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Is the FRAT Undermining Your Safety Initiatives?

SMS | September 12, 2014

Author: Jeff Whitman

 

The FRAT, also known as the Flight Risk Assessment Tool, has gained a lot of traction in the industry. All the alphabet organizations and SMS vendors are promoting the FRAT as the all-important tool of any valid SMS.

Whether by their own choosing, or through misdirected advice, many operators may actually be undermining their safety initiative through improper use of the FRAT!

For the record, I am a strong supporter of a well-designed FRAT. It is an extremely valuable tool if used correctly. Unfortunately, the correct use of the FRAT is the exception, not the rule. An unintended consequence of its popularity has led to the depreciation of its value.

In this article, we will briefly review the fundamentals of hazard and risk analysis, which will take us into the discussion of how the FRAT may be undermining your safety initiatives. We will conclude with a few suggestions for ensuring you are getting the most out of this valuable tool.

Review of the Fundamentals

To ensure we are speaking the same language, a review of a few fundamentals is necessary. This will help identify where many operators are getting off track.

The purpose of the FRAT is to quantify the compounding risk associated with the exposure to multiple hazards, for a given flight or flight segment.

A hazard is a condition or circumstance that can lead to a physical injury, damage to equipment or property, or a loss of reputation or business standing.

A consequence is the potential outcome or outcomes realized by exposure to a hazard.

Risk is the measuring of the potential consequences, in terms of frequency/probability and severity, of exposure to hazards.

The risk analysis is a comprehensive investigation or study of a hazard to determine the frequency or probability AND the severity of the most credible outcome (consequence) from the exposure to the hazard.

The risk assessment is the organizational tolerance for the identified risk.

In simplest terms:

  • Hazards are the things that can get us in trouble.
  • Consequences are the troubles we manage to get ourselves into.
  • Risk is how often we get in trouble and how much trouble we’re in once we get there.
  • Analysis is the understanding of the hazard/consequence/risk relationship.
  • Assessment is the acceptance or rejection of risk.

The FRAT Template

Most organizations are using the standard FRAT template, provided by the FAA (InFO 07015), via the various alphabet groups and SMS vendors.

Three significant issues call into question the effectiveness of the FRAT template:

1. The hazards identified on the standard FRAT are the problems identified by the FAA, as important to the industry as a whole.

  • The identified issues may not apply to your organization.
  • Worse yet, it may not identify high-risk items that should be considered for your organization.

2. The risk is undefined and the values are generic, suggesting a lack of accuracy for individual organizations.

  • Potential consequences are not identified.
  • Frequency or probability of occurrence has not been quantified.
  • Severity is not defined in terms of worst-case scenario or most credible outcome (risk of what).
  • Values do not address the existence or effectiveness of mitigation.

3. Risk threshold is general rather than an individual organizational tolerance for risk.

  • Organizational acceptance of risk varies greatly.
  • Is risk tolerance the same for operators who carry company principals as it is for operators who carry freight (severity of loss)?
  • For a given scenario, one organization may consider the risk unacceptable, whereas another may recognize it as necessary for mission completion, therefore making it acceptable.

Detrimental Use of the FRAT

Generally, I prefer to talk about the effective way to do things, but in this case, it is important to highlight the usage of the tool that may be counterproductive and possibly undermining your safety initiatives.

Detrimental usage of the FRAT includes:

  • Go/no-goal decision tool.
  • Hazard identification tool.
  • Collecting data without subsequent analysis or inappropriate analysis.

Go/no-goal decision tool

When the FRAT is used to cancel or modify trips, operators tend look for ways to tweak the numbers to eliminate exceeding defined threshold.

Changing the risk value is well and good, but only if you conduct a proper risk analysis on the applicable hazards and apply or account for the effectiveness of mitigation (policy, training, equipment, etc.).

Changing the risk threshold is appropriate if the risk remains in alignment with your defined corporate risk strategy. Do our have a risk strategy?

Arbitrarily changing the numerical values of a risk, or modifying the risk threshold, may present very serious operational consequences. You may actually hide substantial loss exposure associated with the operation. Additionally, it sends the message to frontline personnel that there may be a lack of management commitment to operational safety.

Hazard identification tool

As previously stated, the purpose of the FRAT is to evaluate compounding risk. It is not a hazard identification tool. Operators that use it this way have, in all likelihood, skipped the prerequisite hazard identification, risk analysis and risk mitigation processes, which is beyond the scope of this article.

Subsequent analysis

Operators that ask how long they should keep the FRAT are missing a key point to its purpose. A well-designed FRAT provides an effective means of collecting valuable safety data.

Remember that one element of risk is the probability of occurrence. Probability is influenced by exposure, which can be tracked using the FRAT. Controlling exposure to a hazard is one means of managing risk.

Effectively Using the FRAT

I no longer call the FRAT an ASSESSMENT tool. I call it an AWARENESS tool.

I advise my clients to use the FRAT in the following manner:

  • Remove what clearly doesn’t apply to their operation.
  • Add the hazards and associated risks that we have identified in the prerequisite processes.
  • Modify risk values only after we have completed a thorough analysis of the hazards associated and have applied the appropriate risk controls.
  • Use the risk threshold to trigger additional management scrutiny rather than as a no-go mandate.

In a follow-up article, I will address a few specifics of the FRAT and how to go about making it applicable to your organization.

 

Jeff Whitman is a Safety Management expert. He is the President and CEO of Air Safety Group, LLC, which is an organization that specializes in helping business aircraft operators develop, establish, and manage their safety management initiatives. Jeff is recognized by the International Business Aviation Council (IBAC) as an IS-BAO Support Services Affiliate and an Accredited IS-BAO Auditor.


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