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Why aviation is embracing risk-based oversight

The shift towards risk-based and data-driven oversight in aviation

By José Fernandez | November 11, 2024

IATA’s move to the risk-based IOSA is expected to be completed in 2025, marking a key milestone in the industry’s move away from prescriptive risk assessments to a more tailored approach.
Aerospace
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Aviation has become a very safe industry, particularly given the complexity of hardware it uses, the numbers of passengers and amount of cargo it carries, and the extremes of the environment that it often works in.

The industry has enhanced its safety record by taking a view of risk that focuses on four key areas: technical aspects, human factors, organizational factors, and, more recently, a total-system approach applying safety management system (SMS) principles.

Safety and risk are constantly evolving subjects, and safety oversight is currently going through a significant transformation. Traditional approaches, often reliant on prescriptive regulations and periodic inspections, are being supplemented or even replaced by risk-based and data-driven oversight. This shift is being championed by major regulatory bodies such as the International Civil Aviation Organization (ICAO), the European Union Aviation Safety Agency (EASA) and the Federal Aviation Administration (FAA).

What is risk-based oversight?

Putting it simply, risk-based oversight (RBO) is an approach where regulatory activities are prioritized based on the risk they pose to safety. Instead of treating all entities equally, regulators focus their resources on areas with the highest risk. This method allows for more efficient use of resources and enhances the overall safety of the aviation system.

Regulators are moving from a prescriptive approach that applies across the entire industry (or at least across a specific jurisdiction), to a more flexible regulatory approach that’s based on the risk that an individual organization’s activities represent when compared to the entire industry. Putting it simply, safety risk assessments are increasingly taking data from individual organizations into account.

To take an airline-specific example, a prescriptive regulation of the airport alternate allocation, number of alternates and distance regulation, could be replaced for a different policy based on safety risk assessment that is supported by the operator safety data. This means that they can choose to operate without an alternative airport if the data-driven risk assessment shows that it is safe.

The aviation sector has always been superb at recording all kinds of very detailed data, but we are moving into an era where that data is being converted into meaningful insights. This is enabling a more flexible regulatory environment that does not compromise safety.

What are the benefits of risk-based and data-driven oversight?

The shift towards risk-based and data-driven oversight offers several benefits. Primarily, it enables proactive risk management: Data-driven oversight enables organizations to see where problems could arise, which allows for proactive management of safety issues. This tends to reduce the need for reactive measures, which are likely to be more expensive.

Secondly, with organizations like ICAO leading the way, RBO promotes global harmonization of safety standards and practices, which is fundamental to an industry like aviation where routes often span countries and regulatory jurisdictions.

Regulators’ positions

The three main aviation regulators are leading the move to a more flexible risk-based philosophy. To take each on in turn:

ICAO’s role

ICAO has become a strong advocate for RBO in recent years, incorporating its principles into its standards and recommended practices, particularly in Annex 19, which deals with safety management.[1] ICAO’s approach emphasizes the importance of safety performance and risk management, encouraging member states to adopt these practices.

EASA’s initiatives

EASA has been at the forefront of implementing the principles of RBO in Europe, with its comprehensive framework including guidelines and best practices for member states.[2] EASA’s approach integrates risk profiles and safety performance into oversight planning and execution, ensuring that the highest risks are addressed first. This method has been successfully applied across various domains, including air operations, aircrew and air traffic management.

FAA’s strategy

The FAA has also embraced a risk-based and data-driven oversight philosophy. The FAA’s Integrated Oversight Philosophy (IOP) leverages data to make informed, system-level decisions.[3] This approach allows the FAA to identify potential safety issues before they become critical and looks to encourage proactive rather than reactive oversight.

Global adoption

In addition to regulators at state level, the International Air Transport Association (IATA) is transitioning its Operational Safety Audit (IOSA) program to a new Risk-based IOSA model.[4] This approach tailors the audit scope to each airline’s specific operational profile and safety risks, rather than using a one-size-fits-all method.

Key features of the Risk-based IOSA include:

  • Improved aviation safety by focusing on the most pertinent risks and enhancing the overall audit process
  • A tailored audit scope that focuses on the most critical safety risks for each airline, enhancing the effectiveness of the audit
  • A new maturity assessment component, which evaluates the maturity of an airline’s safety-critical systems and programs to provide a more comprehensive safety assessment

According to IATA, the Risk-based IOSA is expected to be fully implemented by 2025, with both traditional and risk-based audits coexisting during the transition period.

The role of data in modern oversight

In many ways, the aviation sector is perfectly placed to move to risk-based assessments. The industry has always been proactive in collecting data about its activities and data is the cornerstone of RBO. By collecting and analyzing vast amounts of safety data, regulators can identify trends, predict potential issues and implement corrective actions more effectively.

Data collection and analysis

Modern oversight relies heavily on data from a variety of sources, including flight data monitoring, incident reports and maintenance records. This data is analyzed to identify patterns and assess risks. For example, EASA uses data to create risk profiles for different sectors, which helps prioritize oversight activities.

The risk profile is created through a defined process:

  1. Data related to operations, incidents and other relevant metrics is collected
  2. This data is used to identify areas with elevated risks
  3. The risk profile is updated regularly as new data becomes available
  4. Safety measures that an organization puts in place are evaluated
  5. The effectiveness of SMSs are evaluated
  6. Historical safety performance data is reviewed
Determining oversight priorities

Information sharing and advanced training tools are crucial to ensure effective oversight.

Effective RBO requires collaboration and information sharing among regulators, airlines and other stakeholders, which is again an approach that the aviation industry is generally comfortable with. ICAO and EASA have established mechanisms for sharing safety information, which enhances the ability to manage risks on a global scale.

Regulators are also investing in training and tools to support RBO. Inspectors are trained to use data analytics and risk assessment tools, enabling them to conduct more effective audits and inspections.

Implementation challenges

While the positives for the industry are clear, implementing RBO in aviation comes with several challenges, particularly for airlines.

Effective risk-based oversight relies heavily on accurate and comprehensive data. However, collecting high-quality data can be challenging due to inconsistent reporting practices and varying data standards across different organizations and regions.

Shifting to a risk-based approach requires significant resources, including advanced data analytics tools and trained personnel. Smaller organizations or those with limited budgets may struggle to implement these changes effectively without clear guidance and support on how to prioritize different aspects of the evolution.
There can be resistance to change within organizations accustomed to traditional oversight methods. Convincing stakeholders to adopt a new approach that emphasizes proactive risk management over reactive compliance can be challenging.
Different countries and regions may have varying regulations and standards, making it difficult to implement a uniform RBO approach globally. Harmonizing these regulations requires extensive collaboration and agreement among international regulatory bodies.
Assessing risk accurately involves complex analysis and understanding of various factors, including operational, environmental and human elements. Developing robust risk assessment models that can handle this complexity can be a significant challenge.
Ensuring that inspectors and other personnel are adequately trained to use risk-based oversight tools and methodologies is crucial. It requires ongoing education and competency development programs.

A safe, flexible approach to risk

Despite the challenges, RBO is enabling the aviation industry to adopt a more sophisticated and effective approach to safety oversight. By adopting risk-based and data-driven methods, regulators like the EASA, the FAA, IATA and the ICAO are enhancing their ability to manage safety risks proactively. This shift not only improves safety outcomes but also ensures that oversight resources are used more efficiently, which ultimately benefits the entire aviation ecosystem.

Cultural resistance to change can be challenging, but working with organizations such as the WTW Aviation Safety Partnership can help by bringing perspective and strategies that can be effective at helping airlines to move towards a more proactive and informed approach to safety and risk management and get ready for Risk-based IOSA.


Footnotes

  1. ICAO Annex 19, Safety Management Return to article
  2. Practices for risk-based oversight Return to article
  3. Order 8000.72 - FAA Integrated Oversight Philosophy Return to article
  4. Risk-based IOSA Return to article

Disclaimer

WTW offers insurance-related services through its appropriately licensed and authorized companies in each country in which WTW operates. For further authorization and regulatory details about our WTW legal entities, operating in your country, please refer to our WTW website. It is a regulatory requirement for us to consider our local licensing requirements.

Author


Associate Director, Aviation Safety Partnership
Global Aviation & Space

Contacts


Director, Aviation Safety Partnership, Global Aviation & Space

Jason Saunders
Global Aviation and Space Industry Vertical Division Leader – North America

Derek Greaves
Head of Aviation – Canada

Shane Rambhaccus
Client Executive – Canada

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