In a remarkable show of alacrity, Indian Ministry of Civil Aviation (MoCA) grounded the Boeing 737 MAX fleet after two crashes involving the plane led to 346 deaths in less than six months.
DGCA has taken the decision to ground the Boeing 737-MAX planes immediately. These planes will be grounded till appropriate modifications and safety measures are undertaken to ensure their safe operations. (1/2)
— Ministry of Civil Aviation (@MoCA_GoI) March 12, 2019
This action by a regulator that instantly grounds aircrew for even using mouthwash before a flight came after many smaller countries took their decisions. I welcome this bold step in true spirit of the old Hindi aphorism ‘der aaye, durust aaye‘ (came late but came safely).
Bloomberg has a list of countries where the Boeing 737 Max cannot fly as of date. You can read it here.
Till late last night, the world waited with bated breath for US Federal Aviation Authority’s (FAA) decision. The FAA, a paragon of virtue for matters aviation, sent out this disappointing tweet on 13th Mar 19, even after DGCA had grounded the MAX fleet:
“Thus far, our reviews shows no systemic performance issues and provides no basis to order grounding the aircraft”.
Many aviation watchers like me watched in utter shock. Then in a bizarre but totally understandable U-turn few hours later, FAA grounded the Boeing 737 Max. Even as they took time to decide, their confusing tweets invited strong reactions from Twitterati. Please take a look:
— The FAA (@FAANews) March 13, 2019
Apparently, blood has a different colour in the US and it took ‘satellite data’ to confirm that too many people have died. The FAA will have to live with this ignominy for weeks to come. It almost appeared like they had sold their soul to the moneybags while bodybags were piling up at Addis Ababa.
Safety & security are two holy cows in aviation nobody can touch. Aviation and aviation security regulators always take the moral high ground when it comes to these two animals. But things can be different when either big money or bad publicity is involved. In the 737 MAX case, there’s a delicate combination of the two.
A day after the Ethiopian Airlines Max8 ET-AVJ crashed soon after takeoff from Addis Ababa airport killing 157 passengers, a public notice was issued by Indian regulator DGCA directing airlines operating these aircraft to follow additional checks and balances in equipment serviceability and crew experience. Then they waited to see which side the wind blows.
MAX is MIN in India
Only two Indian carriers, Spicejet (12 aircraft) and Jet Airways (5 aircraft) have the B737 MAX in their fleet.
That’s not a big number at all considering thousands of commercial airplanes flying around in Indian skies, led by the incumbent government’s ‘hawai chappal to hawai jahaz‘ vision (flying for everyone). The decision to ground would have been a no-brainer, many felt. Yet, there was that finite pause.
Soon after the Ethiopian crash, there was public uproar worldover regarding safety of the 737 Max8 and its Manoeuvring Characteristics Augmentation System (MCAS). The same MCAS behaviour triggered by a faulty angle of attack sensor is suspected to be behind the Lion Air Flight 610’s crash off Indonesian coast in Oct 2018 that killed 186.
After many countries like China, Singapore, Australia, Ethiopia, Nigeria, UK, etc. grounded the Max8, India followed suit. Whether this was done fearing public outrage or genuine safety concerns, we don’t know. What matters is we took the decision when we did. FAA dragged its feet.
Moneybags or Bodybags?
It’s a tough call to compare FAA with DGCA. But one thing is clear. When it comes to big money or powerful lobbies, nobody is above board. Here’s my question to both these regulators:
What if the airplane in question was an Airbus?
Boeing is an American company. Airbus is European. As per Wikipedia, Boeing 737 is the highest selling commercial jetliner in history . The 737 MAX is the fourth generation of this aeroplane. As of Feb 2019, over 15000 Boeing 737s have been ordered of which 5000 are for the MAX (376 delivered).
Fortunately, the 737 MAX is MIN in India! In India, Indigo Airlines alone has over 190 Airbus A320s.
Now please sit back and reflect on the numbers, jobs, homes & hearths involved in a decision like this.
Ah! The moment of truth is here!
When it comes to big money and decisions that affect millions of lives & livelihoods, nobody is immune to bias or moral turpitude.
DGCA, Please Seize the Initiative, Set the Bar High…and Logical!
I take this opportunity to applaud DGCA, often at the receiving end of mirth and criticism for their dodgy ways and penchant for ‘copying’ from here and there. At least once, you submitted your homework before the FAA did. So this is a good time as any to do some more introspection, seize the initiative and shape course to become the gold standard for aviation – a tough call, but eminently doable.
Let me elaborate with some simple examples that can be the start point for such transformation.
A Quicksand of Rules
First up on any aircrew’s flying day in India is the preflight breath-analyzer check (BA check).
In India, BA check is mandatory before every single flight or the first flight in a series of flights. Whether or not you have the situation (NSOP vs Scheduled operators), conditions or prescribed equipment, BA check is inviolable here. Great. Who can debate a rule which holds ‘zero’ as pass-mark for a test called ‘medical examination of aircraft personnel for alcohol consumption’?
The difference is in minute details of how such tests are administered & documented. The Civil Aviation Requirement (CAR) on the subject talks at length about ‘blood alcohol’ while what’s measured is your breath!
India is the only country in the world which requires a breathalyzer check to be performed, under CCTV with a doctor/paramedic in attendance, before the first flight each and every day. It is a system founded in good intentions but rooted in mistrust, fraught with unnecessary risks and violates an individual’s right to privacy and employment. It is also a primary cause for many ‘casualties’ which is but expected in a ‘zero tolerance’ system. In my time, I have seen highly experienced and skilled aircrew grounded because of bloopers like such:
- Use of mouthwash
- Use of OTC expectorants
- Dental procedures involving use of sanitisers/disinfectants
- Cleaning of medical inspection rooms with sanitizers / disinfectants (crazy? It’s true!)
- Missing a BA check due to memory lapse, distraction or task saturation
- Use of after-shave lotions or sanitizers
Booze? Hell, I Don’t Even Touch The Drink!
Now, now! How can anyone engage in a debate with alcohol on one side and aeroplanes on the other? It’s a no-brainer, right? Well, the FAA and most other developed countries don’t think so. Random, surprise checks for alcohol, narcotics and psychotropic substances are the norm elsewhere in the world. They’ll catch you unawares with small cups you have to pee into. Humane & scientific methods separate wilful offenders from the casual user of good ol’ grandma’s cough medicine. Here, they plant size-8 boots on your backside and send you home.
In the Indian system, even teetotallers have been grounded for three months; enough to motivate a healthy pilot to switch careers.
Today we have just 300 civil helicopters in India. The US has over 12000. Pilots don’t come cheap or easy. Nor are they all teetotallers or habitual drinkers. Such a system places undue burden on NSOPs and is bound to fall apart when we grow. Or worse, it’ll hamper growth.
In many areas, the FAA with their honor system and ‘just culture’ has been a regular go-to for Indian rulemakers. As per my American colleague who has seen both sides of the fence, in the US, there is no system of preflight BA checks. It is truly random & without notice. Drug & alcohol test is administered only if there’s a doubt that a person is under the influence. Even then, he or she has the option to pull out of the roster and self-report. He keeps his job and can be returned to useful duty. If he refuses that option and the test is positive for BAC > 0.04 dl, the pilot loses his licence.
In India, that threshold is ZERO because we trust nobody! So is rehab or chances of mitigation through an appeal or review. So the crew goes home, chin down, with no pay or insurance. The company loses a trained crew, the individual faces job-loss, three months’ pay and his licence is stigmatised for life. Who wins, who loses with this well-founded but badly administered ‘zero-tolerance policy’ is anybody’s guess.
Also, such daily checking and harsh, punitive action only drives the habit underground (like prohibition) and teaches crew how to ‘play’ the game. It incentivises aircrew to invest in personal devices (forbidden by law) and interlocks, enjoying the tipple under a system meant to separate the twain.
Wait. There’s more.
It is 2019. Even Regional Transport Offices (RTO) and CSD liquor canteens issue smartcards. Indian flying licence is still a small booklet which can’t survive its own validity period. The paper and print quality are such that the parchment soon fuses together and crew have to peel their own mug shot from the preceding page. Entries are hand-written, rubber-stamped, and signed in ink. This is the coveted flying licence students pay crores to earn. Have some respect for their parents’ hard-earned money!
The Rubber Stamp Culture
This belongs to the licence-permit raj, not 21st Century. Is Prime Minister Modi with his ‘Digital India’ and paperless economy okay with this? Every piece of paper that is sent for process to DGCA needs to bear at least a few rubber stamps or it will land back on your table faster than a surgical strike. Pilot logbooks, already cramped for space and filled with numerous entries, have to accommodate 2-3 stamps against each entry for recurrent training, proficiency checks, IR tests etc. My school-going son’s diary has none. What are we trying to breed with this rubber-stamp approval culture? Charles Lindberghs or babus?
Mountains of Paperwork
Every time an application is submitted to DGCA, a small patch of forest dies somewhere in the world. Reams of repetitive, self-defeating forms and paperwork, backed-up with copies of approvals & clearances accorded by their own office have to be submitted to clerks who throw them about, adding to a fire hazard near Safdarjung Airport more than being of any value to aviation. Can this stop and we go paperless please? Remember, each crew works through numerous drafts before the final is ready, stamps and all. Is this even environmentally sustainable? And to what purpose?
Death by Training
Every accident, every incident inevitably leads to another training capsule. While the importance of training can never be overemphasised in aviation, who keeps record of the net value such trainings add to the cockpit?
Dubious ‘DGCA-approved’ training institutes that mushroom around the countryside certainly do, milking the cash cow. An ATP-holder flying two types of helicopters has to undergo over two dozen different training sessions (flying & ground training) every year. How will small companies afford this? And who audits the contents and delivery of such training products? ‘Cut-copy-paste’ runs riot in many ‘approved’ training institutes that have their bottom line prioritised over safety of the skies.
Please have an international agency carry out a bipartisan audit and rationalise the quantum, methodology and contents of all such training. Beyond a point, it becomes repetitive, infructuous and distracts from core areas like simulator training. In my opinion, we are already at that tipping point.
Drastic changes are needed in our approach to accident/incident investigation. They need to be more scientific, thorough and timebound. Almost always, it results in a witch hunt at the lowermost level (read pilot/engineer) and looks like a cover-up job. Where’s the central database of air accidents? Why isn’t it in the public domain?
Just an example. In Jan 2018, a PHL Dauphin helicopter crashed into sea killing five senior DGMs of ONGC and two crew from PHL. To date, not even a preliminary report is available for safety sentinels and Accountable Managers. Need I say more?
It is time to move on from aping others and set the gold standard that others will follow. We have it within us to do so and need no ‘gyan‘ from FAA, EASA or CAA. They have the experience, we have the wisdom. We must choose wisely and take the right decisions in time. Just like we did on the Boeing 737 MAX. Even if that was an Airbus.
Lastly, don’t shoot me. I am only a messenger. Besides, I love flying!
(This story was first published by The Quint on 15th Mar 19. You can read it here)
©KP Sanjeev Kumar, 2019. All rights reserved. Cover photo by ace aviation photographer @VishalJolapara.
An article written by me in the wake of Lion Air Flight 610 crash can be read here.
Please consult national regulations and your company’s Operations Manual for rules as applicable to the type of operation you undertake. Views are personal and do not reflect those of my employer or the industry at large. I can be reached at firstname.lastname@example.org.