4.1.1.1 The following sections describe how DASA carries out the independent safety assurance functions identified in Chapter 3 of Volume 1. These functions are described in simple terms as:
Policy prescription and interpretation. DASA prescribes and interprets policy for the management of Defence Aviation safety, inclusive of the Defence Aviation Safety Regulation (DASR) and related standards.
Certification. Issue authorisations, including permits, approvals and licences, to certify that Defence Aviation platforms, systems, organisations and personnel have shown compliance with applicable DASR.
Oversight and enforcement. Conduct ongoing oversight and enforcement activities to assure compliance with the DASR and the continued validity of authorisations issued by DASA
Safety promotion. Promote Aviation Safety through education, training, and dissemination of safety information.
4.1.2.1 DASA is accountable to the Defence Aviation Authority to prescribe and interpret Aviation Safety management policy . This is fulfilled primarily through:
the promulgation and management of the Defence Aviation Safety Regulation and supporting standards
the provision of authoritative advice and guidance in relation to compliance with those regulations and standards.
4.1.2.2 DASA is required to ‘issue standards, inclusive of airworthiness codes, as required for the implementation of the DASR’ . In fulfilment of this responsibility, DASA prescribes and interprets the minimum safety requirements for the design of Defence aircraft, engines, propellers, and other aircraft-related systems and equipment that have an effect on aviation safety.
4.1.2.3 In prescribing design requirements for aircraft and aircraft-related systems, DASA recognises Airworthiness Codes issued by certain CAAs and MAAs and supplements these with additional requirements identified through ADF operational experience and/or CRE considerations. DASA periodically reviews prescribed requirements and assesses their continued applicability and suitability. Finally, DASA provides advice on the appropriateness of tailoring the prescribed requirements and the impact of non-compliance.
4.1.3.1 DASA is accountable to the Defence Aviation Authority to ‘issue authorisations, including permits, approvals and licences, to certify that Defence Aviation platforms, systems, organisations and personnel have shown compliance with applicable DASR’ . This activity is known as ‘certification’. The various authorisations DASA issues are described in chapter 5.3.
Introduction
4.1.4.1 The effectiveness of the Defence Aviation Safety Program (DASP) is underpinned by the suitability of, and the level of compliance with, the Defence Aviation Safety Regulations (DASR). Entities that operate within the regulatory framework seek to maintain compliance in two ways:
By developing and implementing organisational systems, supported by processes and instructions, that address the regulations
By developing feedback mechanisms to verify that the processes and instructions have been followed, and remain suitable for the purpose of meeting regulatory requirements.
4.1.4.2 Regulatory oversight contributes to aviation safety by identifying potential compliance concerns that may then be further evaluated, and addressed if necessary. Compliance with DASR also mitigates systemic and human errors that dominate hazardous safety events. Oversight is a systematic means of monitoring entities that operate within the regulatory framework for their level of understanding and observance of the regulatory system, as indicated by their policies and instructions and their adherence to them. A natural consequence of regulatory oversight is that it also provides insight into the suitability and effectiveness of the regulatory controls themselves, which is essential for their ongoing development.
4.1.4.3 A key component of an effective regulatory framework is ensuring that regulated entities have a clear understanding of when, why and how DASA may take action in the event of regulatory breaches or unresolved safety performance issues. The DASP enforcement policy supports compliance with the DASR through application of a consistent framework, and has been developed with due consideration of the Defence Aviation environment and associated Commonwealth legislation.
4.1.4.4 Accident and incident investigation also provides opportunity for oversight of compliance with required aviation safety processes and systems, as the structured means of determining and assessing the factors that led to the accident or incident should reveal any deficiencies regarding compliance with the DASR. However, accident and incident investigation is outside the scope of this chapter and further guidance can be found under chapter 4.4 Independent Investigative Capability.
Purpose
4.1.4.5 This chapter describes the principles that comprise the ‘Oversight and Enforcement (O&E)’ component of the DASP. This chapter applies to all entities regulated under the DASR, and any entity performing Defence Aviation functions that are regulated by a DASA-recognised Civil Aviation Authority (CAA) or Military Aviation Authority (MAA).
Regulatory Requirement
4.1.4.6 DASR GR.60 specifies regulated community compliance oversight and enforcement obligations; and requires all Defence, civilian and contractor entities operating within the Defence Aviation Safety regulatory framework to comply with the DASR. Regulatory compliance is subject to ongoing oversight at multiple levels within the framework, and results of the oversight are used to:
assure that regulated entities are complying with the DASR,
inform future DASR development, and
refine the processes and procedures that support implementation of the DASR.
4.1.4.7 Regulated entities are required to ensure that they comply with their applicable aviation safety processes and instructions. Ensuring compliance requires the systematic and routine review of organisational management elements, to assess compliance with the Authority's requirements relating to aviation safety. Each regulated entity should establish arrangements and processes, including a compliance review schedule, to ensure compliance with the DASR.
Oversight
4.1.4.8 Oversight is required to provide confidence to the Defence Aviation Authority (Defence AA) that Defence is executing Aviation operations safely, in accordance with legislated requirements. DASA’s Oversight function is executed through the O&E operating model at Figure 1, which assists to define DASA’s and regulated entities’ obligations to effectively establish and maintain DASR compliance.
4.1.4.9 The model at Figure 1 is separated into an upper (forward-looking) cycle (i.e. DASR implementation) and a lower (DASA feedback) cycle. Both cycles must be effective in their own right for an effective regulatory outcome. This is achieved by mapping each element of the model to corresponding personal accountabilities, responsibilities, expected outcomes and associated DASA (and other local) policy.
Figure 1: The Oversight and Enforcement operating model
4.1.4.10 Operating model components. The following model components apply:
Implementation loop 1A – Develop and maintain DASR. Refer DASPMAN Vol 1.
Feedback loop 1B – Aviation Safety reviews. Analysis and reporting on DASR compliance and safety intelligence is designed to provide senior decision makers, who have accountabilities under JD 21/2021, with a relative picture of DASP status, contemporary Aviation Safety issues, and an assessment of the aviation safety performance of regulated organisations. Issues raised can generate actions or be recommended for further monitoring. Reporting is achieved through the Defence Aviation Safety – Annual Report (refer section 2), and Airworthiness Boards (refer section 13).
Implementation loop 2A – Implement DASR requirements. Organisations subject to DASR are expected to implement locally-tailored and contextually-appropriate management systems to effectively comply with DASR. Systems are used to define any interaction of people, products (i.e. technology) and processes. However, outcomes from systems are rarely consistent, with their effectiveness continuously varying (e.g. through changes in local application context, staff churn and competencies, competing Service and organisational policies and priorities, etc). Entities are therefore expected to self-monitor and implement corrective actions as necessary.
Feedback loop 2B – Compliance assessments. Compliance assessments detect if documented management system meet required regulatory outcomes (i.e. ‘Present’ and ‘Suitable’ in the PSOE oversight construct—see below). DASA Findings document DASR non-compliances.
Implementation loop 3A – Using documented management systems. Once entities’ documented management system are approved and promulgated (i.e. found to be DASR-compliant at the time of the DASA assessment), DASA expects the entity’s staff, facilities, data, equipment etc to conform to that system11.
Feedback loop 3B – Conformance and continuous improvement assessments. Conformance assessments are designed to detect if staff, facilities, data, equipment, etc are conforming to the promulgated management system. By inference, if staff conform to DASA-approved systems, the organisation will remain compliant with DASR (i.e. ‘Operating’ in the PSOE oversight construct—see below). These assessments also look for local feedback data and safety intelligence that validate the documented management systems are effectively meeting DASR hazard control outcomes (i.e. ‘Effective’ in the PSOE oversight construct— see below).
4.1.4.11 Present-Suitable-Operating-Effective (PSOE ) model. The PSOE Model was introduced into civil aviation with the release of ICAO Annex 19 Safety Management in 2013, defining outcome-based safety management requirements against the hazard of compromised Aviation Safety. Importantly, when ICAO Annex 19 was released, an ICAO sub-committee (the Safety Management International Collaboration Group – SMICG) published PSOE construct guidance, ICAO (2012) - SMICG Safety Management System Evaluation Tool), providing it as an effective Annex 19 oversight methodology. Specifically, the PSOE construct allowed assessment of regulated entities’ maturity based on the effectiveness of hazard control implementation and incorporation of continuous improvement activities. The SMICG defined four progressive ‘stages’ of an entity’s Safety Management System maturity (ie PSOE). In turn, defence has tailored these PSOE definitions (see section 5.4) to make them applicable to all DASR( not just SMS), due to the advantages the PSOE assurance methodology provides.
4.1.4.12 Oversight activities are conducted against defined PSOE criteria, by qualified staff; who should be substantially independent of the area being reviewed. A PSOE assessment is carried out through two very discreet activities—the Desk Top audit and an On-Site Performance Assessment—as follows:
Desk top assessment. The Desk Top assessment (for ‘Present’ and ‘Suitable’), is an assessment of the entity’s documented management system (i.e. the organisational approval basis) including Orders, Instructions and Procedures (OIP) that are used to comply with the relevant DASR. The Desk Top assessment gathers evidence which demonstrates the proposed DASR compliance means are ‘Present’ and ‘Suitable’ for the scope of the entity’s authorisation.
On-site assessment. The on-site assessment (for ‘Operating’ and ‘Effective’) is carried out to provide assurance that the documented management system (i.e. the basis for the organisational approval) is operating as expected and effectively providing risk mitigation to the threats that the DASRs have been implemented to treat.
An on-site assessment can be conducted as part of an initial application for organisational approval or as part of an ongoing oversight program. The ongoing oversight program periodicity may be influenced by adopting a risk based approach for some organisations or operational activities influenced by safety intelligence information.
Enforcement
4.1.4.13 In addition to oversighting ongoing compliance with the DASR, DASA is also required to enforce the ongoing compliance of Defence Aviation organisations. The concept of enforcement within the DASP covers the following spectrum as outlined in Figure 2 below:
Reinforcement of requirements, through mechanisms which include providing education, updating regulatory material, and reinforcing positive behaviours.
Compelling compliance, through the raising of DASR Findings or issuance of Directives.
Deterrence of ongoing operations with non-compliances through the suspension or removal of a DASR approval.
Figure 2: Enforcement Model
DASA Enforcement Principles
4.1.4.14 The DASA enforcement policy is founded on the following principles:
Principle 1: Enforcement shall consider organisations/operator attitudes.
Enforcement will give due and equitable consideration to organisational attitudes and distinguish consistent or premeditated non-compliance, from non-compliance resulting from unintentional errors or deviations.
Principle 2: Enforcement action shall be graduated.
Enforcement action shall commence at the lowest level commensurate with the increase in risk to aviation safety and willingness of the regulated entity to address the non-compliance, and should be escalated only when necessary to secure compliance.
The rate of escalation is cognisant of the underlying aviation safety risk, prior interaction between DASA and the non-compliant entity, and the entity’s motivation and capacity to comply with the regulations.
Principle 3: Enforcement action shall be fair and proportionate.
Full details of the nature of the non-compliance will be disclosed, along with supporting evidence.
The response to the non-compliance will be proportionate to the identified breach and the increased risk to aviation safety.
Enforcement action will relate directly to the non-compliance and associated increase in safety risk.
In the interests of procedural fairness, regulated entities will be afforded the opportunity to review and respond to an identified non-compliance prior to enforcement action being initiated.
Principle 4: Enforcement decisions shall be independent and evidence based.
Enforcement decisions will be independent, transparent and underpinned by objective evidence.
Enforcement decisions will not be influenced by personal, political, capability or financial considerations.
Proportionate and Graduated response
4.1.4.15 The key factors influencing a DASA decision to escalate an enforcement action include:
the nature, seriousness and extent of the non-compliances, including the safety implications and the intent (if applicable) of the non-compliances;
the willingness of the organisation to address the non-compliances and ensure that they are not systemic;
the nature and sufficiency of available objective evidence of the non-compliances;
the action required to effectively and efficiently address the aviation safety risks that have been identified or are likely to arise;
the need to obtain expert assistance on a complex technical or operational issue, including legal advice;
the obligation to be fair, consistent, impartial and proportional in taking enforcement action.
4.1.4.16 While imposing a sanction that suspends or revokes an entity’s approval is a real and credible course of action, as part of a graduated response to serious and/or continuing non-compliances, this may not always be in the interests of the Service. If DASA is considering an unscheduled act of limiting, suspending or revoking an entity’s approval, the relevant Environmental Commander or Group Division Head is to be consulted before any proposed sanction that suspends or revokes an entity’s approval is imposed. This level of consultation is not required where a scheduled revocation takes place, for example removal or amendment of an organisational approval after an aircraft type is withdrawn from service.
Coordination with external bodies
4.1.4.17 In certain circumstances, DASA may identify a regulatory breach or safety concern that falls under the jurisdiction of an external CAA or MAA. If this occurs, DASA will consult with external agencies as necessary, to ensure a coordinated approach to any enforcement or remedial action is undertaken.
Introduction
4.1.5.1 The Defence Aviation Safety Authority (DASA) is responsible to the Defence Aviation Authority (Defence AA) for enhancing and promoting Aviation Safety through the implementation of a Defence Aviation Safety Program (DASP). The DASP promotes safety awareness and the sharing and exchange of safety information with the aviation community to foster the maintenance and improvement of safety; to support the development of a generative safety culture; and to assure the effective management of aviation safety risks.
4.1.5.2 The second function of the Defence Aviation Safety Program (DASP) is ‘Promote Aviation Safety’. This function comprises the following elements:
Aviation Safety promotion and dissemination of safety information
education, training and communication.
4.1.5.3 While Function 2 of the DASP explicitly directs ‘promotion’, all five functions require engagement with stakeholders. DASA cannot implement these functions in isolation. Ongoing engagement with stakeholders internal, external to the Authority, internal and external to Government is required to improve aviation safety outcomes and support capability.
Aviation Safety Promotion and Dissemination of Safety Information
4.1.5.4 A key tenet in promoting Aviation Safety is the two-way communication flow of safety information. Aviation Safety promotion can take many different forms, and cover a wide spectrum of activities— from dissemination of general information on Aviation Safety, to visits by DASA personnel. In either case, the establishment and management of relationships is paramount.
4.1.5.5 Figure 1 details the regulatory model, which includes DASA and the Defence Aviation Community. DASA uses its Engagement and Promotion Strategy to ‘manage relationships’ between the two entities.
Figure 1: The Regulatory Model
4.1.5.6 The ‘promoting Defence Aviation Safety through education, training and dissemination of safety information’ function employs a number of strategies to disseminate Aviation Safety information, including:
participation in dedicated safety stand-down days
publication of safety and regulatory magazines, (i.e. Spotlight)
sponsoring conferences and convocations
Defence Aviation Authority (Defence AA) safety messages
publishing the Defence Aviation Safety - Annual Report (DAS-AR)
maintaining safety information recording and analysis systems, such as Sentinel and Salus
posting safety information, such as Defence Aviation Safety Regulation (DASR) awareness briefs on the DASA web site
visits by DASA personnel.
4.1.5.7 Of particular importance is the ability to disseminate safety information in a timely manner, particularly in response to investigation of an accident or serious incident. The DASP provides several ways for DASA to disseminate urgent safety information, enabling the selection of the most appropriate way, cognisant of the specific circumstances.
4.1.5.8 Visits by DASA personnel to regulated entities are also an important means of promoting Aviation Safety and disseminating aviation safety information— providing the opportunity to discuss particular safety aspects in detail.
Education and Communication
4.1.5.9 All personnel within the Defence Aviation sector, who undertake or directly support aviation activities, should receive sufficient education to provide a general understanding of Aviation Safety. Commensurate with each person’s aviation safety responsibilities, they should receive further safety education. The DASA sponsors a wide range of Aviation Safety regulatory and technology training courses that personnel may nominate to attend.(see www.defence.gov.au/DASP/Training/Default.asp)
4.1.5.10 In addition to delivering and sponsoring Aviation Safety education, DASA also facilitates a number of opportunities for two way dialogue on Aviation Safety, including:
continuation training programs
DASA Newsbreak
DASA workshops
international visits to, or by, other regulators/safety bureaus or equivalent organisations
conferences and symposiums
regulated community forums
Airworthiness Boards and convocations
audits.
4.1.5.11 Commanders and managers within the Defence Aviation sector should encourage their personnel to take maximum advantage of the opportunities afforded to discuss Aviation Safety. Additionally, personnel should endeavour to further their Aviation Safety knowledge through the various means currently available. Members of the regulated community should advise DASA of opportunities to improve Aviation Safety communication so that DASA may consider implementing appropriate improvements.
4.2.1.1 DASA carries out two ensure functions in direct support of the management of Aviation Safety by the Defence aviation community:
provision of aviation safety management system products and services
provision of structural integrity engineering product and services.
(Reserved)
Introduction
4.2.3.1 The Directorate of Aviation Engineering (DAVENG) has a mandate to support Commanders to ensure structurally-airworthy platforms, and is the Defence Centre of Expertise (CoE) for Aircraft Structural Integrity Programs (ASIPs), Propulsion System Integrity Programs (PSIPs) and Non-Destructive Testing and Composite Technologies (NDT&CT).
4.2.3.2 In this capacity, DAVENG supports associated organisations with specialist advice, design services and training in these fields to maximise Defence capability. DAVENG also provides stewardship of sovereign capability initiatives and input into relevant policy frameworks.
4.2.3.3 For the avoidance of doubt, these services are provided by DAVENG in a separate capacity to the DASA Functions described in Chapter 4.1.
Aircraft Structural Integrity (ASI) and Propulsion System Integrity (PSI) and Services
4.2.3.4 ASI and PSI CoE Services. DAVENG supports the Defence ASI and PSI community with the following services:
advice on ASIP and PSIP establishment and execution
advice to CASG on ASIP and PSIP-related contracting and governance
CoE review of ASIP and PSIP products and outputs on behalf of CASG
technology specialist advice, such as supporting risk assessments
where appropriate, and when agreed, coordination and management of major ASI / PSI issues or tasks on behalf of CASG
support to Defence ASIP and PSIP policy artefacts on behalf of Capability Managers and CASG.
4.2.3.5 SI Sovereign Capability Stewardship. The SI Sovereign Capability encompasses the specialist technical capabilities that come to bear for critical and high-value SI activities where sovereign oversight and/or indigenous solution development is required to ensure Defence objectives are met. Under their Defence SI CoE capacity, DAVENG stewards the SI Sovereign Capability initiative, and chairs the Capability Management Board advocacy and governance forum. More information on the SI Sovereign Capability initiative and governance is available in the SI Sovereign Capability Strategy document, which can be provided by DAVENG to relevant parties upon request.
4.2.3.6 Training Courses. DAVENG sponsors the following three specialist courses:
ASI Familiarisation Course
Helicopter Structural Engineering Familiarisation Course
Propulsion Systems Engineering Familiarisation Course.
4.2.3.7 These three practitioner courses include components intended to teach ASI and PSI fundamentals and best practice, as well as components intended teach how ASI and PSI programs support DASR compliance.
NDT Appointments, Training, Certification and Authorisation
4.2.3.8 ADF NDT Responsible Level 3 Appointment. DASR 145.A.30(f) requires DASR 145 Maintenance Organisations (MOs) to appoint an NDT Responsible Level 3 (RL3) as the management position responsible for implementing a training and certification system compliant with European standard EN4179 Qualification and approval of personnel for non-destructive testing (refer DASP Manual Volume 3 Chapter 8.3.2).
4.2.3.9 To ensure all ADF Non-Destructive Inspection Technicians (NDITECHs) are trained to the same level of competency and to avoid the burden of each ADF DASR 145 MO appointing their own NDT RL3 and establishing NDT training and certification frameworks, DAVENG performs the Defence NDT RL3 function and manages all NDT training and certification activities for ADF members, Department of Defence employees and other staff members working within ADF DASR 145 MOs. The Director of Aviation Engineering appoints a suitably qualified senior NDITECH to be the Defence NDT RL3, with that individual approved by the DASA as a Form 4 Holder.
4.2.3.10 ADF DASR 145 MO NDT Certification Framework. ADF DASR 145 MO Quality Managers are responsible for ensuring that staff conducting NDT are certified by the Defence NDT RL3 (or delegate) before being authorised to certify maintenance. This includes:
staff who have obtained training from external training providers or third parties
external Industry or Contracted service providers working in an ADF DASR 145 MO.
4.2.3.11 In order to support ADF DASR 145 MOs, the Defence NDT RL3 maintains a NDT training and certification system (both initial and ongoing training / certification) that meets Defence’s needs and complies with DASR 145.A.30(f) requirements.
4.2.3.12 ADF DASR 145 MO Authorisation of NDT Staff. DASR 145.A.30(f) requires personnel who conduct NDT be certified in accordance with EN4179. Under Defence’s NDT certification system, the process followed is:
the Defence NDT RL3 (or delegate) certifies the technician as meeting the requirements of EN4179 for the applicable NDT method or technique, and subsequently,
the MO Quality Manager (or delegate) authorises the technician to conduct NDT maintenance within the scope and validity of the NDT certification.
4.2.3.13 The Defence NDT RL3 (or delegate) will issue Certification records via PMKeyS proficiencies (primary system) or a Minute. ADF DASR 145 MOs are to check the scope and currency of NDT proficiencies on PMKeyS prior to authorising staff to perform NDT. MO authorisations should only remain valid for the validity period of the applicable PMKeyS proficiencies.
4.2.3.14 Additional Information. More detailed information on NDT training and certification services provided by DAVENG, including training courses and frequently asked questions, is available on the DASA NDT&CT Website.
NDT Engineering Services
4.2.3.15 DAVENG NDT&CT Engineering Section develops NDT procedures, inclusive of introducing new NDT technologies, in support of ADF capability requirements. Engineering Section provides the following services to ADF units and ADF support contractors:
development of DASA approved NDT Instructions for Continuing Airworthiness (ICA), including:
platform specific procedures
NDT general procedures (AAP 7002.043-36)
CoE NDT advice on the selection of appropriate NDT techniques
assistance with the introduction of new NDT technologies in support of ADF capability requirements
testing and evaluation of NDT support equipment for introduction into the Defence inventory
technical review of platform-specific NDT publications and associated procedures
NDT Information Review (IR) of standards, practices and equipment
provision of other NDT CoE advice
manufacture of certified NDT reference standards.
Composite Repair Training and Certification
4.2.3.16 ADF DASR 145 MO Composite Repair Certification Framework. Personnel who conduct composite repairs must be trained and certified in accordance with SAE AIR4938 - Composite and Bonded Structure Technician Specialist Training Document (refer DASP Manual Volume 3 Chapter 8.3.2). On behalf of all ADF DASR 145 MOs, DAVENG conducts the training and certification (including re-certification) for all personnel who perform composite repairs. DAVENG staff issue the PMKeyS proficiency P124689 Composite & Adhesive Bonding Recertification upon successful completion of training requirements.
4.2.3.17 ADF DASR 145 MO Authorisation of Staff to Conduct Composite Repair. MO Quality Managers (or delegates) are responsible for verifying that technicians hold a valid PMKeyS proficiency for composite repair prior to authorising them to conduct composite repairs within an ADF DASR 145 MO. MO authorisations should only remain valid for the validity period of the applicable PMKeyS proficiency.
4.2.3.18 Additional Information. More detailed information on Composite Technology training and certification services provided by DAVENG, including training courses, is available on the DASA NDT&CT Website.
4.3.1.1 This section provides a description of Delegates of the Safety Authority (DoSA), their purpose, selection and scope of delegations.
Purpose
4.3.1.2 A DoSA is an individual who has been formally delegated a DASA responsibility (Letter of Delegation) by DG DASA and is considered an agent of the DASA when exercising that delegation. Delegations may cover general assurance function carried out by the Authority (such as Occurrence Report assessments or standards interpretation) or provision of DASA authorisations such as a Military Permits To Fly (MPTF). In all instances, the delegation scope must be linked to an explicit DASR obligation of DASA.
4.3.1.3 A DoSA performs assurance activities and critical roles that extend the competence and capacity of the DASA. DoSAs are placed within the aviation community to provide greater access and insight to regulated entities or activities. DoSA delegation scope varies, but is invariably linked to the role of an incumbent. This role may be as a senior engineer, test pilot and/or subject matter expert (SME) related to a specific platform or regulatory domain providing in-depth knowledge to support aviation safety assurance. When in proximity to the regulated entity a further benefit is realised with greater education and promotion for the organisation and DASA ‘eyes and ears’ in the field.
4.3.2.1 DoSA applicants are suitable for nomination by virtue of the roles they fill within the aviation community as senior members within their domain. Nomination for a DoSA is via a Form 104 submitted to the DASA Registry. Within Form 104 the member identifies the need, and the qualification, training and experience (QTE) that enables them to perform the role relevant to the scope of delegation being awarded. For each type of DoSA role, there are mandatory requirements that the nominee must meet. Annex A contains a baseline set of generic QTE requirements.
4.3.2.2 DASA staff will assess nominated DoSAs through a standard process to assess their suitability and provide a recommendation to DG DASA. The assessment process will usually involve two interviews; the first a preliminary interview to broadly assess an individual’s suitability to execute delegated authority functions, and a final interview with DG DASA to confirms the skills, knowledge and attitude of the applicant. If suitable, DG DASA will authorise a delegation to the individual.
4.3.2.3 A DoSA delegation is issued in the form of a letter directly from DG DASA. Delegates are provided an induction pack containing foundational information and are supported under the DASA Business Management System as a member of the DASA. Delegations are generally awarded to nominees filling a specific role. Upon leaving the position in which DoSA was awarded, eg formal posting, the members delegations are rescinded. In exceptional circumstances, extensions may be negotiated directly with DG DASA, via the applicable DASA directorate. DASA may amend or revoke a delegation at any time at the discretion of DG DASA.
4.3.3.1 The scope of duties and responsibilities of the DoSA depends on the capacity in which they have been delegated. The following list the categories functions delegated:
Occurrence Report Assessment for specific functions related to DASR 21, DASR M and DASR 145
Airworthiness Directives (AD) for specific functions related to DASR 21 Subpart A
Military Permit To Fly (MPTF) for other than flight test, including flight conditions, for specific functions related to DASR 21 Sub-part P
MPTF for flight test, including flight conditions, for specific functions related to ASR 21 Sub-part P
Military Certificate of Airworthiness (MCoA) for specific functions related to DASR 21 Sub-part H
Airworthiness Standards for specific functions related to DASR 21.A.16B
Other categories as considered necessary by the DASA for effective management of aviation safety.
4.3.3.2 The current classes of DoSA are:
Platform DoSA: A Platform DoSA has the widest scope of functions and may include assurance of Military Type Certificate Holder (MTCH) actions with respect to reportable occurrences, issue of MCoAs, approval of flight conditions and issue of Airworthiness Directives. The Platform DoSA is ostensibly delegated to the incumbent CENGR of the platform MTCH organisation and provides assurance in the DASR Part 21 Initial Airworthiness domain.
Flight Test DoSA: A Flight Test (FT) DoSA has a scope of functions that are relevant to assuring the safety parameters within the DASR Part 21, Subpart P Flight Test domain. Their function is to provide assurance through the approval of operational flight conditions specifically for Flight Test activities and issue of MPTF authorisations. Flight Test DoSAs will invariably have the qualifications, training and experience (QTE) of Flight Test qualified aircrew relevant to certain platforms and will provide the function as part of their position within Flight Test organisations.
Standards DoSA: A Standards DoSA has a scope of function relevant to a specific technology/design discipline domain. They perform the prescribe and interpret airworthiness design requirements and standards function for their assigned technology, and provide advice to command on the management of risk associated with non-compliance to the prescribed airworthiness design requirements. Standards DoSAs have been established to cover Aeronautical Life Support Equipment (ALSE), Air Navigation Services (ANS) and Aerial Delivery technologies, and are delegated to SMEs posted to the unit charged with managing these technologies.
Training DoSA: A Training DoSA has a scope of function to assure that the content delivered in DASR 147 Maintenance Training Organisations is suitable to meet the requirements of DASR 66 licensing.
There may be requirements/opportunities for other DoSA roles in the future, such as in Aircraft Type Certification. These will be identified and documented when implemented.
4.3.3.4 The concept of a Project DoSA has been discontinued since the scope was not linked to exercising any explicit DASR obligations. Notwithstanding this, the incumbent Project Engineering Manager (PEM) is required to have a comprehensive understanding of initial and continuing airworthiness DASR in order to ensure project acquisition activities enable the issue of appropriate and timely DASA authorisations, and subsequent handoff to the gaining MTCH and Continuing Airworthiness Management Organisation (CAMO).
4.3.3.5 For each class of DoSA, there are certain QTE requirements that the nominee must possess or have achieved. More information on the QTE and mandatory requirements of each DoSA will be provided through the nomination process. DASA will also endeavour to support additional training where possible to assist in the execution of the duties of the DoSA. DASA convenes a DoSA convocation to induct new DoSAs, discuss topical DoSA subjects and implement changes applicable to their duties.
4.3.3.6 When exercising their delegation, a DoSA is undertaking this function as part of the DASA, using DASA authorised procedures. Annex B contains specific functional DoSA information and reading. Whilst performing duties under the DoSA capacity, the DoSA is subject to internal DASA process audits in how they execute the functions specific for their scope.
4.3.4.1 A critical safety feature of the Defence Aviation Safety Program (DASP) is the separation between assuring and ensuring aviation safety through the application of the DASP. Given nominated individuals may be performing tasks that ensure Aviation Safety in their primary employment role, there is a natural concern for a conflict with their DoSA role of assuring Aviation Safety. In their capacity as DoSA, it is important that they are able to maintain objectivity (without undue pressure), evaluate their independence, have adequate time to exercise the delegation and maintain conscious awareness that the individual is representing DASA when exercising the delegation.
4.3.4.2 Where instances arise that the DoSA has been part of a decision that ensures aviation safety in their regulated community role, it is possible that their independence to assure aviation safety for the same issue is compromised. The DoSA is expected to have a level of competence and judgement to remove themselves from the assurance role and advise DASA.
4.3.4.3 Where the DoSA identifies conduct or behaviours in the regulated community that may represent DASR non-compliances, non-conformances or where associated hazards and risk are not being eliminated or minimised SFARP, the DoSA is expected to notify DASA of their concerns. DG DASA enables the DoSA to inform their office directly where the nature of the conduct is serious. It is important to note that the DoSA role only provides ’in the field’ oversight/awareness and the DoSA is not expected to execute DASA enforcement policy, which remains the duty of the relevant DASA Directorate staff responsible for that oversight and enforcement.
DoSA Qualifications, Training and Experience (QTE)
Specific Functional DoSA Information and Reading
4.4.1.1 Joint Directive 21/2021 The Defence Aviation Safety Framework directs DASA to establish an independent investigative capability aligned to ICAO standards and recommended practices (SARPs). This capability is provided by the Defence Flight Safety Bureau (DFSB) within DASA. This chapter describes how DFSB meets the responsibilities described in the Defence Aviation Safety Program Manual Volume 1 Requirements for the DASP.
4.4.1.2 Annex 13 Aircraft Accident and Incident Investigation to the Convention on International Civil Aviation, requires that the accident investigative authority be independent from State aviation authorities and other entities that could interfere with the conduct or objectivity of an investigation. Director DFSB is accorded specific responsibilities and the power for autonomous action outside both DASA and the command chain to directly report matters of concern to the Defence Aviation Authority (Defence AA). DASP Manual Volume 1 details DFSB’s functional independence of DASA Directorates and powers for autonomous action outside of DASA and the command chain.
4.4.1.3 DFSB and the Australian Transport Safety Bureau (ATSB) have a Memorandum of Understanding (MoU) for cooperation relating to transport safety investigation. The MoU deals with mutual assistance, sharing of expertise, mutual training opportunities, joint and parallel investigations, and the participation by members of either organisation in investigations carried out by the other organisation. The MoU is available on the DFSB intranet site.
4.4.1.4 DFSB is also responsible for promoting and enhancing aviation safety, which requires more than policy and processes. DFSB recognises the complex social and cultural work environments within the Defence aviation community, and works to positively influence safety attitudes and behaviours.
4.4.2.1 In accordance with DASP Manual Volume 1, DFSB is responsible for a number of functions in support of both retrospective investigation of Defence accidents and incidents and proactive approaches to preventing military accidents and enhancing flight safety. These functions are:
Aviation safety reporting framework. DFSB maintains the Defence Aviation safety reporting framework by:
Developing and maintaining the Defence Aviation safety reporting system. DFSB meets this requirement through the management of the Defence Corporate Safety Reporting Tool: ASR in Sentinel. ASR in Sentinel provides a closed loop process for the reporting, investigation, tracking and review of aviation safety events and issues. Sentinel is available to all Defence aviation personnel with access to the 3Defence Protected Environment (DPE). DFSB maintains an ASR Service desk, at asr.servicedesk@defence.gov.au or (02) 5130 7704 to provide ASR related support to the Defence aviation community.
Developing and maintaining the appropriate documentation to define the reporting framework. The Defence Aviation Safety Manual (DASM) defines the reporting framework, including reporting and notification requirements, categorisation and classification of aviation safety events, and types of reporting. Additional guidance material is available on the DFSB intranet site.
Establishing a confidential reporting scheme to enable confidential reporting of issues that effect, or might effect, aviation safety. DFSB provides and maintains a confidential reporting system that allows individuals to report aviation safety issues or concerns where they are unwilling to use the normal aviation safety reporting system for fear that they may be disciplined, ridiculed or otherwise disadvantaged if they do so. The DASM provides policy and guidance on confidential reporting. Individuals can report via email directly to Dir DFSB or through the link on the DFSB intranet site.
Defining notification requirements and mechanisms (immediate and routine) for aviation safety reports. Notification requirements and mechanisms are defined in the DASM, and guidance is provided on the DFSB intranet site. All aviation safety events and issues must be reported into ASR in Sentinel, or through the offline ASR form AE774. Immediately reportable matters (as defined in the DASM) must be notified to the DFSB Duty Officer on (02) 6144 9199.
Defining taxonomies to facilitate safety information exchange that are compatible with the ICAO Accident/Incident Data Reporting system and broadly aligned with those of the Australian Transport Safety Bureau (ATSB). DFSB has embedded the aviation safety reporting taxonomies within ASR in Sentinel. More information is available on the DFSB intranet site. DFSB also manages the Aviation Safety Intelligence Portal, Salus, which supports the sharing, exchange and analysis of safety data within Defence, and between DFSB and the ATSB. The MoU (referenced in para 3) further supports alignment of safety reporting and information exchange.
Defining the classification system for aviation safety reporting. The classification system for aviation safety reporting in Defence is described in the DASM. Aviation safety events are defined by both realised and potential consequences with reference to Personal Injury Level (PIL), Aircraft Damage Level (ADL) and Perceived Risk Level (PRL). Aviation safety events are classified in accordance with Table 1. More information is available in the DASM or on the DFSB intranet site.
|
Event Classification |
Description |
|
Class A |
PIL of fatal ADL of destroyed |
|
Class B |
PIL of serious 3ADL of Substantial PRL of High or Very High |
|
Class C |
PIL of minor ADL of Moderate PRL of Medium |
|
Class D |
PIL of No Injury ADL of No Damage/Minor Damage PRL of Low or Very Low |
Table 1: Event Classification
Developing processes to monitor the health of the aviation safety reporting system. DFSB monitors the aviation safety reporting system through internal mechanisms, including daily review of aviation safety reports and periodic research activities to examine specific features of the system, such as usability and data quality.
Safety data collection and processing. DFSB has established and maintains safety data collection and processing systems to capture, store, and aggregate and thence enable the analysis/exchange of safety data and safety information. Safety data refers to a defined set of facts or set of safety values collected from proactive or reactive safety related activities. Safety information is created when the data has been processed, organised, integrated and analysed in a given context. DFSB collects and manages safety data and information from:
DFSB safety investigations.
Aviation safety reports and investigations from within the organisation’s safety management systems and provided to DFSB (primarily through ASR in Sentinel).
Data collected by DFSB during the course of cultural surveillance activities (e.g. cultural surveys).
In addition to ASR in Sentinel, DFSB also maintains the following systems:
Salus. The DASA Salus application is designed to support the sharing, exchange and analysis of safety data within and between DASA and the Defence aviation community, with the goal of enhancing aviation safety. Salus is available on the DPE, and more information and guidance can be found on the DFSB intranet site. DFSB maintains a Salus service desk, at salus.servicedesk@defence.gov.au, to provide support and guidance to users.
Snapshot Survey. The DFSB Snapshot Survey is an annual survey administered to personnel from Air Force, Army Aviation, Fleet Air Arm, Air Domain and other selected domains. The survey captures information on a broad range of issues that impact the safety, performance and overall health of the participating organisations. DFSB generates a range of tailored Snapshot reports targeting different levels of the organisation, and aims to provide information on the workgroups safety/organisational climate, benchmarked against other units. The reports allow commanders to track changes from one year to the next, identify risks, and assess the effectiveness of recent interventions. More information is available on the DFSB intranet site.
Joint Agency Aviation Safety Analysis Coordination Group (JAASACG). DFSB is also a member of the JAASACG, which facilitates the data analysis and reporting function under Australia’s State Safety Program. Conducting safety data exchange and analysis through the JAASACG assists in maintaining strong stakeholder relationships and allows safety data to be shared and research and analysis efforts coordinated between Government Agencies to improve aviation safety.
Analysis, Research and Review. DFSB conducts a range of applied safety data analysis and research activities to inform DASA, the Defence Aviation Authority and the broader Defence aviation community. DFSB produces a range of products, including:
The DFSB Annual Review of Defence Aviation Safety Statistics, input to the Defence Annual Safety Annual Report, Safety Snapshot Culture Survey Reports, and supplementary reports as identified through ASRs and safety surveys.
Support to command in the use of safety data systems, including guidebooks, service desk support, training databases, and training content for DFSB safety courses. These products are available on the DFSB intranet site.
DFSB staff members attend a number of aviation safety, investigation, human factors and non-technical skills forums and conferences in order to provide internal learning opportunities, benchmarking against international and domestic military and civilian agencies, and to support industry wide learning.
DFSB produce and support targeted human factors programs, primarily fatigue and non-technical skills related policy and guidance. These programs are described in the DASM, and through guidebooks and resources on the DFSB intranet site.
Independent Investigation. DFSB provides independent investigation and reporting of all accidents, selected incidents and selected systemic safety issues. This is achieved through:
All Defence Aviation Class A and select Class B events are independently investigated by a DFSB Aviation Safety Investigation Team (ASIT) which reports directly to the Appointing Authority (AA). The AA is the designated commander at the appropriate level authorised to initiate and close aviation safety investigations. The DASM describes the appropriate levels and delegations. The ASIT operates under the procedural direction of DFSB.
DFSB investigations are functionally independent of the DASA regulatory directorates, and in general, of any other party of the entity that could conflict with, or influence, its objectivity.
The sole aim of a DFSB investigation is to prevent further occurrence and enhance safety outcomes through the identification and remediation of local and systemic deficiencies, and the improvement of risk controls. DFSB investigations do not apportion blame or liability.
DFSB investigations are conducted consistent with the international standards outlined by ICAO, and those described in the Australian Transport Safety Investigation (TSI) Act 2003. Given the unique nature and demands of military flying, a DFSB investigation may deviate from these provisions in such a manner that is considered necessary or appropriate under the specific circumstances. Additional guidance can be found in the DASM and on the DFSB intranet site.
In the case of Class B events, DFSB may decide not to undertake the investigation, leaving the responsibility to the command chain. This decision will be made in consultation with the relevant environmental commander, and taking into account the safety implications of the event, the suitability of the event for investigation by DFSB and the breadth of lessons likely to be learned from the event.
DFSB provide specialist advice and support to aviation safety investigations undertaken within the command aviation Safety Management System.
A Class A or Class B Defence event that involves a civil (VH registered) aircraft could be subject to an investigation by the ATSB in accordance with the TSI Act 2003, their priorities and mandates for investigation. The carriage and conduct of the investigation will be negotiated through DFSB in accordance with the extant ATSB/DFSB MoU.
DFSB is responsible for the Defence Aviation Cockpit Voice Recorder (CVR) and Flight Data Recorder (FDR) download and analysis capability. DFSB Investigation team have the specialist skills and equipment to support this capability. Policy and guidance on download and analysis of the CVR and/or FDR is found in the DASM.
DFSB must be notified of all Class A and Class B events involving Australian Air Force Cadets (AAFC) in the course of their duties; however, all reporting and investigation resides within the AAFC’s Aviation Safety Report system.
Safety awareness, knowledge and action. DFSB is responsible for fostering safety awareness, knowledge and action through promotional and education programs, and utilising the outcomes from safety analysis, research and investigative functions to influence organisational learning. This is achieved through a range of programs including:
Aviation safety policy. DFSB is responsible for the development and maintenance of key aviation safety policy, including the DASM, which supports the implementation of efficient and compliant aviation Safety Management Systems, and the Aircraft Accident WHS Manual to support the safety response to military aviation accidents and incidents.
Aviation safety training. DFSB provides aviation safety reporting, investigation and safety data related education and training, through the provision of Aviation Safety Officer Initial and Advanced courses, Non-Technical Skills Trainer Course and the one-day Aviation Incident Investigation Course. DFSB is also responsible for the integration of aviation safety and non-technical skills content into the Defence training continuum.
Aviation safety awareness. Through investigations, analysis of safety data, research reports and engagement with industry and military partners, DFSB identifies key lessons and safety issues. DFSB has a range of products and services to support the integration of those lessons into aviation safety policy and training, and to support positive organisational learning. These products include promotional materials, guidebooks and training materials and are available through the DFSB intranet site.