When bureaucracy and overregulation pose a major hazard to safety

MedEwok wrote:

As an emergency physician, I also question the safety advantage of having a person on the field who can call the fire bridge in case of a crash. Strictly from a medical perspective, it seems unlikely to experience a crash scenario where the fire brigade – unless on standby at the airport, fully equipped, which is only the case at major international airports anyways – will make a difference to your survivability.

At our base, LESB, with AIP-restricted operating hours, the fire brigade is manned every time the airport is open. This is used by the airport operator as the official reasoning behind the restriction in operating hours. (In reality it is a cover up to a labour dispute, but perhaps that is off-topic, other airports may have different reasons. Maybe such “unjustifiable labour usage” is the only way for the community to keep these airfields open, more on that in the flying in Greece topic).

In 20 years I have been flying at Son Bonet, LESB, there have been several accidents on our island with aircraft flying into or out-of the airfield. Other than a couple gear-up landings with very minor consequences from the fire brigade point of view, (no fire, no personal casualties, no spilt fuel…) not a single time has one of those accidents occurred within the airfield perimeter, and hence the local (non-airport) fire brigade had to be called-in. The airport fire brigade made no practical difference. That does not mean there could not be an accident (hopefully not) where they could be of use, it is just that the risk is statistically low, and the pilot/operator should be the one to assess that risk, in the context of the remaining risks and benefits affecting his flight.

Off_Field wrote:

I have a suspicision that some required major maintenance does more harm than good. We’re all aware of problems / infant mortality following maintenance. I’m not sure how one could gather enough evidence to prove or disprove it though.

I have been witness to several events along this line.

Not long ago a clever guy in the Spanish aviation authority brought about a regulation requiring that for engines to be flown beyond the OEM calendar recommendation for OH, you needed to do a very thorough inspection every year. Amongst other items, this required the removal of all removable cylinders.

In my personal experience I have never seen an engine failure that can be purely attributed to calendar age on an otherwise airworthy engine. I personally know of two cases where incorrect cylinder installation has lead to engine failures, a couple more due to other maintenance errors, two more due to pilot error. This is my personal sample, but I am certain the accident databases portray a similar picture. Fortunately the authority reversed their ruling.

Cessna SIDs (aging aircraft inspections) could be a similar thing, where a lot of dissassembly is required for some of the inspections. On some individual aircraft the risk/benefit is unbalanced, on others it is more than justified.

This, like many other ruling and procedures that could be listed in this thread can be linked to one of two origins:

a) CYA, and/or
b) Bad practices from the operators/maintainers (in this case, where decrepit old airframes were repeatedly signed off as airworthy based on a pure checklist approach or otherwise, and/or owners refused to realize and produce the effort required to keep their aircraft up to par)

Both are and have been industry-damaging practices

Along a similar note, one of the most widespread cases of normalization of deviance has been Part-21 for light aircraft, in case where:

a) An undocumented or non-EASA approved minor mod has remained installed on an otherwise airworthy aircraft without further noting or ado
b) For old or orhpan aircraft, where a Form One could not be produced for certain unavailable parts

The issue with the above is that it causes helplessness and legal uncertainty, placing owners ransom to their CAMOs, as changing CAMO is the occasion where the next CAMO will ground your aircraft for one of the above reasons. I personally know of two severe incidents where the origin was directly related to these practices.In one case, the new CAMO induced additional risk by rectifying the “non-airworthy” situation (FAA-legal but not EASA-legal) and installing an EASA-approved but less safe system. The known deficiency addressed by now removed FAA mod, later caused the single-engine aircraft to lose all its oil while in flight at high altitude.

Fortunately, EASA has reversed course on those counts for ELA1 and ELA2 aircraft

So, to summarize, the current disputed examples list is, in no particular order:

• Airport closing times (this impacts safety by avoiding the linking of the time of operation of flights and their routings to utility, wx, persons duty times, and other safety factors)
• Excessive logging requirements (though it is unclear if and how much this impacts safety)
• Excessive customs requirements (this impacts safety through the impossibility to operate a flight at the appropriate time, and diversion of flight planning resources)
• MTOW limitations (especially on ultralights, this impacts safety through normalization of deviance)
• Restriction of overlay approaches (ie boat-anchor ADF onboard, this impacts safety by making either otherwise safe approaches unavailable or normalization of deviance, ie flying illegal GPS approaches)
• Aircraft certification gold-plating (this impacts safety by diverting resources into items with little safety benefit, thus making aircraft more expensive, fewer advances available and the overall fleet smaller and older)
• Excessive maintenance requirements not proportionate to safety benefits (this damages safety through disproportionate diversion of resources and the direct introduction of new risks)

please keep adding examples!

Jujupilote wrote:

This thread reminds me, that european GA can’t lobby for anything because we can’t agree on something to lobby for
We all face different limitations and have different acceptances of these limitations.

My point is not addressing the symptoms, which you are right, they vary, but the illness.