Remarks of Robert Sumwalt
Member, National Transportation Safety Board
to the
Regional Airline Association's
Presidents Council Luncheon
October 29, 2008
Washington, DC

 

Thank you very much for the opportunity to address the leaders of the US regional airline industry.

Today’s regional air carriers play a vital role in our Nation’s transportation system. For over 400 communities, without regional airlines, there simply would not be any air service at all. And for others, communities like my home town, Columbia, SC, the number of non-stop destinations has increased significantly due to service provided by regional airlines.

I joined the Safety Board in August 2006. My second week on the job started with a phone call from NTSB Chairman early on a Sunday morning. The call wasn’t social in nature - he was calling to inform me there had just been a crash in Lexington, KY, and it involved multiple fatalities.  

Since the Comair 5191 accident – the most recent crash involving a passenger fatality on a US part 121 air carrier, the US regional airlines have carried the equivalent of the entire US population – over 300 million people, without a single fatality. 

As you know, fatal accidents are extreme outcomes. For every fatal accident, there are scores of less serious precursor events that, if properly investigated, could signal conditions that lead to more serious accidents.

The FAA, NTSB, Flight Safety Foundation and many air carriers have realized that formal data collection programs are excellent means of proactively anticipating problems before becoming serious events.  

Today’s regional carriers carry about 20 percent of the airline passengers and account for about half of the Nation’s airline flights. With such a large percentage of passengers flying on regional carriers, it becomes even more imperative to ensure a single level of safety.

When a passenger buys a ticket on an airline to go from say, Columbia, SC to San Francisco, he or she may find that the flight from Columbia to a hub city is being operated by a regional airline that is partnering with a major airline, while the next leg will be on a major airline.

The tickets would be issued on the major airline’s ticket stock, the passenger would check in through the major airline’s ticket counter and they would board planes that are painted in that major airline’s livery. 

Doesn’t that passenger deserves the same level of safety while traveling on the regional airline portion of that flight as they receive on the portion flown by the major airline?

Let me give you an example of why I’m not convinced they always receive it.

Following s fatal regional airline accident a few years ago, the Safety Board issued safety recommendations calling for air carriers to implement Aviation Safety Action Programs (ASAP) and Flight Operations Quality Assurance (FOQA). Almost two years after those safety recommendations were issued, I did some research to see how many carries had implemented them.

ASAP programs encourage employees to report safety concerns in a non-punitive environment, which allows the air carrier to act on the information before an accident or incident occurs. I found virtually no difference between regional and major carrier in implementation of ASAP. 93 percent of 14 major carriers in my survey had ASAP programs, whereas 91 percent of the 21 regional carriers had these programs. I applaud major and regional carriers alike in their efforts to implement ASAP.

Unfortunately, regarding FOQA implementation, there was a sizeable difference between regionals and major carriers. FOQA is especially well suited for detecting exceedances that may occur during flights, such as high bank angles and unstabilized approaches, and assessing whether crews are conducting flights according to standard operating procedures. My survey found that 86 percent of the majors had FOQA programs, but only ten percent of the regional carriers had FOQA.

Why the disparity?

Although system safety tools such as FOQA have demonstrated safety benefits, the Safety Board is concerned that these programs are not used more widely by regional air carriers.

FOQA is a best practice for safety management. Many of your operating partners at the major carriers understand and demonstrate the importance of having FOQA programs. Yet, the majority of regional airlines do not have these programs. If it is something the majors feel they need to ensure highest levels of safety, then why don’t regional airlines also have them?

This is why I raise the question of equivalent level of safety.

Safety is a process – it’s not a destination. It is a process that involves systematically attending to, valuing and managing safety, just as you attend to, value and manage other vital business functions.

Organizations attend to those things they believe are important. For example, consider the financial well-being of your company. In order to survive, you manage your finances with a great deal of care and attention. You have a CFO. You use General Accepted Accounting Practices (GAAP), you conduct audits - both internal and external. You use financial controls and strict accountability. You sign a quarterly Sarbanes-Oxley statement to certify that your financial reporting is accurate.

And why do you do these things? Because you know that finances are important and you therefore properly attend to, value and manage them.  You make it a priority.

Do you place the same care and attention to managing safety as you do finances? How do you know what is going on in your operations? Is what you are looking at and measuring the right metrics for safety?

Following a regional airline accident four years ago, Safety Board investigators asked the airline’s chief pilot how they ensured that crews were operating according to standard operating procedures during repositioning flights. His reply: “Same way I do any flight being conducted to SOP. We look at the reports. We look at the numbers, you know, did they leave on time, did they not leave on time, and if anyone is on the jump seat doing a check. That’s the only way I know if any flight I have is being conducted per SOP.”

I hope you will agree that it is absurd that the chief pilot for an airline with 110 regional jets and 900 pilots would think that an acceptable metric of SOP compliance would be on time performance. Yet, that’s what he said.

Organizations attend to those things they believe are important. In this case, the chief pilot demonstrated that the priority was clearly on on-time performance, not safety.  

One way to ensure equivalent level of safety is to implement a robust Safety Management System (SMS). The Safety Board had recommended that the FAA require Part 121 air carriers to establish SMS programs, and the FAA intends to do so.

SMS incorporates proactive safety methods for air carriers to identify hazards, mitigate risk and monitor the extent that the carriers are meeting their objectives. It provides a formalized structure for a carrier to manage safety, in the same sense that other important business functions are managed.

SMS involves four major components:

1. Written policies, procedures and guidelines. You ensure these are in place and you audit to ensure you are actually following them.
2. Data collection and analysis. This involves collecting and analyzing data from all relevant sources, including ASAP and FOQA.
3. Risk management. Here you use your data sources to identify hazards, assess risks associated with those hazards and then make decisions based on managing risks to an acceptable level.
4. Safety culture. You know you’re on the right track to establishing a safety culture when your employees do the right things, even when no one is watching. Safety must start at the top of the organization and permeate throughout.  

By employing SMS, you can ensure that safety is properly attended to, managed and valued. You ensure that you are doing everything you possibly can to provide equivalent level of safety. But, a word of caution: it will only work if you actually implement the program in entirety, and only if you and your management team are totally committed to making it a way of running your business. A program that only “checks the boxes” does nothing except provide a false sense of security.

Best selling author John Maxwell says, “Leadership is about influence. Nothing more, nothing less.”

You are the leaders of the US regional air carrier industry. It is up to you to provide the leadership and the direction.

On behalf of the traveling public, my challenge to each of you: use your leadership influence to ensure that there is an equivalent level of safety.

To do anything less is simply unacceptable.

Thank you for your attention.