A Personal View Expressed by Niki Tompkinson
“aaaahs” from industry readers, who might well be thinking that it was the regulated party’s lot which was not the happy one! But what was the cause of such disharmony? Surely we were all trying to achieve the same end – the security of the travelling public – weren’t we? So, looking back now from the safe distance of eighteen months out of the job, what might I have done differently to improve everyone’s lot, mine included? As the UK’s transport security regulator from 2002 to 2010, I was dedicated to the role and committed to doing it as well as possible, but nevertheless often felt that I was on a hiding to nothing – unable to do more than take tiny snapshots of security delivery in all its many and various manifestations, and then feeling personally responsible when, as happened from time to time, there were revelations of poor security practices, usually and annoyingly uncovered either by the media or (worse) the European Commission. How had I allowed this to come about, I would be asked? I don’t doubt that other regulators share my paranoia. How often in recent months have I read about some failing in public life, whether relating to the provision of financial or social or other services, only then to hear, sooner or later, an assertion that this event amounted to a failure of regulation. As though that somehow excused the banks for their inability to manage the country’s finances, or the water companies to reduce leaks.
T
When things go wrong, it is of course legitimate to ask “where was the regulator?” and the public have a right to effective enforcement regimes. But it is a fact that regulators cannot be everywhere, and they should not need to be everywhere. They need to do enough to assure themselves and the public that the right regulations are in place and are being adhered to.
But
they will be better placed to give meaningful assurance if they are able to judge that the spirit of the law, not just the letter, is being followed. And if the conversation between regulator and regulated could focus more on spirit and less on letter, maybe that would not only improve the relationship but improve security too. Writing in the pages of this magazine over a year ago (“Aviation Security – time for a re-think?” February 2011), I touched on the government proposal to move to a more outcome-based (now known as Outcome Focused Risk Based) approach to regulation. Of course, it is important that government ensures that regulated parties understand the desired outcome and can demonstrate that the measures are necessary. But I suggested that recasting the regulations themselves is not necessary to achieve this, that it might seem like nugatory and unwelcome work for many directed parties (i.e. it won’t improve their lot), and that the exercise could be a distraction from what really matters, namely the development of a strong security culture. One year on, I continue to hope that common sense will prevail, that the regulations will be left well alone, and that all those who make up the security community, from both government and operators, will start to focus more on the “how” of security and leave the “what” as it is. With the current regulations now established, this
48 Download your FREE ASI "iPad/iPhone APP" NOW
he regulator’s lot is not a happy one – or so it felt sometimes when I was the regulator.
Cue sarcastic
…if the conversation between regulator and regulated could focus more on spirit and less on letter, maybe that would not only improve the relationship but improve security too…
is a good moment to look at the bigger picture of how to get security better embedded. I have often wondered why the safety culture seemed part of the DNA of aviation whereas security was treated with more suspicion, as though it was there to get in the way, not to promote the interests of the industry.
But security awareness
does not have to be exclusive or conflicting; it should be able to exist alongside the commercial and operational cultures which are also essential to the aviation industry. A strong security culture would mean a workforce that understands the importance of what security should deliver and is therefore more likely to get the detail right, one that spots any gaps and responds properly to suspicious occurrences, and one that is also constantly looking for (and rewarded for finding) innovative and more efficient and effective ways of delivering within the operational environment. And there might just be scope for suggesting changes to the operation which would make it more security friendly. So how would a regulator recognise this?
There are tools
available (some even produced by government agencies) for defining the factors that should be present and for measuring how well they have taken hold. Softer issues such as training and communication would feature strongly and, even more importantly, a strong focus on quality management - managers who set the right example, offer incentives to understand and maintain security standards, and ensure that the culture prevails throughout the workforce, not just among the security specialists. Measuring success in these areas should encourage a rather more thoughtful dialogue between regulator and regulated, using common language and seeking to achieve a common aim. I am not suggesting that this replace conventional compliance inspection activity, but it could act as a key indicator for selecting where attention is most needed. So, if I could have my time again……
Niki Tompkinson is a security adviser and commentator. She was formerly Director of Transport Security and Contingencies for the United Kingdom’s Department for Transport (2002-2010).
April 2012 Aviationsecurityinternational
THE F INAL WORD
Page 1 |
Page 2 |
Page 3 |
Page 4 |
Page 5 |
Page 6 |
Page 7 |
Page 8 |
Page 9 |
Page 10 |
Page 11 |
Page 12 |
Page 13 |
Page 14 |
Page 15 |
Page 16 |
Page 17 |
Page 18 |
Page 19 |
Page 20 |
Page 21 |
Page 22 |
Page 23 |
Page 24 |
Page 25 |
Page 26 |
Page 27 |
Page 28 |
Page 29 |
Page 30 |
Page 31 |
Page 32 |
Page 33 |
Page 34 |
Page 35 |
Page 36 |
Page 37 |
Page 38 |
Page 39 |
Page 40 |
Page 41 |
Page 42 |
Page 43 |
Page 44 |
Page 45 |
Page 46 |
Page 47 |
Page 48 |
Page 49 |
Page 50 |
Page 51 |
Page 52