Final As Delivered

I’m delighted to be here today to speak to the Flight Safety Foundation in person for the first time–and to have the opportunity to acknowledge the incredible work that this organization has done to improve aviation safety worldwide for almost seven decades.

When the Flight Safety Foundation formed in 1947, we were just two years removed from the end of World War II. That year, Chuck Yeager became the first pilot to exceed the speed of sound in level flight, in a rocket-propelled Bell X-1 research aircraft. The prototype of the 100-passenger Boeing 377 Stratocaster first flew. And the U.S. Civil Aeronautics Authority first began testing radar precision landing equipment at airports in Washington and Chicago.[1]

Amid these changes, commercial aviation was rapidly growing.  It barely resembled the industry it is today. Airplanes were powered by propeller-driven engines.  The cabins were loud, often filled with cigarette smoke, and subject to uncomfortable vibrations. And, sadly, deadly accidents were very, very common.

The Flight Safety Foundation set out to change that record, and, over the years, has compiled an impressive list of “firsts” in its pursuit of safety improvements.[2] The Foundation organized the first civil aviation accident investigation workshop. It sponsored the first international air safety seminar. It conducted the first collection and distribution of aircraft mechanical malfunction reports. And it conducted the first computer modeling of accident forces, which led to the improvement of passenger restraint systems.

Improving safety is an endless series of “firsts,” because improving safety is an endless evolution. Today, because the FAA and our aviation partners have embraced this evolutionary approach, airline passengers in the U.S. take safety for granted. Our aviation system has achieved a level of safety that really has no historical precedent in any mode of transportation – and there is an assumption that we will continue to set the gold standard when it comes to safety.

A key element in our approach is to constantly strive to be better. That means we have to question whether we can do things differently, to work smarter, or to work more efficiently.

Many of us know that our traditional approach to safety was to look backwards and analyze accidents after they occurred.  We determined what went wrong and tried to prevent the problem from causing the same type of accident again.

But after a troubling string of accidents in the late 1980s and 1990s, the FAA and the airline industry knew that more needed to be done.  We set an ambitious goal of reducing accidents by 80 percent. When that goal was announced, our critics questioned whether we could meet that number.

The critics had a point: The way we had been approaching the problem, it was highly unlikely that we would succeed. But it was the agency’s position that we – and by “we,” I mean the FAA and our industry partners– needed to change our thinking. We needed to evolve.

What if we started trying to identify safety problems long before they led to accidents, or even incidents? What if we started looking for hidden trends, which we all knew could be precursors to accidents? To do this, we knew we’d have to start taking advantage of information sources.

Together with the aviation industry, we formed the Commercial Aviation Safety Team, or CAST. CAST focuses on intense data analysis to detect risk and works to prevent accidents or serious incidents from happening in the first place. To be successful, we knew we would need to collect a lot of data as possible to look for trends that wouldn’t otherwise be obvious. We adopted a wide array of programs that encouraged aviation industry professionals – whether they are pilots, flight attendants, mechanics or air traffic controllers–we asked everyone to voluntarily report all safety events. The idea is that people are more likely to report events—and provide us with critical safety information—if they know that doing so will not have repercussions or jeopardize careers.

Today, we can all take credit for an amazing accomplishment: We have all but eliminated the traditional common causes of commercial accidents – controlled flight into terrain, weather, wind shear, failure to complete checklists. All told, the Commercial Aviation Safety Team reduced the risk of fatalities in U.S. commercial aviation, not by 80 percent but by 83 percent over 10 years.

But we can never be satisfied with the status quo. We know that we need to constantly and continually evolve to meet the safety challenges of tomorrow. And we recognize that the aviation environment has reached a level of complexity where we can’t achieve further safety improvements by following a purely rule-based approach.

So the FAA and industry began implementing Safety Management Systems, which are designed to identify hazards, assess the risks from those hazards, and put measures in place to mitigate those risks. This is the core of what we call our Risk-Based Decision Making Initiative.

Now we’re taking our Risk-Based Decision Making initiative to the next level through what we are calling the Compliance Philosophy.

The Compliance Philosophy is the latest  step in the evolution of how we work with those we regulate. It focuses on the most fundamental goal: find problems in the National Airspace System before they result in an incident or accident, use the most appropriate tools to fix those problems, and monitor the situation to ensure that they stay fixed.

The Compliance Philosophy recognizes that what we all want is that everyone complies with aviation’s high safety standards.  It recognizes that most operators voluntarily comply with both the rules and the core principles of a Safety Management System. It also recognizes that in today’s complex aviation environment, even the best operators make honest mistakes. But even unintentional errors can have a serious adverse impact on aviation safety, so we have to fix the problem. 

So, in cases where a deviation results from factors such as flawed procedures, simple mistakes, lack of understanding, or diminished skills, we use tools like training or documented improvements to procedures to ensure compliance.

That doesn’t mean we’re going to go easy on compliance, or that we’re ignoring minor issues, or making anyone feel they have a free pass. We still have zero tolerance for intentional reckless behavior or inappropriate risk taking. Enforcement is, and always will be, one of our tools that we will use to ensure compliance. We use the enforcement tool in the case of willful or flagrant violations, or for refusal to cooperate in corrective action.

So, the success of our Risk-Based Decision Making initiative, which includes Safety Management Systems and now the Compliance Philosophy, requires both the FAA and the aviation community to evolve in how we do business and how we interact with one another.

To find and fix safety problems, there has to be an open and transparent exchange of information and data between the FAA and industry. We don’t want operators who might inadvertently make a mistake to hide it because they have a fear of being punished. If there is a failing, whether human or mechanical, we need to know about it, to learn from it and make the changes necessary to prevent it from happening again. Again, it’s about finding the problem, fixing the problem, and making sure it stays fixed.

That open and transparent exchange of information requires mutual cooperation and trust, which can be challenging to achieve  in the traditional, enforcement-focused regulatory model.

So what specifically are we doing on the FAA side?

• We have started training for all FAA employees on the new Compliance Philosophy, with detailed “how-do-I-implement-it” training for each Line of Business.
• We are using data, not calendar dates, to determine when and where to conduct surveillance and inspections.
• We are emphasizing that we expect our employees to use critical thinking, which is essential to successful implementation of the Compliance Philosophy. We want inspectors to use their judgment, experience, expertise and qualifications to identify risk, to work with the individual or operator, and to identify the most appropriate tools needed to permanently fix the problems.  

On the industry side, success requires understanding that compliance requires going above and beyond. The FAA expects certificate holders to develop and implement risk controls that are appropriate to their operational environment. That means thinking about outcomes and performance, identifying hazards, and mitigating associated risks, and implementing practices and procedures that encourage reporting.

To get useful reporting, both regulators and operators have to understand the difference between accountability – which accepts responsibility and looks forward – and blame, which focuses on punishment for what’s already happened. With accountability, the idea is to look at the operator’s compliance attitude.

And that’s where the Compliance Philosophy is a critical part of the Risk-Based Decision Making approach.  The Compliance Philosophy recognizes that the greatest systemic safety risk arises not from a specific operational event or its outcome, but rather from the operator’s willingness and ability to comply with safety standards and to operate in accordance with the core principles of a Safety Management System.

So, we use tools like training or documented improvements to procedures to ensure compliance in cases where a deviation results from factors such as flawed procedures, simple mistakes, lack of understanding, or diminished skills. And we use the enforcement tool in the case of willful or flagrant violations, or for refusal to cooperate in corrective action.

In our continuing work to maintain the U.S. system as the gold standard for aviation safety, we start with the fundamental idea compliance is the foremost factor in safety. In all cases, the goal is to achieve rapid return to compliance, to mitigate the risk, and to ensure positive and permanent changes that benefits the aviation industry. That’s what Compliance Philosophy is all about.

As I said at the beginning, we can never relent when it comes to our pursuit of even safer skies. It is our collective responsibility to find new ways to improve, to evolve, to identify new “firsts” while making flying even safer.

Once again, I would like to thank the Flight Safety Foundation for your longstanding  commitment to continuous safety improvement. You are and will continue to be a key partner as we make flying ever safer both here and throughout the world.