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The Australian Government's Aviation Safety Regulation Review - Ministerial Statement


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http://www.minister.infrastructure.gov.au/wt/speeches/2014/wts013_2014.aspx

 

Ministerial Statement: The Australian Government's Aviation Safety Regulation Review

 

Speech

 

WTS013/2014

 

03 June 2014

 

Parliament House, Canberra

 

Madam Speaker, on 14 November last year I advised the House that the Government had commissioned an independent review of Australia's system of aviation safety regulation, to be undertaken by a panel of three eminent and experienced members of the international aviation community. I can now advise the House that I have received the review Report from panel chairman, Mr David Forsyth.

 

The Report confirms that Australia has an excellent safety record and an advanced aviation regulatory system. It also recognises that there are opportunities for the system to be improved to ensure Australia remains a global aviation leader. The review makes 37 recommendations for the Government to consider which collectively would represent the biggest reform in aviation regulation in decades.

 

The review panel has engaged widely with the industry, the aviation agencies and other stakeholders. Some 269 written submissions were received. The panel also considered international trends in the aviation industry and emerging global practices in aviation safety regulation.

 

The role of the regulator is pivotal in the safety system, and many of the recommendations relate to the Civil Aviation Safety Authority. They span issues such as the relationship between the regulator and operators, mechanisms for a more collaborative approach to regulatory oversight, the culture and skills required and the role of the board.

 

Other recommendations are aimed at strengthening the overall system and the arrangements for coordination across the work of the aviation agencies. These cover issues such as sharing of safety data and strategic planning through Australia's State Safety Program.

 

In relation to the Australian Transport Safety Bureau, the Report recommends that an additional commissioner be appointed with operational aviation experience.

 

An important set of recommendations relate to the finalisation of the longstanding Regulatory Reform Program and guidance on principles for developing future regulatory change proposals. The Report highlights the opportunity to improve the approach to regulatory reform, to reduce the volume and improve the clarity of aviation safety regulations.

 

Madam Speaker it is vital that Australia fosters a dynamic aviation sector. Aviation is an essential element in a modern economy. Given the speed with which the global aviation industry is changing and growing, we need to ensure that our regulatory system adapts to keep pace with the industry.

 

Safety will always remain the Government's highest priority.

 

The Government will commence consideration of the Report in detail without delay. The Report will be open for public comment for the next month. Written submissions received by the Review will be made public over the coming days except for those provided in confidence and a number of others about which the Government is seeking legal advice.

 

I will advise the House of a comprehensive response to the recommendations as soon as possible.

 

In developing the response, we will be looking to ensure that our safety regulatory system is as good as it can be to support aviation into the future. We will be looking to ensure clear strategic direction and coordination, to support contemporary approaches consistent with global best practice, and to foster effective industry engagement, in particular in regulatory development.

 

Consistent with the Government's broader agenda in deregulation, we will be looking for ways to reduce regulatory costs on the industry without reducing safety.

 

The Government will also take account of the recommendations as we approach a number of important appointments in the aviation agencies. This includes the appointment of two extra members to the CASA board to bolster the aviation experience, in line with a Coalition election commitment. I also expect that the CASA board will give full regard to the Report in its current process for selection of the next Director of Aviation Safety.

 

Madam Speaker, I would like to take this opportunity to thank the review panel. Mr David Forsyth AM, the Chairman of the panel, is the former chair of Safeskies Australia and of the Airservices Australia board and has brought over 30 years of experience in the Australian aviation sector to the review. He was joined on the panel by Mr Don Spruston, former Director-General of Civil Aviation at Transport Canada and former Director-General of the International Business Aviation Council, and Mr Roger Whitefield, former Head of Safety at British Airways, former safety adviser to Qantas and former United Kingdom Civil Aviation Authority board member. The panel was assisted by Mr Philip Reiss, former President of the Aircraft Owners and Pilots Association of Australia on issues relating to the general aviation sector and regional operators.

 

I would like to recognise the substantial contribution by aviation industry participants to the review. I would welcome industry views on the Report and on the best options for ensuring effective processes for representation in collaborative processes.

 

The full Report is now available on the Department's website.

 

Madam Speaker, the independent review of Aviation Safety Regulation was a commitment by the Coalition in the 2013 federal election. I welcome the panel's Report as the first step towards a stronger and more harmonious aviation industry.

 

 

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Aviation Safety Regulation Review

 

Executive summary - www.infrastructure.gov.au/aviation/asrr/files/ASRR_Executive_Summary.pdf

 

Australia has an excellent, high-capacity Regular Public Transport safety record and an advanced aviation

 

regulatory system. However, there are opportunities for the system to be improved to ensure Australia

 

remains a leading aviation state.

 

The Aviation Safety Regulation Review makes 37 recommendations for the Australian Government to

 

consider.

 

Despite Australia’s good standing, the aviation industry is highly self-critical and regularly has a ‘take

 

no prisoners’ approach to public discourse. While this critical introspection may contribute to its good

 

record, it can at times be counter-productive to promoting rational public debate on aviation safety and to

 

building a positive and collaborative national aviation safety culture.

 

The current relationship between industry and the regulator is cause for concern. In recent years,

 

the regulator has adopted an across the board hard-line philosophy, which in the Panel’s view, is not

 

appropriate for an advanced aviation nation such as Australia. As a result, relationships between industry

 

and the Civil Aviation Safety Authority (CASA) have, in many cases, become adversarial.

 

Leading regulators across the world are moving to performance-based regulation, using a ‘trust and

 

verify’ approach, collaborating with industry to produce better safety outcomes and ensuring the regulator

 

stays in touch with rapidly advancing technology and safety practices. On occasions, individual operators

 

may push the boundaries and require close regulatory oversight and a firm regulatory response. An

 

effective risk-based regulator will judge when a hard line is necessary.

 

A number of countries with advanced aviation regulatory systems have developed collaborative

 

relationships between their regulators and industry, leading to open sharing of safety data. Due to the

 

present adversarial relationship between industry and CASA, Australia lacks the degree of trust required

 

to achieve this important aim. Sharing safety data is a fundamental principle of good safety management.

 

The Panel concludes that CASA and industry need to build an effective collaborative relationship on a

 

foundation of mutual trust and respect. Therefore, CASA needs to set a new strategic direction. The

 

selection of a new Director of Aviation Safety should concentrate on finding an individual with leadership

 

and change management abilities, rather than primarily aviation expertise. Other jurisdictions have

 

appointed leaders without an aviation background, who have been successful in changing the strategic

 

direction of the safety regulator.

 

The CASA Board should exercise full governance over the organisation. The addition of two extra

 

directors and filling of two upcoming vacancies provides an opportunity to ensure the CASA Board has an

 

appropriate blend of skills including experienced practitioners from across the aviation industry.

 

To help improve the industry – regulator relationship, the Panel recommends that CASA align its

 

organisation with industry, re-establish small offices at major airports, adopt an industry exchange

 

program, devolve medical renewals to DAMEs, and publish service KPIs.

 

The Panel also recommends a number of changes in regulatory oversight. The regulatory audit program

 

should reflect international auditing standards, fully disclosing findings during an audit and at exit briefings.

 

Findings should be graded on a scale of seriousness. The Panel also recommends that CASA make use

 

of third party commercial audits as a means of supplementing its surveillance program.

 

Current appeals processes, while having a sound basis, can be improved. The Panel recommends that

 

the CASA Industry Complaints Commissioner report to the CASA Board and be authorised to convene

 

independent review panels on merits matters, chaired by a CASA non-executive director.

 

The Regulatory Reform Program has been ongoing for over two decades and has changed direction

 

several times. This has led to widespread ‘reform fatigue’ within the industry. A speedy resolution to

 

the current program is required, and a more manageable (but regular) process of periodic maintenance

 

should be adopted. This maintenance should only change regulations when change is required

 

to improve safety, or to ensure harmonisation with global best practice and the Standards and

 

Recommended Practices of the International Civil Aviation Organization (ICAO). Australia should ensure

 

that its unique regulatory requirements are minimised.

 

Industry is frustrated with many new Civil Aviation Safety Regulations, viewing them as overly legalistic,

 

difficult to understand and focused on punitive outcomes. The situation has arisen from a combination

 

of the move to a two-tier regulatory approach, policy decisions by the regulator, and government drafting

 

requirements. The Panel recommends returning to a third tier of regulation, removing as much detail as

 

possible from regulations, and using plain language standards in the third tier. A reduced number of high-

 

level offence and penalty provisions would remain in the regulations. The third tier of standards should be

 

carefully drafted using small project groups of industry experts working with the regulator, separate from

 

the day-to-day regulatory task.

 

The Australian Transport Safety Bureau (ATSB) has been heavily criticised in Australia for its report into

 

the 2009 ditching of a Pel-Air Westwind off Norfolk Island/1. Canada’s Transportation Safety Board is

 

completing a review of the ATSB and will report shortly. The Panel considers that the Pel-Air report

 

was an aberration, and not typical of the high standard that the ATSB usually attains. The Panel

 

recognises that the ATSB is putting measures in place to prevent a reoccurrence. To improve the ATSB’s

 

governance, the Panel recommends that an additional Commissioner be appointed, with extensive

 

aviation experience.

 

ICAO requires that countries formulate a State Safety Program (SSP), which Australia has done.

 

The Panel considers that Australia should develop the SSP as a strategic plan for the aviation safety

 

system, under the leadership of the Aviation Policy Group. To implement this plan, the Department of

 

Infrastructure and Regional Development should play a stronger policy role in the SSP, providing policy

 

guidance while respecting the operational independence of CASA, the ATSB, and Airservices.

 

The Panel appreciates the significant level of interest, support and contribution from both the aviation

 

community and government agencies.

 

1 ATSB, Ditching – Israel Aircraft Industries Westwind 1124A, VH-NGA, AO-2009-072, August 2012

 

List of recommendations

 

The Aviation Safety Regulation Review Panel recommends that:

 

1. The Australian Government develops the State Safety Program into a strategic plan for

 

Australia’s aviation safety system, under the leadership of the Aviation Policy Group, and uses it

 

as the foundation for rationalising and improving coordination mechanisms.

 

2. The Department of Infrastructure and Regional Development plays a stronger policy role in the

 

State Safety Program.

 

3. The Australian Transport Safety Bureau investigates as many fatal accidents in the sport and

 

recreational aviation sector as its resources will allow.

 

4. The Australian Transport Safety Bureau and the Civil Aviation Safety Authority utilise the

 

provision in their bilateral Memorandum of Understanding to accredit CASA observers to ATSB

 

investigations.

 

5. The Australian Government appoints an additional Australian Transport Safety Bureau

 

Commissioner with aviation operational and safety management experience.

 

6. The Civil Aviation Safety Authority’s Board exercises full governance control. The non-executive

 

directors should possess a range of appropriate skills and backgrounds in aviation, safety,

 

management, risk, regulation, governance and government.

 

7. The next Director of Aviation Safety has leadership and management experience and

 

capabilities in cultural change of large organisations. Aviation or other safety industry experience

 

is highly desirable.

 

8. The Civil Aviation Safety Authority:

 

a. reinstates publication of Key Performance Indicators for service delivery functions

 

b. conducts a stakeholder survey every two years to measure the health of its relationship

 

with industry

 

c. accepts regulatory authority applications online unless there is a valid technical reason

 

against it

 

d. adopts the same Code of Conduct and Values that apply to the Australian Public Service

 

under the Public Service Act 1999.

 

9. The Civil Aviation Safety Authority develops a staff exchange program with industry.

 

10. Airservices Australia, in conjunction with the Department of Infrastructure and Regional

 

Development and the Civil Aviation Safety Authority, reconsiders the policy on ‘Assessment of

 

Priorities’ that stipulates that air traffic controllers sequence arriving aircraft based on category

 

of operation, rather than on the accepted international practice of ‘first come, first served’.

 

11. The Australian Transport Safety Bureau and the Civil Aviation Safety Authority amend the

 

wording of their existing Memorandum of Understanding to make it more definitive about

 

interaction, coordination, and cooperation.

 

12. The Civil Aviation Safety Authority delegates responsibility for the day-to-day operational

 

management of airspace to Airservices Australia, including the designation of air routes, short-

 

term designations of temporary Restricted Areas, and temporary changes to the classification

 

of airspace for operational reasons.

 

13. The Department of Infrastructure and Regional Development and Department of Defence (and

 

appropriate agencies) establish an agreed policy position on safety oversight of civil operations

 

into joint user and military airports.

 

14. The Civil Aviation Safety Authority changes its regulatory philosophy and, together with industry,

 

builds an effective collaborative relationship on a foundation of mutual understanding and

 

respect.

 

15. The Civil Aviation Safety Authority continues to provide appropriate indemnity to all industry

 

personnel with delegations of authority.

 

16. The Civil Aviation Safety Authority finalises its Capability Framework and overhauls its training

 

program to ensure identified areas of need are addressed, including:

 

a. communication in a regulatory context

 

b. decision making and good regulatory practice

 

c. auditing.

 

17. The Civil Aviation Safety Authority publishes and demonstrates the philosophy of ‘just culture’

 

whereby individuals involved in a reportable event are not punished for actions, omissions or

 

decisions taken by them that are commensurate with their experience and training. However,

 

actions of gross negligence, wilful violations and destructive acts should not be tolerated.

 

18. The Civil Aviation Safety Authority reintroduces a ‘use of discretion’ procedure that gives

 

operators or individuals the opportunity to discuss and, if necessary, remedy a perceived

 

breach prior to CASA taking any formal action. This procedure is to be followed in all cases,

 

except where CASA identifies a Serious and Imminent Risk to Air Safety.

 

19. The Australian Transport Safety Bureau transfers information from Mandatory Occurrence

 

Reports to the Civil Aviation Safety Authority, without redaction or de-identification.

 

20. The Australian Transport Safety Bureau transfers its safety education function to the Civil

 

Aviation Safety Authority.

 

21. The Civil Aviation Safety Authority changes its organisational structure to a client-oriented

 

output model.

 

22. The Civil Aviation Safety Authority establishes small offices at specific industry centres to

 

improve monitoring, service quality, communications and collaborative relationships.

 

23. The Civil Aviation Safety Authority shares the risk assessment outputs of Sky Sentinel, its

 

computerised risk assessment system, with the applicable authorisation holder.

 

24. The Civil Aviation Safety Authority provides full disclosure of audit findings at audit exit briefings

 

in accordance with international best practice.

 

25. The Civil Aviation Safety Authority introduces grading of Non-Compliance Notices on a scale of

 

seriousness.

 

26. The Civil Aviation Safety Authority assures consistency of audits across all regions, and delivers

 

audit reports within an agreed timeframe.

 

27. The Civil Aviation Safety Authority implements a system of using third-party commercial audits

 

as a supplementary tool to its surveillance system.

 

28. The Civil Aviation Safety Authority establishes a safety oversight risk management hierarchy

 

based on a categorisation of operations. Rule making and surveillance priorities should be

 

proportionate to the safety risk.

 

29. Recreational Aviation Administration Organisations, in coordination with the Civil Aviation Safety

 

Authority, develop mechanisms to ensure all aircraft to be regulated under CASR Part 149 are

 

registered.

 

30. The Civil Aviation Safety Authority changes the current two-tier regulatory framework (act and

 

regulations) to a three-tier structure (act, regulations and standards), with:

 

a. regulations drafted in a high-level, succinct style, containing provisions for enabling

 

standards and necessary legislative provisions, including offences

 

b. the third-tier standards drafted in plain, easy to understand language.

 

31. The Civil Aviation Safety Authority structures all regulations not yet made with the three-

 

tier approach, and subsequently reviews all other Civil Aviation Safety Regulation Parts (in

 

consultation with industry) to determine if they should be remade using the three-tier structure.

 

32. The Civil Aviation Safety Authority reassesses the penalties in the Civil Aviation Safety

 

Regulations.

 

33. The Civil Aviation Safety Authority applies a project management approach to the completion

 

of all Civil Aviation Safety Regulation Parts not yet in force, with drafting to be completed within

 

one year and consultation completed one year later, with:

 

a. a Steering Committee and a Project Team with both CASA and industry representatives

 

b. implementation dates established through formal industry consultation.

 

34. The Civil Aviation Safety Authority’s Director of Aviation Safety meet with industry sector leaders

 

to jointly develop a plan for renewing a collaborative and effective Standards Consultative

 

Committee.

 

35. The Civil Aviation Safety Authority devolve to Designated Aviation Medical Examiners the ability

 

to renew aviation medical certificates (for Classes 1, 2, and 3) where the applicant meets the

 

required standard at the time of the medical examination.

 

36. The Australian Government amends regulations so that background checks and the

 

requirement to hold an Aviation Security Identification Card are only required for unescorted

 

access to Security Restricted Areas, not for general airside access. This approach would align

 

with international practice.

 

37. The Civil Aviation Safety Authority amends the current Terms of Reference of the Industry

 

Complaints Commissioner so that:

 

a. the ICC reports directly to the CASA Board

 

b. no CASA staff are excluded from the ICC’s jurisdiction

 

c. the ICC will receive complaints that relate to both the merits and the process of matters

 

d. on merits matters, including aviation medical matters, the ICC is empowered to convene

 

an appropriately constituted review panel, chaired by a CASA non-executive director, to

 

review the decision

 

e. while all ICC findings are non-binding recommendations, the original decision-maker is

 

required to give reasons to the CASA Board if a recommendation is not followed.

 

 

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Looks like the review panel addressed a lot of industry concerns. It will be interesting to see how many of these recommendations are implemented, but it seems like a good start.

 

rgmwa

 

 

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35. The Civil Aviation Safety Authority devolve to Designated Aviation Medical Examiners the ability

 

to renew aviation medical certificates (for Classes 1, 2, and 3) where the applicant meets the

 

required standard at the time of the medical examination.

 

Interesting word 'devolve' means to delegate, transfer, entrust, give to, pass to ....

 

This will be interesting, I take it this is different to the current method where the DAME can sign your medical at renewal and it is valid until the new medical arrives from CASA (as long as they dont review and decline in the mean time).

 

It sounds like the intent is for the DAME to renew the medical. But how will that be managed? I'll bet CASA will still want their fee to administrate the process, and I'll bet the medicals with "renew by CASA only" will still be stuck in that merry-go-round process.

 

 

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They'll need to clean out the dead wood at CASA Avmed before there'll be any devolution to DAME's. That mob are in the business of 'make work' via their so called 'complex case management committee' which takes months to review the many renew-by-CASA only cases. When CASA Avmed require a renewal-by-CASA only status, for 5 years, on a minor excision of a melanoma - you'd have to believe that they are just creating an empire. Realistically, a DAME can do a much better job because they see the pilot, and should be able to collaborate with local specialists to develop a prognosis and a treatment plan as needed. This is one section where we all have an interest and we need to make comment on it.

 

happy days,

 

 

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I dont see how that helps us as PICs

Think this refers to the area within the blue lines, (which is RPT parking only - from 30 mins before scheduled time to 30 mins after they leave), plus the inside security area, as being separate from general airside access, ie, you can be airside on a full security airport but not in these blueline areas without ASIC. It will probably have many interpretations and be a source of aggravation until the industry obtains a uniform understanding. Currently, you can't even be in your airside hangar without an ASIC being worn. Sucks!

 

happy days,

 

 

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If all these recommendations are implemented it would seem that CASA will change from the BIG Brother approach to Friendly Brother approach. Apart from that Australia would finally come in to line with most other countries with a collaborative rather than adversarial approach.

 

Ramp checks are one of the first things that should go. I can't see how they improve safety at all.

 

Roll on the changes.

 

 

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It sounds like the intent is for the DAME to renew the medical. But how will that be managed? I'll bet CASA will still want their fee to administrate the process, and I'll bet the medicals with "renew by CASA only" will still be stuck in that merry-go-round process.

This is how it should be done as it is in NZ. The DAME issues or renews the medical certificate and updates the CAA records on line. Simple. What CASA does for their fee is what the DAME does in completing the records. It doesn't mean hours of extra documentation as this is already done by the DAME. It is just double dipping and big brother regulation for its own sake.

If the new CASA boss is as they have specified he should be, then there is light at the end of the tunnel. The problem might be that it all just makes too much sense for a public service organisation like CASA to accept.

 

 

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It matches most of the submissions which were very light on with specifics, so a heap of wriggle room, no real timelines, and no specific processes. Those who are used to setting or evaluating kpi's in Companies will know the pattern.

 

It does put some discussion subjects out there which could be worked on though. but I suspect the initiative would have to come from the operating side of the industry rather than CASA

 

 

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the ONLY purpose of a ramp check should be to educate.. not revenue raise through fines...

A fine focuses the mind and may ensure that proper fuel management is undertaken therefore mitigating the possibility of a lack of fuel and a resultant crash into the local school during school hours.

In NSW cars are only rego checked once a year but there a loads of cars and trucks out there waiting to cause serious accidents (including death) because of vehicle faults. If the cops did safety checks when they were doing booze checks we might have fewer deaths.

 

 

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... In NSW cars are only rego checked once a year but there a loads of cars and trucks out there waiting to cause serious accidents (including death) because of vehicle faults. If the cops did safety checks when they were doing booze checks we might have fewer deaths.

Really ... and just how many fatalities in road accidents have been statistically linked to mechanical faults that would have been picked up in mechanical check?

Col I would suggest bugga all otherwise the other Australian States would have introduced compulsory mechanical checks and at the moment at least three don't require it.

 

I have often wondered what a cost benefit analysis would show in this area.

 

 

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In Vic, you can pay the rego fee over the internet by EFT. No checks, no forms unless there is a change, and no new rego sticker issued. Police cars are equipped to high speed cameras which can check regos as they pass you on the road, whether you are driving or parked.

 

 

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Same in Qld and SA I believe.

 

We have no rego stickers and the rego cameras in NSW, but still require the annual pink slip (mechanical check) for vehicles over 3 years ? old from memory.

 

 

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A fine focuses the mind and may ensure that proper fuel management is undertaken therefore mitigating the possibility of a lack of fuel and a resultant crash into the local school during school hours.....

Sorry Col...fines don't focus the mind to the extent people refrain from engaging in unsafe activities. If they did, then we wouldn't have 20 million infringements handed out each year for speeding, unroadworthy, careless driving, drink driving and a great many more driving behaviours that are shown to have a high risk for safety of the individual and for the wider public.

 

If the prospect of running out of fuel and crashing and possibly killing yourself doesn't stop people from running out of fuel in their aeroplane, why would you think that a fine would?

 

Kaz

 

 

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bloody ramp checks will be here to stay should be more of them I have been ramp checked 3 times and never had a problem twice at wagga and once at albury it was educational and interesting

 

when they had finished and we were talking I was amazed at what they found out about pilots and planes and some off the reasons given for not having enough fuel not having maps not having licence not having maintenance release not giving radio call was a doosy he couldn't as the radio was in for repair in Brisbane were he came from

 

so you want to fly in the same air space as that clown so bring on no ramp checks at your bloody peril neil

 

 

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Really ... and just how many fatalities in road accidents have been statistically linked to mechanical faults that would have been picked up in mechanical check?...

I have no statistics, but first-hand knowledge of a death caused by a Qld-reg old banger with three brake lines nipped off (i.e. one operating rear brake only). I'm quite happy to pay that bit more for rego, knowing most of the cars coming at me have had some sort of inspection.

 

 

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...If the prospect of running out of fuel and crashing and possibly killing yourself doesn't stop people from running out of fuel in their aeroplane, why would you think that a fine would?Kaz

Surisingly Kaz, it probably would. All the graphic road-safety campaigns had little effect on the road toll, but RBT was a terrific success. It seemed that people took seriously the likelihood of a losing money or licence, but losing a life was just a vague possibility they could ignore. People are funny cattle.

 

 

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Surisingly Kaz, it probably would. All the graphic road-safety campaigns had little effect on the road toll, but RBT was a terrific success. It seemed that people took seriously the likelihood of a losing money or licence, but losing a life was just a vague possibility they could ignore. People are funny cattle.

I'd suggest it is losing the license that has far more impact than the fine. DUI always comes with a license suspension.

 

 

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Sorry Col...fines don't focus the mind to the extent people refrain from engaging in unsafe activities. If they did, then we wouldn't have 20 million infringements handed out each year for speeding, unroadworthy, careless driving, drink driving and a great many more driving behaviours that are shown to have a high risk for safety of the individual and for the wider public.If the prospect of running out of fuel and crashing and possibly killing yourself doesn't stop people from running out of fuel in their aeroplane, why would you think that a fine would?

 

Kaz

I think that the main problem there is that illegal and unsafe are often two different things, you can do illegal things safely, and I see some being legal but unsafe. We focus far too much on being legal and far too little on being safe.

 

 

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Surisingly Kaz, it probably would. All the graphic road-safety campaigns had little effect on the road toll, but RBT was a terrific success. It seemed that people took seriously the likelihood of a losing money or licence, but losing a life was just a vague possibility they could ignore. People are funny cattle.

I think that you'll find drink drivers are rife, they've just got a bit more wiley.

 

 

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