“He who troubles his own house will inherit the wind, …” Proverbs 11:29
The last two articles I wrote reference theology. Although I do enjoy a good theological discussion, it is not my intention to wax dogmatic in my articles. I find Scripture to be multi-interpretational, meaning that there is more than one meaning behind passages written in the Bible, Quran and the Torah.
To me, the above passage from Proverbs can be interpreted that, “He who troubles his own society, inherits nothing;” you can substitute family, house, industry, etc., for the word ‘society’. It is part of a quote; I don’t normally sub-quote anything because I think it takes the author’s intent out of context. However, I am going to take some liberties with this quote.
My students often ask me why I dislike the influence of the National Transportation Safety Board (NTSB) so much. My answer is: I don’t hate the NTSB, but I disagree with a lot that they say. In fact, I respect many of the technical people who conduct the investigations. But, to be honest, I’m not so crazy about the track record of the Federal Aviation Administration (FAA) either. Both organizations suggest a decision-making process, saturated with ignorance. And here’s why …
Bureaucracy, plain and simple. Trying to communicate safety concepts through any bureaucracy, whether industry, airline, manufacturing or within government is like falling through the ice on a Minnesota lake; you, the safety advocate, are under the ice and attempting to break upwards through the frozen layer. This analogy may seem overly dramatic, yet it’s the impossibility of breaking through that speaks to my point.
Has anyone ever tracked the success rate of an NTSB recommendation? Have aviation professionals taken the time to contest the findings of the NTSB or FAA, and thus the effectiveness of changing, eliminating or writing regulation?
My old friend, Bill O’Brien – a man who commanded sold-out houses for his seminars in which mechanics would sit on the rafters to hear him speak – once told me that to change a Federal Aviation Regulation (FAR) was a three-by-three investment. What this means is that every change to an FAR, e.g. a word or punctuation, costs three million dollars and took three years to complete. Bill told me this in 2004 (he passed away in 2009), so it is likely that the cost has risen considerably. But he was correct, because I’ve taken part in FAR rulemaking; the $3,000,000 cost he quoted, it turns out, is on the low end of accurate; it is also a conservative estimate to say three years; it is usually more.
Look at the Colgan flight 3407 accident, Buffalo, NY, February 12, 2009; as with many accident investigations and resulting recommendations, the consequences of actions taken are not thought out. Colgan 3407 was a Regional feeder to a larger air carrier, Continental Airlines. Certain problems identified from Colgan 3407 stemmed from Regional pilot qualifications and Regional pilot domiciles; these were indigenous issues limited to certain Regional air carriers and not others. To explain why ‘cookie-cutter’ solutions cause more problems than good would take way too much space than my website would allow.
Let me elaborate: FedEx and UPS both fly cargo overnight. However, they are as different as apples and carrot sticks, in so many ways. When one looks at Delta, American, United and Southwest together, they would notice that the differences far, far outweigh the similarities, even though their missions are similar (they all move passengers and freight). Regional carriers flying for, e.g. American, are just as different from each other; they have to be, e.g. by the equipment they fly and the schedules they contract for. With these facts, how does the FAA blanket-manage air carrier certificates so diverse from each other in the same way? Answer: They don’t. Furthermore, they can’t.
This week, an industry panel is recommending to the FAA to relax dozens of safety rules brought about from the Colgan 3407 accident. Whether one agrees or disagrees with the proposals, they are indicative of the NTSB’s knee-jerk recommendation process; that the NTSB is either: (a) too inexperienced in how the commercial aviation industry has evolved to suggest sweeping aviation safety laws; or, (b) the NTSB never considers the consequences of such actions. The NTSB just makes recommendations and then they move onto the next accident; their job is done. The FAA, meanwhile, looks cowed; they have implemented, without reasonable consideration, rules that cripple the commercial air carrier industry without any thought to the NTSB’s ineffective recommendations.
It isn’t apparent to the Colgan 3407 victims’ families, who pushed for legislation spearheaded by the inexperienced NTSB’s recommendations, that the legislation isn’t working. It would shock them to realize that what they push so hard for has a negative effect that negates their argument. Worse, what they spent so much time fighting for has no effect at all.
Aircraft accidents are tragic opportunities; to suggest otherwise is both ignorant and cruel. Ignorant because we have an opportunity to learn from mistakes and, what should be a one-time event, turn the tables, capture our errors and purge them with no chance for re-occurrence; one time, no repeats. Cruel because if we don’t learn, if we shirk our responsibility as safety investigators, we condemn other innocent people to suffer the same fate as those lost in the original accident.
Let me give a good example: ValuJet 592 crashed on May 11, 1996; its tragic end brought to light a deficit of training in the Air Cargo Operations industry. What should have occurred as a result? Immediately, comprehensive training should have been designed and delivered in proper Air Cargo Operations, e.g. weight and balance, ramp personnel training, hazardous materials, contracting oversight, etc. These training programs should have been built strictly by those who know Operations best: Air Carrier and FAA Operations experts. The NTSB should have recommended that this happen right away; don’t wait for the report to come out, get it done. If only this happened, we might have avoided tragic accidents and the loss of life in, e.g. FedEx 1406 – 9/5/1996; Fine Air 101 – 8/7/1997; Air Midwest 5481 – 1/8/2003; UPS 1307 – 2/7/2006; UPS 006 – 9/3/2010; and National Airlines 102 – 4/29/2013.
Aviation bureaucracies have troubled their own house. As a result, we, the travelling public, have inherited nothing.