Suspension of PIA operations by EU – a threat or an opportunity?

 
August 04, 2020

Jamil A. MalikPIA is an enduring icon of Pakistan. In over six decades, it has racked up countless notable achievements and weathered many storms. The current problems with the European Union...

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Jamil A. Malik

PIA is an enduring icon of Pakistan. In over six decades, it has racked up countless notable achievements and weathered many storms. The current problems with the European Union Aviation Safety Agency (EASA), come at a critical time when the airline faces other daunting challenges ranging from financial difficulties to traffic drop due COVID-19. In these circumstances, the EASA suspension order and resultant curtailment of its international operations, poses a serious threat to the continuance of Pakistan’s National Carrier. Background Trust is a core value that enables the vast, complex, and highly regulated system of global civil aviation to function smoothly. Each member state extends recognition and respect to other member states, based on trust in their competence and compliance with ICAO standards. Founded on this trust, states allow airlines from other states to operate to their airfields. Trust facilitates the mutual validation of licenses and certifications which enables employment of foreign pilots and engineers, leasing and insurance of aircraft and numerous other vital aviation activities. In the ultimate analysis, the passenger confirms his confidence in this complex system by boarding an aircraft and trusting the airline with his life. EASA and PIA The declining safety trend of Pakistan’s national carrier progressively lowered EASA’s confidence, prompting a ‘continuous monitoring’ of PIA’s safety performance since June 2019. After due interaction, PIA submitted a Corrective Action Plan (CAP) that included the overdue implementation of a ‘Safety Management System’ (SMS), which was accepted by EASA in September 2019, with a strict target date of 24 May 2020. The significance of this stipulation became woefully apparent just short of this cutoff date when PIA flight PK-8303 crashed at Karachi on 22 May 2020. The Interim Investigation Report by Pakistan Air Accident Investigation Board indicates the accident cause to be ‘human factors.’ A fully functional SMS could proactive have prevented the ‘successive breaches of multiple levels of safety defences’ that resulted in crash of an otherwise serviceable aircraft. PIA failed to comply with the CAP implementation time limit that had been extended to 17 June 2020. EASA lost confidence and belief in the reliability and ability of PIA to comply. On 30 June 2020 EASA informed PIA by means of an emailed letter that its TCO Authorization was summarily suspended, thereby barring the Airline from the airspace of its 32 member states. PIA had over-committed and under-performed on its pledge, damaging its trust equation with EASA. In the same letter, the EASA Executive Director pointedly referred the much publicized address of the aviation minister to the National Assembly on 24 June 2020, in which it had been announced that 260 of the 860 holders of Pakistani pilot licenses had attained these licenses ‘fraudulently.” Expressing serious mistrust in Pakistan Civil Aviation Authority (PCAA), the Executive Director stated, “EASA no longer has confidence that Pakistan as state of operator can effectively ensure that operators certified in Pakistan comply at all times with the applicable requirements for crew qualification.” This statement clearly indicates EASA’s stance that PCAA is currently not capable to certify and oversee its operators and aircraft in accordance with applicable international standards. A direct consequence of such a ‘zero-trust’ condition is that the credentials of operators certified by PCAA may become unacceptable to other states causing withdrawal of operational permissions. The inevitable backlash from EASA’s strongly worded disapproval of Pakistan’s aviation authority became rapidly apparent: America’s FAA downgraded Pakistan’s safety rating to Category 2, the UK CAA withdrew PIA’s permit to operate and the UN removed all Pakistani airlines from its ‘Recommended List,’ advising the UN staff in Pakistan not to travel on any Pakistan-registered airlines. PIA and the EU air safety list The European Union publishes a list of air carriers that are banned from operating to any of its member states for failing to meet EU regulatory safety oversight standards. The EU Air Safety List, also known as the EU Blacklist, details the full or partial ban imposed and is subject to periodic review. It merits mention that on 05 March 2007 PIA was included in Part ‘B’ of the EU Safety List, whereby B747 and A310 aircraft were banned from entry into Europe, on account of discrepancies and potential risk factors in the areas of maintenance and operations; and only B777 operations were permitted. PIA mobilized resources to suitably address the discrepancies notified by the EU; Airbus and Boeing technical experts were invited to audit the problem areas, competent foreign consultants were engaged for specific roles and a comprehensive Recovery Action Plan (RAP) was prepared. The RAP implementation was carried out with intense focus and sustained efforts, with continuous monitoring by PCAA. Progress reports were regularly submitted to EU with endorsement of PCAA. After detailed analysis and satisfactory findings, the ban was removed on 27 Nov 2007. This was a validation of EU’s restored trust in PIA’s compliance with ICAO safety standards. The quantum of effort entailed, demonstrated yet again that it is difficult to gain lost trust back. Having been personally linked with these efforts, I believe that PIA’s successfully exit from the EASA Blacklist in less than nine months, was assisted by two key factors: Direct involvement of reputable Foreign Experts in formulation of the RAP and overseeing implementation. Continual involvement of PCAA in scrutiny and approval of the RAP, monitoring implementation and endorsement of timely Interim Reports to the EU. The way forward In its emailed letter of 30 June 2020, EASA notified PIA that its Third Country Operator (TCO) authorization was being suspended for six months because PIA had not complied with its commitment to “effectively implement all elements of a SMS as stipulated by ICAO.” The deadline for completion of this action was 17 June 2020, but the timing and nature of penalty for non-compliance is indicative of EASA’s concern that SMS deficiencies were a cause of the A320 accident, as inferred from findings of the Preliminary Investigation report, that was finalized by Pakistan AIIB with participation of EASA, the engine manufacturer and French BEA. The suspension of PIA’s TCO authorization must be viewed as an imminent threat of a greater penalty - being relegated to the EU Safety List. Therefore, the Level 1 Finding notified by EASA warrants urgent address by PIA. As advised by EASA, sufficient evidence will have to be provided “to prove that the capacity of the airline and of its oversight authority to implement international safety standards is of a sufficient level.” This clause of EASA implies that competence of the PCAA, as the airline’s regulator, is a concurrent precondition. The discrepancies pointed out by EASA in the notice of 30 June indicates that the status of PIA’s SMS continues to be ‘work-inprogress.’ With possibility of a harsher penalty for noncompliance, and wary of EASA’s dogged persistence and incisive scrutiny, it would be in PIA’s interest to seek help from an expert entity, to help with full SMS implementation within the stipulated time. The serious lapse in the licensing and safety oversight by PCAA has diminished its credibility as a regulator, therefore EASA may not accept its monitoring or validation of PIA’s corrective actions. This is a reason to follow the strategy of engaging a reputable expert in implementation of remedial actions. Due lack of an in-country resource, a foreign expert may be the only option. This action would also improve EASA’s confidence in PIA’s resolve to comply and add credibility to activities undertaken. ‘If you think safety is expensive try having an accident,’ is an acknowledged axiom of aviation that directly came true for PIA on 22 May 2020, when PK-8303 crashed at Karachi. The riskbased, proactive approach of a functional SMS will provide PIA a much-needed safety net to help prevent such an accident in the future. PIA’s commitment to SMS would foster the values of trust, credibility, and reliability, which are key determinants of success in commercial aviation. The suspension imposed by EASA will be a catalyst for improvement and must be viewed as more an opportunity than a threat. Ultimately, the most compelling reason for PIA to implement a fully functional SMS should be its own vision to rise again as a safe, reliable, and trustworthy flag carrier. The writer has served CAA as a Flight Inspector and PIA in various capacities, including Director Flight Safety. Email: jamil.mgmx.com.



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