On 17 July 2014, the world was shocked to take note of yet another aircraft accident as #MH17 was lost over Ukraine.
While world leaders were quick to blame the loss on Russian supported rebels, we also saw a very quick attempt to scale-down the rhetoric with use of words like "Likely", "Possible" and "Probably"!
While I have no deeper affection for Russia and the communists than any other country or group in the world, as a safety professional with experience of handling aircraft accident investigations, it was shocking for me to note that blame was being attributed, and punishment being meted out in the form of economic sanctions even before any investigation had started or any hard evidence was available as to the root cause of #MH17's loss. This, in my personal opinion, only succeeded in creating an environment of deep mistrust, and the subsequent problems we continue to face in conducting a proper investigation of this event. Accident investigations need to be conducted dispassionately. The focus needs to remain on the truth and on preventing a recurrence.
While at this time, I prefer to reserve my comments on what caused this unfortunate event; this event does highlight for us the important question of who is responsible for safety of our air-routes?
I have read comments in the press that airlines are not security agencies and that countries need to follow ICAO regulations. To me, these comments are indicative of a lack of understanding of ICAO regulations, and of the very role of ICAO!
I had covered the subject of the roles and responsibilities of ICAO in a great depth in my book "Waiting...To Happen!" To briefly recapitulate, ICAO is a United Nations body that was formed with a mandate to coordinate development of appropriate International Aviation Safety Regulations.
Being a United Nations agency, it does not have any authority to supersede, or even instruct, any member state. All ICAO does is to promote an industry wide discussion and provide guidance material in the form of Docs and Annexes, that contain the industry "Standards and Recommended Practices or, SARPs". These are not laws. Every member state then has to evaluate these and either reject them (and inform the world of the deviation) or adopt them into their primary civil aviation regulation, which then becomes the law. The national government and the civil aviation regulator of each country are responsible for this in their respective countries. Of course this has to follow a process of hazard identification and risk management to understand all aspects of an operation. It is only after such a process has been completed can one decide which of the ICAO SARPs are applicable and which are not.
What is developed by ICAO, needs to have a very wide applicability across the technological, cultural, political and environmental scenarios world wide. For this reason, ICAO recommendations are often generic in nature and divided into two parts. A Standard is what represents the minimum acceptable level of safety (or defines the concept of "As Low As is Reasonably Practicable", also called ALARP) and can generally be applied across all the different cultures and regions worldwide. A Recommendation is what defines the additional measures possible if the local environment or operating conditions so require, based on the results of a risk assessment.
However, there are always certain unique situations where either application of a Standard is not practicable or results in an active hindrance to operations, without any commensurate enhancement of safety. In such a case, the national regulator (or the affected aviation business) is well within its rights to conduct an exercise in hazard identification and risk assessment to document this fact and to then arrive at a decision to deviate from an ICAO standard, in whole or part, after ensuring this fact is adequately promulgated through its AIP for information of international operators who would otherwise be expecting its applicability. Depending on the complexity of the case and results of the risk assessment, such a deviation may be applicable to the whole country at all times, or limited to a region, to a specific time or to a specific type of operation. What is important to note here is that such a decision can not be adhoc but needs to be based on the recommendations of a professionally conducted risk assessment involving various industry groups, professionals and stakeholders jointly examining all aspects of the operation.
This thought process then needs to percolate down to all levels of the industry and to all types of aviation operations, including management of the routes aircraft are permitted to fly in. Generally the national government of a country is responsible for regulation and control of its own air-space, and by extension of air-routes through that airspace. However, that does not absolve an airline, or another aviation business, from its responsibility towards management of its operational risks. ICAO, unfortunately, can play little or no role in this process because while it can try to foster international cooperation and data-sharing, it does not have any authority to regulate inside the borders of another sovereign state.
In final analysis, it is the job of an Airline/Aviation business, to manage its operational risks. The national government needs to create the political environment to make this possible. The national regulator needs to provide the leadership to facilitate and to regulate this activity. The national aircraft accident board needs to provide guidance based on which regulations are created and regulatory activities undertaken. But in the end, it is the respective aviation business that must remain responsible, and accountable, for management of its operational risks. There is just no other way to safely operate an aviation business!
The paradigm "Everybody, Somebody and Nobody" applies here. Everybody was responsible for safety of MH17, Somebody should have analyzed the hazards and assessed the risks, but Nobody did it! This is exactly why statements of truism like "Safety is Everybody's Business" do not work! Safety is the business of the professional Aviation services company and risk assessments need to become a way of life. Only then can this industry move forward from the eight losses that we have already suffered in seven months of this year. |
“Capt. Kohli focused his book on understanding and explaining the causal factors of the crash, rather than sensationalizing it or assigning blame. He highlighted areas of improvement in hopes of preventing the next accident and for these reasons, it is a privilege to present him with the Brownlow award.” Mr. Jon Beatty, President and CEO, Flight Safety Foundation.
| "'Into Oblivion' is a well written, educational and informative book regarding the disappearance of #MH370. It addresses the facts and sequence of events, explains the technical terms and then gives a methodical overview of the many theories that are swirling around the mystery. 'Into Oblivion' is a thought provoking yet respectful book and highly recommended!" Ms. Jennie Cullen, CreateSpace customer. |
"From the very beginning it is apparent there has been extensive research into writing this book. The book covers a lot of ground in human factors, and it does so with a laser focus on one of the most recent accidents in Indian aviation history. This book is a must read for all aviation professionals, enthusiasts, managers, regulators and, above all, bureaucrats. The author also highlights the role of management of safety by aviation operators by telling the story of obscure accidents which are lost in the noise of the bigger ones across the world" - Captain B Thomas - Part 135 Pilot, USA. | "A very interesting book that provides an accurate summary of the events that occurred during the mysterious flight MH370. The author explains important concepts of physics, aviation and communication satellites in a very descriptive way which helps understanding facts from hypothesis created by people and media worldwide. The book shows how much the tabloids and TV news distorted the events for their TRPs and sales. As the title says this tragedy should never be forgotten." Ms. Piedad Salomon, Amazon customer. |
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Books that tell fast-paced action stories and educate even as they entertain! |
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About the author |
An ICAO qualified and certified Safety Management Systems trainer, Captain Sam's Aviation career has spanned over 30 years. He has to his credit experience of military combat operations; air accident investigations; airport design, construction & management; and aviation support to the Oil & Gas Industry. He has also been a part of committees formed by ICAO and ACI for the development of International Standards and Recommended Practices. The authors last book, "Waiting...To Happen!" was awarded the prestigious 'Cecil A Brownlow publication award' for the year 2014 by the Flight Safety Foundation. |
Some reader reviews |
"Easy and exciting to read, this book shows how disasters could have been easily avoided if all professionals along the line had fulfilled their duties. It is a must to anyone who has any level of responsibility in a high-risk industry and doesn't want to just wait for disaster to happen." Mr. Cobut Thierry, General Manager AGIP Oil Ecuador. |
"I really enjoyed the book and your insights to the accidents. I liked your comparison to Dryden Air Ontario. When TC first mandated Human Factors training for Engineers in Canada that accident was a core study case ... What I thought was excellent in the book was that you highlighted both the similarities to the accident causal factors but the differences in the follow up to the event. The compassion of a management system of an airline to soccer team was great. It highlights the “blame the pilot” to the same likeness as blaming the goal tender. Most people can watch a match and see where errors are being made including off of the pitch. Yet with aviation there is still a tendency to blame the pilot. Once again Sam great job." Robert Cavers, Regional Aviation Adviser, Eni Australia Limited. |
"I found the book of Captain Kohli very interesting, well written and above all extremely useful for everyone involved in safety-critical systems." -Captain Antonio Chialastri, Human Factors Researcher, Italy. |
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