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Old 07-15-2014, 09:01 PM
  #111  
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Originally Posted by 3pointlanding View Post
The company does not have to flly to Brazile, Chile, Dubai, Turkey, most Middle East countries, India, and soon to be China either.
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What the heck does this mean and where is soon to be China? Weird.
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Old 07-23-2014, 08:12 AM
  #112  
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Originally Posted by TonyC View Post
No, Companies have SMS because they are truly interested in improving the safety environment, or they do it because CONGRESS requires the FAA to report to them who has an SMS and who doesn't.

That's also why The Company was so eager to ink those MOUs and LOAs in our pretend contract 3˝ years ago..
You are wrong, but I don't have the energy to do a 5 foot long post so I cannot compete with you there. Here goes.


Of course they do it out of the goodness of their hearts, but SMS is also an international requirement that the US does not (and is one of the few nations not to) currently comply with. Every Canadian airline has an SMS approved by Transport Canada; Airlines in the US do NOT have an approved SMS because there is no regulatory definition in this country and no regulation CURRENTLY requiring it, although the FAA has been promising a reg for some time now. Most airlines participate (to some level) in the FAA VOLUNTARY pilot SMS program; the program material has some definitions for elements of an SMS. For example, you need to have a system to allow employees to report safety concerns in a voluntary/non-punitive and confidential fashion. YOU DO NOT HAVE TO HAVE AN ASAP. But most carriers use ASAP for this and when the rule is finished, will use this to satisfy the requirement for their SMS. Likewise, you need to have a system to monitor crew performance in aggregate - LIKE a LOSA, but it does not have to be a LOSA. Based on your posts, your understanding of what and why for SMS is inaccurate.


That said, reiterating that I am in full agreement to try to do cockpit observations without the endorsement and support of the pilots is stupid.
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Old 07-23-2014, 08:47 AM
  #113  
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Originally Posted by skywatch View Post

You are wrong, but I don't have the energy to do a 5 foot long post so I cannot compete with you there. Here goes.

1 link will do.



Originally Posted by skywatch View Post

Of course they do it out of the goodness of their hearts, but SMS is also an international requirement that the US does not (and is one of the few nations not to) currently comply with. Every Canadian airline has an SMS approved by Transport Canada; Airlines in the US do NOT have an approved SMS because there is no regulatory definition in this country and no regulation CURRENTLY requiring it, although the FAA has been promising a reg for some time now. Most airlines participate (to some level) in the FAA VOLUNTARY pilot SMS program; the program material has some definitions for elements of an SMS. For example, you need to have a system to allow employees to report safety concerns in a voluntary/non-punitive and confidential fashion. YOU DO NOT HAVE TO HAVE AN ASAP. But most carriers use ASAP for this and when the rule is finished, will use this to satisfy the requirement for their SMS. Likewise, you need to have a system to monitor crew performance in aggregate - LIKE a LOSA, but it does not have to be a LOSA. Based on your posts, your understanding of what and why for SMS is inaccurate.


That said, reiterating that I am in full agreement to try to do cockpit observations without the endorsement and support of the pilots is stupid.

I never said we have to have ASAP, or LOSA, but we do have them, and they meet the requirements of the FAA's idea of SMS, and they satisfy the requirements of the IOSA standard.

What have I said that is inaccurate? I love source documents -- bring 'em on.






.
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Old 07-23-2014, 10:06 AM
  #114  
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Likewise, you need to have a system to monitor crew performance in aggregate - LIKE a LOSA, but it does not have to be a LOSA.

So like I say if this is the intent then a LOA or MOU is required so crews know the rules before hand.
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Old 07-23-2014, 10:36 AM
  #115  
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Originally Posted by HIFLYR View Post
Likewise, you need to have a system to monitor crew performance in aggregate - LIKE a LOSA, but it does not have to be a LOSA.

So like I say if this is the intent then a LOA or MOU is required so crews know the rules before hand.
And see the results afterward.
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Old 07-23-2014, 12:33 PM
  #116  
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Enders. All I need to remember...
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Old 07-23-2014, 01:11 PM
  #117  
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Originally Posted by TonyC View Post
SMS is not "soon coming" to FedEx. FedEx HAS SMS right now, at this moment, and the 4 FAA programs I've mentioned over and over are part of that SMS. We have MOUs and LOAs for ASAP, FOQA, LOSA, and FRMP. It's not theoretical, it's not maybe someday, it's real and it's now.

The Company's new QA program has nothing to do with those programs, and it is NOT required by either SMS or IOSA.

.
(Sigh) here is one link. Here is an example of the fact that there is no such thing as a US SMS program as defined.

SMS Implementation and Practical Considerations for Business Aviation Operators | Universal® Operational Insight Blog

"You can be denied entry into an ICAO country if you do not have an active SMS program. For example, France is currently looking for an “approved SMS” from charter operators (when requesting permits). However, no U.S. operator can actually comply with this, as the Federal Aviation Administration (FAA) is not yet in the business of approving SMS programs. Also, Bermuda has been requesting evidence of SMS for private non-revenue operators. The problem is that there’s no real definition of what a fully mature SMS program looks like, and it’s difficult for anyone to gauge whether you have an effective SMS or not. So, non-compliance issues are hard to predict."

It is not right now, not until the FAA decideds what it looks like and publishes a rule.

You are wrong about your new QA program having nothing to do with SMS. For example the Advisory Circular has four "pillars" or components of an SMS program, one of which is Safety Assurance. I am betting you cannot link me to something that says that the QA program is NOT a part of an SMS, any more successfully than I can link you to something that says it is - which only proves my first point. But nonetheless, if a carrier chooses to use a crappy QA program for the SA, then so be it, they can, they are allowed to, as there is no definition of what it has to be. If they can show an IOSA auditor that the have a Safety Assurance program that is built around this QA thing, that satisfies that requirement.

Which takes me to my last point, which I don't want lost - to do any kind of program without the endorsement and acceptance of the pilots is really stupid. LOSA would be a better choice, on that we agree.
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Old 07-23-2014, 01:13 PM
  #118  
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Originally Posted by hiflyr View Post
likewise, you need to have a system to monitor crew performance in aggregate - like a losa, but it does not have to be a losa.

So like i say if this is the intent then a loa or mou is required so crews know the rules before hand.
+1 agree +1
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Old 07-23-2014, 02:00 PM
  #119  
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Originally Posted by Albief15 View Post
Enders. All I need to remember...
Exactly!!








[filler]
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Old 07-23-2014, 02:38 PM
  #120  
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Originally Posted by Albief15 View Post
Enders. All I need to remember...
I've been in the Aviation Safety business for a very long time (both military & commercial). I've NEVER heard of a safety evaluation where the results weren't shared with those being evaluation.

I mean ... except for the Enders Report!*?
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