Consider the difference between a Performance and Prescriptive regulatory environment
A prescriptive or “compliance” based environment consists of rules which need to be followed, such rules are clear and to measure accomplishment is relatively straight forward in respect that it is a Yes or No situation. Where a “No” translates to a “Finding” either as a non-conformity with the regulations or a non-conformity with the organisational process and procedures.
A Performance based environment on the other hand looks at the requirement as an objective which needs to be met by the organisation. The steps which need to be taken are variable and specifically relate to the achievement of this objective.
Feedback is achieved by measuring the effectiveness of the steps against the expectation.
Where is the challenge?
Well there are in fact 2 quite significant challenges:
The first is the organisations ability to deliver the required management approach and understanding which is necessary to drives the process.
The second is the ability of the regulatory authority to “audit” the organisation and to determine if it is meeting expectations and requirements.
A clear understanding of the role and responsibility related to accountability is fundamental and if such widespread misunderstanding exists a degree of responsibility must sit with the regulatory authorities who it seems are not validating this essential requirement.
Partly as a result of “inadequate” communication regarding roles and responsibilities from EASA there is confusion amongst many senior managers within industry that in in the same way the Quality Manager was “Responsible” for Quality (SIC) the Compliance Manager is “Responsible” for Compliance.
As we know the reality is somewhat different – The Compliance Manager is responsible to determine gaps which are then the responsibility of the business area owner to rectify but dealing with the immediate issue understanding the root cause and developing appropriate mitigations which will remove the problem going forward.
Does it get better?
Well maybe not at first! – An organisation which is struggling to understand at a senior management level the difference between Quality Control / Quality Assurance / Safety Assurance / Compliance and Risk is not going to function exceptionally in the area of development of Performance Based Process and Procedures.
A positive step forward is made when the organisation appreciates that the Safety Management System (SMS) is not only to mitigate against exposure to accidents but rather as an organisation tool to identify exposure across many elements of the business resulting in a positive impact on the both the effectiveness and productivity of the organisation.
Sofema Aviation Services www.sasssofia.com and EASAonline.com www.easaonline.com offer regulatory and vocational training compliant with EASA principles and objectives.
For additional details please email office@sassofia.com
