ASG Position on Safety Matters

Issues of concern are wide-ranging and extend far beyond those of fire and explosion which led to the Group's formation in 1964. Aviation is an ever changing and developing industry with new technological advances being introduced on a regular basis. Keeping abreast of such technology can place undue demands on aircraft operators and flight and cabin crews. It requires strict adherence to standard operating procedures (SOPs) and comprehensive initial and ongoing training in Crew Resource Management (CRM) if accidents or major safety incidents are to be avoided. Indeed, with the mandated introduction of Safety Management Systems it is to be hoped that Crew Resource Management may be expanded to become Company Resource Management.

Commercial pressures to keep aircraft flying can place severe strains upon maintenance engineers and ground staff, many of whom opt out of the maximum 48 hour week and are often found working long hours throughout the night to meet scheduled departure times, on occasions reaching up to 75 - 80 hours work per week.

'We believe this is unacceptable and that Aircraft Maintenance Engineering personnel should have their duty hours regulated by EASA as is the case with pilots, cabin crew and ATCOs. There are various options available for such regulation. These range from classification of AME's as 'mobile' workers (similar to Flight and Cabin Crew), through to implementation of a Fatigue Risk Management System (FRMS), perhaps as part of the MO or AOC holders safety management system. With the recent economic downturn and with Operators cutting back and/or reducing staff, those remaining are being required to work ever longer hours. The Air Safety Group views this situation with some concern, particularly in the light of recent maintenance-related safety incidents and fatigue-related safety accidents and incidents within Commercial Air Transport operations. The Group has expressed its concerns to the Safety Regulation Group, CAA and will continue to press for a resolution to the excessive hours being worked by some Aircraft Maintenance Engineers. Meetings have been held with Operators and the Royal Aeronautical Society to discuss this issue.

In addition to the issues referred to in the above paragraph, the Air Safety Group has been concerned with all aspects of cabin safety, including the following: -

Increasing amount of carry on cabin baggage with the possible overloading of the overhead baggage bins; certification standards for egress and evacuation; fuel tank safety; cabin air quality; harmonisation of airworthiness and operational standards; air traffic control; safety oversight; occurrence reporting; disruptive passengers; protection against terrorist attack; external and internal CCTV monitoring; FDR/CVR duration and content; and use of mobile phones and other Personal Electronic Devices (PEDs) by passengers.

There has also been a major change in the regulatory scene with the formation in 2003 of the European Aviation Safety Agency (EASA). This agency is progressively taking over many of the responsibilities of the various existing European National Aviation Authorities (NAA's) and by April 2012 this will include all operational matters.

While all the issues referred to above have been matters of concern, the Group does not necessarily have a definitive position on each and every one, for it is acutely aware of the sometimes sound reasons for delay in introducing possible safety improvements and of the difficult balance to be struck between economics and safety. The following pages contain the Group's comments/positions on a number of the issues listed above.