and competencies and to ensure that an organisational culture exists that supports this transformation.
A change to RBS is a very substantial change in everything a regulator does. The focus is more on having challenging risk conversations with industry rather than pure compliance checks. However, it is essential to ensure that everyone understands that compliance still remains one of the key components of safety oversight. With this in mind, the skills needed for successful RBS may be quite different from the skill set available in the organisation. As such it is important to build on the technical and regulatory knowledge of the people in place, and move them towards a more risk based approach. This way of regulating also requires the staff to use skills such as influencing/persuasion, negotiation and financial/commercial awareness to best effect and have discussions broader than their traditional subject matter expertise.
To ensure a successful transition or implement changes on a broader scale, the UK CAA believes it is absolutely critical to achieve ‘buy-in’ from the start. In the UK CAA’s experience, this can only be achieved through robust processes, tools and training and information/ justification for the people working in the new environment. The training must not only focus on how to use the processes and systems but should include the background of why this change is so important and how safety is improved and guaranteed throughout. An important aspect is also the practical implementation and what it means for the staff working in this new environment. To achieve ‘buy-in’ from regulatory staff, it is essential to be open to constructive criticism and to welcome suggestions and feedback from staff. Any such feedback, suggestions or best practice, if taken seriously, will make it easier for staff to feel part of the new approach, take some ownership and become an advocate of it early on.
To take your people on this transformation journey, it is essential to fully understand the organisational culture needed to support the transformation to RBS. It is especially important to understand the deeper level of basic assumptions and beliefs that are shared by people within the organisation, some of which may even operate unconsciously. The organisation usually has a view of itself and its environment, which may be seen as ‘taken for granted’. To take your staff with you on the journey to RBS, it is essential to understand what is seen as important by the people in your organisation and to ensure the desired outcome and the lasting success of the regulator is achieved.
By understanding what the organisational culture is currently (the ‘As Is’) and establishing what kind of future organisational culture would be best suited to deliver RBS (the ‘To Be’), regulators will be able to actively encourage the development of this new culture. This can be achieved through targeted interventions. By clearly defining the goals from the outset, any such interventions can also be targeted and adjusted if needed. These interventions form the vehicle by which the organisation will move from the ‘As is’ to the ‘To Be’. This allows for the right adjustments to control systems to be made as well as organisational and/or power structures
On its journey to RBS, the UK CAA has already started to put a number of interventions in place to support its staff to bridge the gap between the ‘As Is’ and ‘To Be’ positions. Some of these interventions are highlighted below:
- RBS enabling systems, tools and process
- Soft skills training and support on change resilience, matrix management and influencing
- Defining the competencies and capabilities to deliver RBS to recruit, develop and measure staff in the right way
- Updating roles and responsibilities to support delivery of RBS
- Started to define the ‘As Is’ and ‘To Be’ organisational culture in more detail to be clear on where the organisation is headed and where the gaps are to support its people.
For a successful transition to RBS, it is essential that staff are fully bought into the reasons for change and aware of how the transition will be achieved, how it will affect them and what support can be expected.
RBS aims to create better aviation regulators and in some ways, it will change the way regulatory staff assess and interact with industry. Taking your people on this journey with you is key. It is essential not to underestimate the efforts required to influence the existing organisational culture, train staff on new skills and commit to ongoing support throughout the transition.
Publications & Project
Risk Based Surveillance as a concept is gaining interest and momentum in the international aviation arena. Its principles are central to the new ICAO Annex 19 and are often the subject of safety conferences…
The relationship between the regulator and its regulated industry is always complex.