Surveillance Activities

By Didrik Strand offroadpilots@gmail.com

The difference between surveillance and oversight is that surveillance is close observation of an enterprise, being airport or airline under suspicion while oversight is something that is left out, missed or forgotten. Surveillance is all activities directly related to evaluating an enterprise's compliance with applicable regulatory requirements including assessments, program validation inspections and process inspections. The regulator does no longer conduct oversight, they do close observations of systems, processes, procedures and work performance activities. A system is a group of inter-dependent processes and personnel working together to achieve a defined result. A system comprises policies, processes and procedures. It is through systems that enterprises should achieve a state of compliance to their regulatory requirements on an on-going basis.


Surveillance is to focus on the hazards.
The regulator’s observations are not only of your regulatory compliance, but includes all activities affecting your enterprise. This includes activities that are unrelated to safety in operations. When an enterprise contacts the regulator with a question, a red flag goes up and the regulator elevates the risk level for that enterprise. Should you be brave enough to ask the same question several times, your risk level quadruples. Surveillance is not oversight, but close observations of your processes and personnel involved. This information is published in aviation advisory circulars and should be known by all enterprises. It therefore becomes crucial for the success of the Safety Management System that enterprises take it upon themselves to monitor their own activities. No organization has the capacity to conduct 100% of the monitoring, 100 % of the times at 100% of the locations. The only way for an enterprise to ensure process compliance is to apply statistical process control (SPC) of operations. Events unrelated to safety in operations takes time away from operational tasks and is a direct hazard to aviation. When applying this concept to findings, that corrective actions for findings are unrelated safety activities, an enterprise with multiple findings becomes an elevated safety risk to aviation with an increase in unidentified hazards and there is less time to ensure safety in operations. 


Knowing all this places the accountability on an enterprise to ensure that their processes conform to:
  1.           Regulatory compliance;
  2.           Policy compliance; and
  3.      Operational Safety compliance.

Safety is paramount, but regulatory compliance is first priority. Without regulatory compliance the platform, or base for operations does not exist. Policy compliance is the second priority. Without policy compliance, there are no operational controls. Operational safety compliance is 3rd priority.

Performance-based regulations is a blank sheet of paper to write your history.
Without operational safety compliance there is no customer service, there is no project solutions quality leadership or Safety Management System in place. 

It has been said that if the regulations don’t state you must comply with a task you don’t have to. With the implementation of SMS and performance-based regulations, this is exactly why an enterprise needs to take it upon themselves and establish performance compliant processes. Times has past when the regulator takes care of your safety. The regulations itself cannot establish your processes. However, if the regulator makes an attempt to establish processes for an enterprise there will be an apparent conflict. This is simply because the regulations are performance based while the regulator expects implementation of prescriptive based regulations. 

When organizational polices, processes, procedures and common practices are established, an enterprise has developed their tools for safety in operations and a Safety Management System. Performance-based SMS regulations are here to assist an operator, being airport or airline, with performance details that are compatible with the safe operations of an airport or aircraft. 

Catalina9

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