1. SUMMARY

  1.1. Madam Chairman and Members of the subcommittee:

  I am Charles Higgins, Vice President for Airplane Safety and Airworthiness of the Commercial Airplane Group of the Boeing Company. I am pleased to provide comments regarding commercial aviation system safety.

  1.2 Boeing has an unwavering commitment to the safety of its products and the world's air transport system. The future of our business depends on keeping our products and the system safe. The following paper provides Boeing comments regarding commercial aviation system safety, and our view of the important role that governments and the civil aviation authorities play in aviation system safety.

  1.3 A safe system is very important to the UK and its economy. THE UK and its industry account for 9 per cent of the aviation industry. As the economy becomes more global and supplier and airline alliances become more prevalent, it makes less and less difference where an aviation accident occurs. If confidence in aviation is lost in one area of the world, it affects us all—government, manufacturer, airline, and civil aviation authority. Business and pleasure travellers from most countries can be found in cities on every continent. If an airplane is lost, it most likely has travellers from many nations. We cannot focus our efforts solely within our nation. We must strive for a single worldwide level of aviation safety to assure the continued growth and prosperity of the economies of our nations and the aviation industry.

1.4 We must set our sights on a single worldwide level for commercial aviation system safety. To achieve this goal:

  1.4.1 In the near term, the FAA, UKCAA and JAA should increase co-operation on a bilateral and regional basis to help countries and regions develop needed oversight and infrastructure.

  1.4.2 As we move to the future, the FAA, UKCAA, and JAA should increase their presence in international arenas through increased support of ICAO, and increase collaboration to create a global set of safety requirements and practices covering infrastructure and certification, operations and maintenance of aircraft.

  1.4.3 The FAA, UKCAA, JAA and ICAO should increase their co-operation in the development of international safety strategies to speed up implementation of safety enhancements for aircraft, aircraft operations and maintenance on a global basis. The FAA Safer Skies, JAA Joint Safety Strategy Initiative, and ICAO Global Aviation Safety Plan are examples of initiatives that need broad support.

2. TABLE OF CONTENTS

Section

Subject

3. Introduction

4. Single worldwide level for commercial aviation system safety.

5. Increase co-operation to help countries and regions develop needed oversight and infrastructure.

6. Increase presence in international arenas and collaborate more to create one set of safety requirements and practices.

7. Co-operate in the development of international safety strategies to speed up implementation of safety enhancements around the world.

8. Recommendations.

3. INTRODUCTION

  3.1 Boeing has an unwavering commitment to the safety of its products and the world's air transport system. The future of our business depends on keeping our products and the system safe. The following paper provides Boeing comments regarding commercial aviation system safety, and our view of the important role that governments and the civil aviation authorities play in aviation system safety.

  3.2 A safe system is very important to the UK and its economy. The UK and its industry account for nine percent of the aviation industry. As the economy becomes more global and supplier and airline alliances become more prevalent, it makes less and less difference where an aviation accident occurs. If confidence in aviation is lost in one area of the world, it affects us all-government, manufacturer, airline, and civil aviation authority. Business and pleasure travellers from most countries can be found in cities on every continent. If an airplane is lost, it most likely has travellers from many nations. We cannot focus our efforts solely within our nation; we must strive for a single worldwide level of aviation safety to assure the continued growth and prosperity of the economies of our nations and the aviation industry.

  3.3 We must set our sights on a single worldwide level for commercial aviation system safety. To achieve this goal:

  3.3.1 In the near term, the FAA, UKCAA and JAA should increase co-operation on a bilateral and regional basis to help countries and regions develop needed oversight and infrastructure. (See Section 5).

  3.3.2 As we move to the future, the FAA, UKCAA, JAA should increase their presence in international arenas through increased support of ICAO and increase collaboration to create a global set of safety requirements and practices covering infrastructure, certification, operations and maintenance of aircraft. (See Section 6).

  3.3.3 The FAA, UKCAA, JAA and ICAO should increase their co-operation in the development of international safety strategies to speed up implementation of safety enhancements for infrastructure, aircraft, aircraft operations and maintenance on a global basis. The FAA Safer Skies, JAA Joint Safety Strategy Initiative, and ICAO and Global Aviation Safety Plan are examples of initiatives that need broad support. (See Section 7).

4. SINGLE WORLDWIDE LEVEL FOR COMMERCIAL AVIATION SYSTEM SAFETY

4.1 We must set our sights on a single worldwide level for commercial aviation system safety.

4.2 If we compare accident rates over the last ten years, the data suggests that the highest risk of an accident is not in the United States or Europe, but other regions of the world. As we investigate accidents and collect data we see the same trend year after year: that operators based outside North America and Europe have two-thirds of the accidents but have only one fourth of the world's flights.

4.3 Accident Rates—Worldwide and Regional

4.4 Model of the Aviation System

  4.5 First, let me present a model in paragraph 4.4 showing how we can achieve our safety objectives. The model shows a view of the complex interactions that occur to produce a safe aviation system. The public sets safety expectations, aviation safety agencies set safety requirements through regulations and oversight, the members of the transportation system meet the requirements, safety indicators are measured, and the safety agencies adjust requirements and oversight as necessary. It should be noted that all elements of the Air Transport System are continuously monitoring the system and making safety improvements without necessarily being required by regulation. Airlines and manufacturers continually introduce safety enhancements with no change in regulation.

  4.6 This model shows the continuous feedback the aviation safety agencies receive both from safety indicators and the public through societal expectations. This model demonstrates the significant role the civil aviation authorities play in worldwide aviation system safety. It also explains why the UK system is so safe compared to other countries in the world. The UK system follows the model and has developed to a very mature state; other countries don't follow the model and their less mature systems have a lower level of safety.

  4.7 The reason for the superior safety level in the United States, Canada, the UK, most of Europe, and many other countries is the investment made in the entire aviation system. The safest countries and regions have invested in their aviation system—in regulatory requirements and oversight, in modern aircraft, in airports, ATC improvements and in airline operations and maintenance. The people who make-up the entire air transportation system have introduced new technologies in hardware and people management, and have continually improved the entire system. With each generation of aircraft, the safety level has improved due to the investment in the entire system.

  4.8 We can measure the results of our investment as shown in the chart below in paragraph 4.9. The chart shows the significant reduction in accident rate (accidents per million departures) with the introduction of new generations of aircraft. Accident rate is a global "safety indicator" in the safety model shown previously in paragraph 4.4.

4.9 Comparison of Hull Loss Accident Rates by Generation of Aircraft

  4.10 The UK-CAA has fostered a working together relationship of all participants in the entire aviation system. For example, the UK-CAA has established a relationship with the operators within the UK that clearly illustrates commitment to enhancing safety rather than taking enforcement actions. As a result, the operators feel free to share information with the UKCAA that will enhance safety without fear that the information will be used to license actions or in punitive measures unless it is truly warranted. The CAA works closely with the operators and the unions to resolve issues and has successfully eliminated what would be classed as an adversarial relationship. As a result they have made significant improvements in the safety of aviation operations in the UK.

  4.11 Another illustration of the close working relationship between all parties in the UK aviation system is the UK Flight Safety Committee. The Committee contains all aviation interests in the UK from helicopter companies to airlines to airports, etc. They meet once a month and discuss aviation problems within the UK and develop plans for resolution. This is all done in a threat free co-operative environment that results in more rapid and accurate actions. We at Boeing have recommended establishment of similar structures in other regions of the world.

  4.12 Let's now look at a comparison of the accident rates achieved by the entire aviation system in the US, Canada and Europe with the rest of the world where the risk of an accident is much higher. As shown in paragraph 4.14, we have the same type of airplanes in service in the rest of the world but with a much higher accident rate. What is the difference? The difference is the maturity of the aviation system. Governments haven't invested as fully in civil aviation authorities that develop regulation and oversight. Governments haven't invested as fully in airports and ATC infrastructure. In some cases airlines have fully invested in operations and maintenance, in some cases they have not. In these less safe aviation systems, the investment in infrastructure and airplane operations is not balanced with the safety improvements incorporated into the airplane.

  4.13 Therefore, if we are to strive for a single worldwide level of safety we need to focus our international safety programmes to further develop civil aviation authorities, further develop needed infrastructure, and further development airplane operations and maintenance.

4.14 Comparison of Accident Rates—USA/Canada/Europe and the Rest of the World

5. INCREASE CO-OPERATION ON A BILATERAL AND REGIONAL BASIS TO HELP COUNTRIES AND REGIONS DEVELOP NEEDED OVERSIGHT AND INFRASTRUCTURE

5.1 If we are to achieve a single worldwide level for commercial aviation system safety in the near term, the FAA, UKCAA and JAA should increase co-operation on a bilateral and regional basis to help countries and regions develop needed oversight and infrastructure

  5.2 In the current environment, the demand for aid from countries with less mature aviation systems is exceeding the supply of qualified specialists. Thus, the FAA, UKCAA, JAA and ICAO cannot fully support important programmes that help foreign authorities become self-sufficient which will lead to improved safety of the aviation system. Thus increasing demand for resources has come from the recent recognition that many countries' aviation infrastructure does not meet the minimum ICAO standards.

  5.3 For example, the FAA established the International Aviation Safety Assessment (IASA) programme that evaluated civil aviation authorities of countries whose aircraft flew into the US. The IASA programme confirmed that some civil aviation authorities did not meet the minimum standard required by ICAO. Subsequently, both ICAO and the JAA have initiated different types of audit programmes aimed at evaluating foreign civil aviation authorities. In addition, the JAA has led international initiatives aimed at regional regulatory partnerships. This unco-ordinated proliferation of programmes puts countries with already limited resources in the position of responding, on some cases, to three sets of inputs—FAA, JAA and ICAO.

  5.4 The FAA and JAA cannot perform the regulatory oversight function around the world. As countries share in the economic benefits associated with aviation, their civil aviation authorities need to take greater responsibility for providing oversight within their own country. However, they need assistance in the near term. The FAA, UKCAA, and JAA should increase its participation in international programmes aimed at further developing civil aviation authorities and aviation infrastructure in emergent regions of the world. ICAO has many such programmes underway and with increased support should serve as the leader so all developed countries can support less developed countries in a co-ordinated fashion.

6. INCREASE PRESENCE IN INTERNATIONAL ARENAS AND COLLABORATE MORE TO CREATE ONE SET OF SAFETY REQUIREMENTS AND PRACTICES.

6.1 If we are to achieve a single worldwide level for commercial aviation system safety as we move to the future, the FAA, UKCAA, JAA should increase their presence in international arenas through increased support of ICAO and increase collaboration to create a global set of safety requirements and practices covering infrastructure, certification, operations and maintenance of aircraft.

  6.2 An example of this of effort has been underway for many years to recognize that US FAA safety design requirements, FAA Part 25, and the European requirements, JAR 25, are equivalent since they produce equivalent levels of safety. As previously discussed, safety indicators such as accident rate are the same for US and Europe. Both systems have equivalent safety, but different safety regulations. However, manufacturers have had to meet both sets of regulations and demonstrate regulatory compliance to both agencies at considerable cost and no additional safety benefit to the travelling public.

  6.3 In an effort to reduce cost and improve efficiency, the FAA, JAA and industry established a harmonisation programme to develop agreements on the equivalence of FAR 25 and JAR 25. This harmonisation project has taken much longer and proven more difficult than originally envisioned. These regulatory harmonisation activities have allowed better understanding and trust between agencies, and are necessary steps toward the goal of eliminating redundant compliance activity. However, we have learned that harmonisation of regulation on a worldwide basis may not be practical. This activity has focused on the certification of the airplane, however as previously discussed the greater leverage for global safety has to do with the regulations and oversight of airplane operations and infrastructure.

6.4 Airplane Design Requirement Harmonisation—US and Europe

  6.5 The situation is more complex for the regulations that cover operations and maintenance and for national governments that have not yet developed aviation systems fully compliant with ICAO standards. There are no universally accepted minimum requirements for aviation system safety. Europe has regionally harmonised their operations requirements and practices under the JAR Ops. We need to expand this effort world wide.

  6.6 In the future, if safety is to be improved in the shortest time frame, it is important for the FAA, UKCAA, JAA, and ICAO to collaborate and develop a co-ordinated strategy to develop the higher-level safety requirements. As we have seen previously, the safety indicators—accident rates, shows that the high leverage safety requirements are in airplane operations and infrastructure. We need to complete our existing harmonisation activity so that we can focus on these safety requirements. International and bilateral agreements offer a means of accomplishing this goal.

7. CO -OPERATE IN THE DEVELOPMENT OF INTERNATIONAL SAFETY STRATEGIES TO SPEED UP IMPLEMENTATION OF SAFETY ENHANCEMENTS AROUND THE WORLD.

  7.1 The FAA, UKCAA, JAA and ICAO should increase their co-operation in the development of international safety strategies to speed up implementation of safety enhancements for infrastructure, aircraft, aircraft operations and maintenance on a global basis. The FAA Safer Skies, JAA Joint Safety Strategy Initiative, and ICAO Global Aviation Safety Plan are examples of initiatives that need broad support.

  7.2 FAA Safer Skies Agenda, the JAA Joint Safety Strategy Initiative (JSSI) and the ICAO Global Aviation Safety Plan provide an opportunity for the industry and civil aviation authorities to focus on high leverage safety agendas. Controlled Flight Into Terrain (CFIT), loss of control, and approach and landing are the leading types of fatal/hull loss accidents for worldwide commercial aviation. As will be discussed more in paragraphs 7.9, all three initiatives recognise the importance of reducing these types of accidents and have made them common elements of their respective agendas.

  7.3 UKCAA has taken a strong leadership role in initiating and supporting the accident reduction programmes of the JSSI. Boeing has been a participant from the outset and we fully support these programmes. All of our efforts will be much more effective and efficient through co-ordinated actions with each part of the aviation system team doing their part.

  7.4 To help make the point as to why working together initiatives such as these are so important, let's review a very successful safety program initiated in the 1980's.

  7.5 During the 1970's and 1980's in the United States, we were averaging about one windshear accident every year. Recalling our model of the aviation system—the safety indicators said we were having more windshear accidents in the US than we should. Through an analytical process, industry and government developed high leverage initiatives as shown on the figure in paragraph 7.6 to address the near term and long term risks posed by windshear to commercial aviation. The windshear program required continued support and effort throughout the years. Because of the government/industry team's long term leadership and commitment, the windshear accident rate has been dramatically reduced to almost zero in a little more than a decade.

7.6 Wind Shear Accident Reduction Programme-A Model for Success

  7.7 All three safety major safety programmes—FAA Safer Skies, JAA JSSI, and ICAO GASP—are linked through participation in the Commercial Aviation Safety Team. This linkage provides a tremendous opportunity to significantly increase the co-operation between the three major safety agencies in the world. Increased collaboration will better utilise scarce resources and speed up implementation of safety improvements.

7.8 International Safety Programme Co-operation and Joint Participation

  7.9 The CAST has active participants for each element of the US aviation system and from international aviation groups and agencies working in aviation accident reduction. With their combined expertise working together, the group is analysing data to determine the high leverage/efficient interventions, agree on the priorities for action, and developing co-ordinated action plans. While CAST has participants who can take direct actions to implement co-ordinated plans in the US, the mechanism for international application is less clear.

  7.10 The US FAA's Safer Skies Programme has three elements—Commercial Aviation, General Aviation, and Cabin Safety. The agendas for each element are shown in the figure in paragraph 7.10. The FAA is co-ordinating actions for the Safer Skies Commercial Aviation accident reduction programme in the US through CAST.

7.11 US FFA's Safer Skies Agenda

  7.12 The three largest types of worldwide commercial fatal/hull loss accidents (CFIT, loss of control and approach and landing) are main elements of the Safer Skies/CAST agenda. In addition, improved data/analysis and human factors are opportunities for improvement affecting all the types of accidents. These elements are common for the JSSI and ICAO agendas as well.

  7.13 The three largest types of worldwide commercial fatal/hull loss accidents (CFIT, loss of control and approach and landing) are also main elements of the JAA's JSSI agenda. As with the FAA/CAST agenda, improved data/analysis and human factors are opportunities affecting all the types of accidents.

7.14 JAA Safety Activity

  7.15 The three largest types of worldwide commercial fatal/hull loss accidents (CFIT, loss of control and approach and landing) are also main elements of the ICAO Global Aviation Safety Programme agenda. As with the FAA/CAST and JSSI agenda, improved data/analysis and human factors are opportunities for improvement affecting all the types of accidents.

  7.16 ICAO Global Aviation Safety Programme

8. RECOMMENDATIONS

  8.1 Aviation is extremely important to the global economy. Aviation is the dominant inter-city mode of transportation for passengers and goods that must be transported quickly and efficiently. Aviation employs hundreds of thousands of people and thousands more in aviation support industries. Even industry segments that are seemingly unrelated depend on a safe and efficient aviation system.

  8.2 As our economy becomes more global and airline alliances become more prevalent, it makes less and less difference where an aviation accident occurs. If confidence in aviation is lost in one area of the world, it affects us all. Business and pleasure travellers from most countries can be found in cities on every continent. If an airplane is lost overseas, it most likely has travellers from many nations. We cannot focus our efforts solely internally.

8.3 We must set our sights on a single worldwide level for commercial aviation system safety. To achieve this goal:

  8.3.1 In the near term, the FAA, UKCAA and JAA should increase co-operation on a bilateral and regional basis to help countries and regions develop needed oversight and infrastructure. In the current environment, the demand for aid from foreign countries is exceeding the supply of qualified specialists. Thus, the FAA and JAA cannot fully support important programmes that help foreign authorities become self-sufficient which will lead to improved safety of the aviation system. This increasing demand for FAA and JAA resources has come from the recognition that many countries aviation infrastructure does not meet the minimum ICAO standards. If we invest today to help make foreign authorities self-sufficient, the resource demand on the FAA, JAA and UKCAA in the future will be less. (See Section 5 for further discussions.).

  8.3.2 As we move to the future, the FAA, UKCAA and JAA should increase their presence in international arenas through increased support to ICAO and increase collaboration to create one global set of safety requirements and practices. Let me be clear that I am not talking about harmonising all safety regulations, but establishing agreement on a common set of safety performance requirements and practices. The globalisation of the air transportation industry has focused the need for a worldwide forum for establishing safety performance requirements. The FAA and JAA have nearly completed the process of developing a single set of safety requirements for airplane design. The FAA, JAA and ICAO need to build upon this effort and increase the collaboration on operations and infrastructure. These focus areas offer the greatest leverage for improving the safety of the system. Again investment in additional resources now will pay dividends in the future. (See Section 6 for further discussions.)

  8.3.3 The FAA, UKCAA, JAA and ICAO should increase their co-operation in development of international safety strategies to speed up implementation of safety enhancements around the world. In our view the benefits for the focused agenda will be the development of wide industry and government support for the safety programmes that follow. This consensus and collaboration will better utilise scarce resources and speed up implementation of safety improvements around the world. (See Section 7 for further discussions.)

Charles Higgins

Vice President

Airplane Safety and Airworthiness

14 April 1999