i'm not familiar with the FedEx QA. Some questions to better understand what your talking about.

Why is there no MOA with the Union?
Is the data de-identified like LOSA data?
Why reinvent the wheel, just contract another LOSA?
Is this a "cost savings" issue to substitute for LOSA?

I'm out on sick leave so I don't have the front seat to observe this program like most of the others on this web board but ...

The Obama Administration has their Scandal of the Month, FedEx Management seems to have their "Harassment of the Month." If you've followed this board for several months you probably noticed the sick leave harassment, Hong Kong pilot LOA harassment, next month they'll find something else to help distract from Contract Negotiations.

I'm surprised we keep falling for it. There must be something we can do to stop it?


.

Flight Mgmt is like the boss in this new Fedex commercial

And they're hoping we're like the Assistant...

http://www.funnycommercialsworld.com/fedex-commercial-dont-count-that-25352.html

(...play the YouTube video within the article)

They fall under the classification of any other pilot that is asking to ride in the jumpseat; Captain's discretion. That part really isn't hard to grasp and was made pretty clear to me at recurrent.

Very hard to find out concrete data about the program. I called Safety - they had no idea. Called my ACP - he directed me to the PAC which had no idea of the program. Just had recurrent and there was no mention of it anywhere - the ground school instructor didn't know about it and was quite sure we weren't getting any sort of brief on it (we didn't). Can't find any mention in the FOM about it. Except for a few advertisements for positions from the Company and the complaint from the Union how can one find hard information about the program? How does anyone know what the purpose is or how the data will be used? I PM'd 3point a long time ago and he never got back so I'm guessing there really isn't anything in writing available for the crew force on the program. ??

I had CMV1 a few months ago and the QA folks were there to give a 30 minute brief on who and what they do. This occured on the same day as the Global War On Error crap, or the new program that replaced GWOE. I know they've been doing the brief for quite some time to educate the crew force. The QA program came from Qantas.

I think there's a lot of misinformation being communicated on this thread.

I had a QA fella on a flight four weeks ago. He wasn't management, nor did he speak highly of anyone in management. He slept through 98% of the flight. He was on the airplane to see a taxi obstruction/situation that resulted in a POR and how the problem could be solved.

I'm sure this post is going to go over like a ***** in church.

I am sure most of them are good crewmembers wanting to help the crewforce. The program just needs to be spelled out in a MOU, LOA ETC. in case something happens or one of them is not such a good guy.

I would think they would want that protection also.

I think you hit the nail on the head. I think generally the program has good goals. However there needs to be protections so that at any point in the future it can't be abused. Also, I think the crew members should be provided any copies of any reports generated.

Just because the company keeps secret records (and loses them when it is in their interest) is no reason to be paranoid. :eek:

There will always be FedEx pilots who don't promote the benefits of transparency. They don't think it's possible that a witch hunt will ever effect them. Could be due to ignorance but, for some, it it's because their friends in management always have their back.

Management touted the program as a "management trainee program." Yea I'm sure they're all good guys. :rolleyes:

Source? I'd love to have that quote tucked into my ALPA calendar.

Wasn't that in an FCIF looking for First Officers?

Spot on...
 

I support the concept. However no MOA or any of the other things you suggest...it is about saving money by using this variant of LOSA...

MOA/mou whatever you want to call it, involve the association on the front vice shoving it down our throats - disrespectful and not respecting of our buy-in as stakeholders in charge of the largest risk at this corporation. But that has been the FedEx way - "Spaulding, you'll get nothing and like it".

Now off to fly into a Typhoon...

http://www.blogcdn.com/massively.joy...0/facepalm.jpg


Well, I've been a little busy the past few days with Recurrent Ground school and a couple of AQP Simulator events, but I don't feel too bad about taking so long to respond to your posts because I said I wouldn't until you produce a link to "one single reference in a regulatory document that requires FedEx to implement the program they're calling QA," and you still have not. However, in the interest of entertainment, here I go.


First, this post:
I want to offer you my sincere congratulations on completing a career of flying, and my sincere condolences that you obviously cannot enjoy the reward of retirement. It must be daunting to have to rely on the benevolence of Uncle Fred and an office job to pay the bills and keep things going. It's a shame, and I'm sorry you have to endure it.

Just out of curiosity, do they keep the thermostats set at 78° in your cubicle? They tell us (pilots) that they won't hook up air conditioning to the jet unless the OUTSIDE temperature is predicted to rise above 78°. Do you have any idea what the cockpit temperature gets to be at that temperature? Anyway, I digress.

Back to the first post ...

Why, of course, why didn't I think of that?!? Oh, wait, I DID! In fact, I said the very same thing, only I gave the title and a link. (That's the text that shows up on your screen as blue. When you place your cursor over the blue text and click, your browser will take you to an on-line copy of the document.) Then I quoted from it. At length. As I recall, ... no, wait, I don't have to rely on memory, I can just copy and paste it here ...

Ah, yes, I remember now. It says, "This AC is not mandatory and does not constitute a regulation. Development and implementation of an SMS is voluntary."

Maybe if we quote it a few more times it will change and become mandatory and constitute a regulation, ya think?




Nope. Joining the IOSA registry is of no interest to me. The reference I asked for, again, is ... "one single reference in a regulatory document that requires FedEx to implement the program they're calling QA."


Interesting, but irrelevant. Apparently you forgot what you forgot because you forgot to complete the list "tomorrow." With or without the complete list, you still have failed to provide "one single reference in a regulatory document that requires FedEx to implement the program they're calling QA."

I don't care to see "just what an observation is for." What I would like to see is "one single reference in a regulatory document that requires FedEx to implement the program they're calling QA."



Thanks, but I don't want the ISARP. What I would like is "one single reference in a regulatory document that requires FedEx to implement the program they're calling QA."



Delusional much?



The programs agreed to by FedEx, ALPA, and the FAA satisfy the requirements of the FAA's SMS program and IATA's IOSA program. The program which FedEx has instituted on its own, without the cooperation or buy-in from the pilots and with no method for protecting pilots or sharing information gathered, IS NOT REQUIRED FOR EITHER.

If I am wrong, please show me "one single reference in a regulatory document that requires FedEx to implement the program they're calling QA."


Here's the deal. The FAA's Safety Management System includes 4 programs, ASAP, FOQA, LOSA, and FRMP, all of which require the participation of The Company, The Association, and the FAA. We voluntarily participate in all 4. If The Company wants to put observers in the cockpit, they can conduct a LOSA according the LOA we all agreed to and signed.

The beauty of this SMS program with all three parties volunteering to participate and all three parties enjoying the benefits of sharing the information, learning from mistakes, and endeavoring together to make our airline more safe is that it also satisfies the requirements of IATA's IOSA standard. We don't have to reinvent any wheels, or copy any Australian airline.

The QA program as explained in our 6-month recurrent ground school is conducted by Fleet Check Airmen, and our FOM states that I must grant them flight deck access. According to the Fleet Check Airman who gave the briefing I attended, they will not bust a pilot even if they observe something that is unsafe or in violation of the FARs. Instead, they will refer those pilots to Standards and Training for further "attention."

This brings up two issues. First, how does the FAA feel about a Check Airman NOT intervening in order to prevent an unsafe condition? How does the FAA feel about a Check Airman turning a blind eye to a violation?

Second, if the Fleet Check Airman can refer me for additional "attention" from a "real" Check Airman (meaning someone who is actually qualified to fly and evaluate on my airplane), then the ride presents jeopardy to me. Just like a line check or a ride by an Aviation Safety Inspector from the FAA, my ticket is on the line.

Since that briefing in recurrent ground school, The Company solicited First Officers to become management wannabes and conduct QA observations. (I would refer to them by their proper title, but I don't know what it is.) The FOM does not require me to grant them flight deck access, so I will not.

AGAIN, if The Company wants to put observers in the cockpits, all they have to do is conduct a LOSA according to the agreed-upon procedures of our LOSA LOA.

And AGAIN, and for the last time, if you can produce that "one single reference in a regulatory document that requires FedEx to implement the program they're calling QA," I'll consider changing my mind about it.






.

I'm pretty sure that's correct. I archive most FCIFs to reference in such a case as this, but my laptop isn't cooperating with me at the moment, so I cannot provide a citation. When I get it back, I'll be happy to provide the quote and details.






.

I overheard one of these FO QA observers talking to his buddy a couple of weeks ago, lamenting that he was probably going to quit the program. He found that the 'Bus jumpseat was too uncomfortable. :rolleyes:

I think he somehow misses the bigger picture.






.

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 3½ years ago.






.

They're briefing it during your CBA-guaranteed lunch break during the "6-month" recurrent, the one with GWOE and a CMV1. It's not briefed during the "Annual" recurrent with CMV2 and CLOE.






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At first it was the autopilot and now it's the wife flying.....was it a cessna or lear

Wife flies, uses autopilot, I sit in right seat and play with my IPad or maybe sleep.

But you don't answer the direct questions asked of you on this forum! :mad:

Tony C
True there is no regulation requiring SMS, QA, or IOSA. Never said there was. But SMS is coming and soon the be published. American, United, Southwest, and others are on board and soon the company be using SMS. IF you do not want an IOSA auditor in your cockpit you certainly have that choice. The company does not have to flly to Brazile, Chile, Dubai, Turkey, most Middle East countries, India, and soon to be China either. Just for you information here is the proposed SMS Part 5:

From NPRM: [Docket No. FAA–2009–0671; Notice No. 10–15]
RIN 2120-AJ86
PART 5 – SAFETY MANAGEMENT SYSTEMS
Subpart A – General

Sec.
5.1 Applicability.
5.3 General requirements.
5.5 Definitions.

Subpart B – Safety Policy

5.21 Safety policy.
5.23 Safety accountability and authority.
5.25 Designation and responsibilities of required safety management personnel.
5.27 Coordination of emergency response planning.

Subpart C – Safety Risk Management

5.51 Applicability.
5.53 System analysis and hazard identification.
5.55 Safety risk assessment and control.

Subpart D – Safety Assurance

5.71 Safety performance monitoring and measurement.
5.73 Safety performance assessment.
5.75 Continuous improvement.

Subpart E – Safety Promotion

5.91 Competencies and training.

1

5.93 Safety communication.

Subpart F - SMS Documentation and Recordkeeping

5.95 SMS documentation.
5.97 SMS records.

Authority

Subpart A – General
§ 5.1 Applicability.

(a) A certificate holder under part 119 of this chapter authorized to conduct operations in accordance with the requirements of part 121 of this chapter must have a Safety Management System that meets the requirements of this part and is acceptable to the Administrator by [date 3 years after the effective date of final rule].
(b) A certificate holder must submit an implementation plan to the FAA Administrator for approval no later than [date 6 months after the effective date of the final rule].
(c)The implementation plan may include any of the certificate holder's existing programs, policies, or procedures that it intends to use to meet the requirements of this part, including components of an existing SMS.

§ 5.3 General requirements.

(a) Any certificate holder required to have a Safety Management System under this part must submit the Safety Management System to the Administrator for acceptance. The Safety Management System must include at least the following components:

2

(1) Safety policy in accordance with the requirements of subpart B of this part;
(2) Safety risk management in accordance with the requirements of subpart C of this part;
(3) Safety assurance in accordance with the requirements of subpart D of this part; and
(4) Safety promotion in accordance with the requirements of subpart E of this part.
(b) The Safety Management System must be maintained in accordance with the recordkeeping requirements in subpart F of this part.
(c) The Safety Management System must ensure compliance with the relevant regulatory standards in chapter I of Title 14 of the Code of Federal Regulations.

§ 5.5 Definitions.

Hazard

means a condition that can lead to injury, illness or death to people; damage to or loss of a system, equipment, or property; or damage to the environment.

Risk

means the composite of predicted severity and likelihood of the potential effect of a hazard.

Risk control

means a means to reduce or eliminate the effects of hazards.

Safety assurance

means processes within the SMS that function systematically to ensure the performance and effectiveness of safety risk controls and that the organization meets or exceeds its safety objectives through the collection, analysis, and assessment of information.

Safety Management System (SMS)

means the formal, top-down, organization-wide approach to managing safety risk and assuring the effectiveness of safety risk controls. It includes systematic procedures, practices, and policies for the management of safety risk.

3

Safety objective

means a measurable goal or desirable outcome related to safety.

Safety performance

means realized or actual safety accomplishment relative to the organization’s safety objectives.

Safety policy

means the certificate holder’s documented commitment to safety, which defines its safety objectives and the accountabilities and responsibilities of its employees in regards to safety.

Safety promotion

means a combination of training and communication of safety information to support the implementation and operation of an SMS in an organization.

Safety Risk Management

means a process within the SMS composed of describing the system, identifying the hazards, and analyzing, assessing and controlling risk.

Subpart B – Safety Policy
§ 5.21 Safety policy.

(a) The certificate holder must have a safety policy that includes at least the following:
(1) The safety objectives of the certificate holder.
(2) A commitment of the certificate holder to fulfill the organization’s safety objectives.
(3) A clear statement about the provision of the necessary resources for the implementation of the SMS.
(4) A safety reporting policy that defines requirements for employee reporting of safety hazards or issues.
(5) A policy that defines unacceptable behavior and conditions for disciplinary action.
(6) An emergency response plan that provides for the safe transition from normal to emergency operations in accordance with the requirements of § 5.27.

4

(b) The safety policy must be in accordance with all applicable regulatory requirements in Chapter I of Title 14 of the Code of Federal Regulations and must reflect the certificate holder’s commitment to safety.
(c) The safety policy must be signed by the accountable executive described in § 5.25.
(d) The safety policy must be documented and communicated throughout the certificate holder organization.
(e) The safety policy must be regularly reviewed by the accountable executive to ensure it remains relevant and appropriate to the certificate holder.

§ 5.23 Safety accountability and authority.

(a) The certificate holder must define accountability for safety within the organization’s safety policy for the following individuals:
(1) Accountable executive, as described in § 5.25.
(2) All members of management in regard to developing, implementing, and maintaining SMS processes within their area of responsibility, including, but not limited to:
(i) Hazard identification and safety risk assessment.
(ii) Assuring the effectiveness of safety risk controls.
(iii) Promoting safety as required in subpart E of this part.
(iv) Advising the accountable executive on the performance of the SMS and on any need for improvement.
(3) Employees relative to the certificate holder’s safety performance.
(b) The certificate holder must identify the levels of management with the authority to make decisions regarding safety risk acceptance.

5

§ 5.25 Designation and responsibilities of required safety management personnel.

(a) Designation of the accountable executive. The certificate holder must identify an accountable executive who, irrespective of other functions, satisfies the following:
(1) Is the final authority over operations authorized to be conducted under the certificate holder’s certificate(s).
(2) Controls the financial resources required for the operations to be conducted under the certificate holder’s certificate(s).
(3) Controls the human resources required for the operations authorized to be conducted under the certificate holder’s certificate(s).
(4) Retains ultimate responsibility for the safety performance of the operations conducted under the certificate holder’s certificate.
(b) Responsibilities of the accountable executive. The accountable executive must accomplish the following:
(1) Ensure that the SMS is properly implemented and performing in all areas of the certificate holder’s organization.
(2) Develop and sign the safety policy of the certificate holder.
(3) Communicate the safety policy throughout the certificate holder’s organization.
(4) Regularly review the certificate holder’s safety policy to ensure it remains relevant and appropriate to the certificate holder.
(5) Regularly review the safety performance of the certificate holder’s organization and direct actions necessary to address substandard safety performance in accordance with § 5.75.

6

(c) Designation of a management representative. The accountable executive must designate a management representative who, on behalf of the accountable executive, must be responsible for the following:
(1) Facilitating hazard identification and safety risk analysis.
(2) Monitoring the effectiveness of safety risk controls.
(3) Ensuring safety promotion throughout the certificate holder’s organization as required in subpart E of this part.
(4) Regularly reporting to the accountable executive on the performance of the SMS and on any need for improvement.

§ 5.27 Coordination of emergency response planning.

Where emergency response procedures are necessary, the accountable executive and management representative must develop, as part of the safety policy of the certificate holder, an emergency response plan that addresses at least the following:
(a) Delegation of emergency authority throughout the certificate holder’s organization;
(b) Assignment of employee responsibilities during the emergency; and
(c) Coordination of the certificate holder’s emergency response plans with the emergency response plans of other organizations it must interface with during the provision of its services.

Subpart C – Safety Risk Management
§ 5.51 Applicability.

A certificate holder must apply safety risk management to a system under any of the following conditions:
(a) Implementation of new systems.

7

(b) Revision of existing systems.
(c) Development of operational procedures.
(d) Identification of hazards or ineffective risk controls through the safety assurance processes in subpart D of this part.

§ 5.53 System analysis and hazard identification.

(a) When applying safety risk management, the certificate holder must have a process to describe and analyze the system for use in identifying hazards under paragraph (c) of this section, and developing and implementing risk controls related to the system under §5.55(c).
(b) In conducting the system analysis, the following information must be considered:
(1) Function and purpose of the system.
(2) The system’s operating environment.
(3) An outline of the system’s processes and procedures.
(4) The personnel, equipment, and facilities necessary for operation of the system.
(c) The certificate holder must develop and maintain processes to identify hazards within the context of the system analysis.

§ 5.55 Safety risk assessment and control.

(a) The certificate holder must develop and maintain processes to analyze safety risk associated with the hazards identified in § 5.53(c).
(b) The certificate holder must define a process for conducting risk assessment that allows for the determination of acceptable safety risk. Acceptable safety risk must, at a minimum, comply with the applicable regulatory requirements set forth in Chapter I of title 14 of the Code of Federal Regulations.

8

(c) The certificate holder must develop and maintain processes to develop safety risk controls that are necessary as a result of the safety risk assessment process under paragraph (b) of this section.
(1) The certificate holder must evaluate whether the risk will be acceptable with the proposed safety risk control applied, before the safety risk control is implemented.
(2) The safety risk controls must, at a minimum, comply with the applicable regulatory requirements set forth in Chapter I of title 14 of the Code of Federal Regulations.

Subpart D – Safety Assurance
§ 5.71 Safety performance monitoring and measurement.

(a) The certificate holder must develop and maintain processes and systems to acquire data with respect to its operations, products, and services to monitor the safety performance of the organization. These processes and systems must include, at a minimum, processes, and systems for the following:
(1) Continuous monitoring of operational processes.
(2) Periodic monitoring of the operational environment to detect changes.
(3) Auditing of operational processes and systems.
(4) Evaluations of the SMS and operational processes and systems.
(5) Investigations of incidents and accidents.
(6) Investigations of reports regarding potential non-compliance with regulatory standards or other safety risk controls established by the certificate holder through the safety risk management process established in subpart B of this part.

9

(7) A confidential employee reporting system in which employees can report, including, but not limited to: hazards, issues, concerns, occurrences, incidents, as well as propose solutions and safety improvements.
(b) The certificate holder must develop and maintain processes that analyze the data acquired through the processes and systems identified under paragraph (a) of this section and any other relevant data with respect to its operations, products, and services.

§ 5.73 Safety performance assessment.

(a) The certificate holder must conduct assessments of its safety performance against its safety objectives, which include reviews by the accountable executive, to:
(1) Ensure the certificate holder’s compliance with the applicable regulatory requirements in Chapter I of title 14 of the Code of Federal Regulations and additional safety risk controls established by the certificate holder.
(2) Evaluate the performance of the SMS.
(3) Evaluate the effectiveness of the safety risk controls established under § 5.55(c) and identify any ineffective controls.
(4) Identify changes in the operational environment that may introduce new hazards.
(5) Identify potential new hazards or safety issues and concerns.
(b) Upon completion of the assessment, if ineffective controls, new hazards, or potential hazards are identified under paragraph (a)(2) through (a)(4) of this section, the certificate holder must use the safety risk management process described in subpart C of this part.

§ 5.75 Continuous improvement.

The certificate holder must establish and implement processes to correct substandard safety performance identified in the assessments conducted under § 5.73.

10

Subpart E – Safety Promotion
§ 5.91 Competencies and training.

The certificate holder must provide training to each individual identified in § 5.23 to ensure the individuals attain and maintain the qualifications necessary to perform their duties relevant to the operation and performance of the SMS.

§ 5.93 Safety communication.

(a) The certificate holder must develop and maintain means for communicating safety information that, at a minimum:
(b) Ensures that all personnel are aware of the SMS.
(c) Conveys safety critical information.
(d) Explains why particular safety actions are taken.
(e) Explains why safety procedures are introduced or changed.

Subpart F - SMS Documentation and Recordkeeping
§ 5.95 SMS documentation.

The certificate holder must develop and maintain SMS documentation that describes the certificate holder’s:
(a) Safety policy.
(b) SMS processes and procedures.

§ 5.97 SMS records.

(a) The certificate holder must maintain records of outputs of safety risk management processes as described in subpart C of this part. Such records must be retained for as long as the control remains relevant to the operation.

11 12

(b) The certificate holder must maintain records of outputs of safety assurance processes as described in subpart D of this part. Such records must be retained for a minimum of 5 years.
(c) The certificate holder must maintain a record of all training provided under § 5.91 for each individual. Such records must be retained for a minimum of 24 consecutive calendar months after completion of the training.

(d) The certificate holder must retain records of all communications provided under § 5.93 for a minimum of 24 consecutive calendar months.

Do not confuse IOSA with SMS, although IOSA will require an SMS program, but then again we do not have to join IOSA or IATA for that matter.

3pt is kinda thick headed...but persistent. Like a bull in a China shop. Perfect management material. He will go far.

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.


Unless and IOSA auditor falls under one of the categories in 14 CFR § 121.547, I actually do NOT have a choice. Admission to the Flight Deck requires the approval of the FAA, the Operator, and the PIC. I'm not certain what category an "IOSA auditor" might fall into, but if the FAA hasn't approved them, I cannot allow them on the flight deck.

A Fleet Check Airman, on the other hand, is listed in our FOM as someone who I MUST allow, barring some safety of flight issue for which I would have to answer. According to this directive, denying a Fleet Check Airman would be the same as denying an FAA Aviation Safety Inspector.



OK, that's the second time you've done that, now I'm convinced you are either not reading my posts, you don't know how hyperlinks work, or your reading comprehension is seriously compromised.

Just for my information, you copied the text ...

Back in my Post #51, I cited the text, I hyperlinked it, and I quoted. Look here, I'll copy and paste it again so you won't have to look far.


Since I've already referenced it, what makes you think I need you to copy the text "for my information"?

Guess what's still missing from the text, whether I hyperlink it, or you copy and paste it, or we print it out and slap a few postage stamps on it and mail it? There is no requirement in the entire thing for the "QA" program which FedEx has created.

It is not required.

It is not required.

It is not required

It is counterproductive to try to ram such a program down the throats of pilots when there is no level of trust, and when a LOSA program already exists.

If you really want to do something good for The Company, convince your cubicle neighbors to drop it.






.

If this is needed and on the Up and Up then why does the company not approach the union for a MOU or LOA?

HIFLYR, thanks for quoting that entire article... ;)

Did not want to give him a easy out!!:D

Yeah, but you are using up all of our screen paper by doing that.:eek:

What the heck does this mean and where is soon to be China? Weird.

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.

1 link will do.



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.






.

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.

Enders. All I need to remember...

(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.

+1 agree +1

Exactly!!








[filler]

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!*? :eek::confused: