Evaluación de RLS sobre la Solubilización de la Hemicelulosa

Having developed the rule making process and issuing the NPRM, a defined standard for the level of management of risk and clear performance indicators would be expected to be defined. The requirement for palpable and realistic performance indicators is necessary to allow operators to understand the extent of safety requirements, to introduce the importance of risk recognition beyond concepts of a safe/unsafe scenarios (i.e. that incidents are forewarnings of unsafe conditions), and, accordingly, to encourage reporting and information sharing. Setting performance targets also allows a starting point for the purpose of the regulation and conforms with a key element of best practice in safety management. However, measurements for such performance indicators proves to be difficult. A low level of incidence of accident occurrences has traditionally been used as an indicator of safety in the greater aviation industry. An accident is officially defined as where a person is fatally or seriously injured or the aircraft requires major repair (NZCAR Part 1 – Definitions and Abbreviations). However it may be as applicable to include incidents that do not result in direct harm or to apply a weighted bias to non-fatal accidents as well. Many adventure aviation activities (for example, paragliding) are accepted as having relatively high chance of injury but a low chance of fatality. This makes extreme indicators, such as deaths and serious injury, less applicable to gauge actual safety performance, or to understand what level of control is actually needed to be applied. Notions of safety aside from death or serious injury remain subjective and, in recreational activities, that subjectivity rests

43 largely with the participants. Many are prepared to indulge in certain relatively risky pursuits that

may well involve some level of injury – the public enthusiasm for mountain biking, or for skiing and snowboarding are obvious examples; individuals take part because the chance of fatality or serious injury is low. However the reaction to relatively minor injuries can be large if they involve paying clients (Edens & Morgan, 2011).

From a practical point of view, and particularly when setting indicators of the performance of the safety systems that are in place, the level of incident occurrence (as opposed to accidents) is a strong indicator of safety and is related to proactive improvement measures. Indeed an incident; a near miss or close shave, is a negative safety performance indicator demonstrating possible weaknesses in the system. The understanding of such weaknesses can lead to a direct improvement in safety. The reporting of such incidents is an indicator that safety issues are being identified and addressed14.

The recognition and reporting of incidents is itself problematic. Within the aviation sector there is some doubt as to the effectiveness of incident reporting. A lack of acceptable reporting channels and commercial and competitive pressures means that the majority of incidents go unreported and therefore many potential safety issues remain concealed (Jamieson, 2006; Department of Labour, 2010b). Recent consultation undertaken for the CAA’s Safety Target Outcome Reports indicates a resistance amongst operators in reporting incidents due to the perceived negativity and repercussive effects (CAA 2004b; ibid.). In any case, it is difficult to ascertain even the present accident rate in terms of flying hours for the adventure aviation category as there is no requirement for records to be lodged by unregistered aircraft operators (i.e. sport and recreational aircraft such as paragliders) and this is viewed as highly problematic for setting performance indicators (Campbell, 2004b). The available statistics for light aircraft in New Zealand (i.e., those below 2,721 kgs) over 12 months in 2003/2004 indicated two fatal accidents within 300,000 total hours flown - giving a fatality rate of about 1:150,000 (CAA 2005b). During the same period “sport” aircraft including hang/paragliders (which are unregistered aircraft - with no statistics for

44 the level of activity) had five fatal accidents. More recent statistics reflect similar levels of

fatalities; in the three years July 2007 to June 2010 – for all (registered) sport aircraft there have been 14 fatal, and 22 serious injuries recorded for private operations in this sector (CAA, 2010d).

Following a broad analysis of safety concerns and consultation with various aviation industry sectors the CAA produced safety targets in a Safety Outcome Targets document (CAA, 2005c). These safety targets set the tracking indicators for safety using actual available accident or incident statistics. That document considered adventure aviation under the new category of “sport transport” being part of public air transport (ibid. p18) and developed a target standard for the future based on an estimation of social cost per hour of exposure. These targets were publicised throughout the industry (CAA, 2005c). Regular updates track the trends and a recent example highlights the increasing trend in actual social cost of the sport sector due to the recent rise in the accident rate (CAA 2011e). Having an established risk baseline allows operators to build safety management systems. Ideally such systems will track adverse events or conditions before injuries or fatalities occurs. Safety management Systems (SMS) is the present best practice framework, applicable to wide range of industries including aviation, for the establishment of such systems.