USPA Reformation Through:
Continuous Oversight, At No Cost, Through the Use of Highly Qualified Volunteers
Despite having knowledge of the incidents reported in the post, “Much is Awry in Ridgely”, the USPA Regional Director recommended Ben Harris, the owner of Skydive Chesapeake, for the position of S&TA at the drop zone. He got the job. Although every S&TA who derives income from the drop zone has to reconcile his interests as an independent Safety Officer with his role as a revenue and cost conscious employee or contractor, the conflict of interest at Skydive Chesapeake couldn’t be clearer, or more dangerous.
After the 2008 "Special Investigation Report", SIR-08/01, where the NTSB studied 32 fatal crashes, the Board concluded that more needed to be done regarding aircraft airworthiness, piloting, surveillance (by the FAA), and restraints (seat belts).
Regarding surveillance they recommended that the FAA conduct inspections of drop zones. After that the FAA, by Federal Order, did regular inspections but after the accident in Hawaii in June of 2019 where a non-airworthy King Air 65-A90 crashed killing ten skydivers and the pilot the FAA wrote in the Official Correspondence that their inspection wasn’t intended to uncover the deficiencies in that aircraft that contributed to the accident. They wrote that skydivers aren’t passengers and therefor the FAA’s responsibilities regarding passenger safety didn’t apply.
Since the FAA doesn’t regard skydivers as passengers, the only oversight relative to aircraft airworthiness by the USPA for Skydive Chesapeake is a one page form that the owner occasionally submits to them attesting to compliance to one of four Part 91 inspection criteria.
The owner of Skydive Chesapeake broke his Group Membership Pledge very shortly after signing it. The operator at Oahu Parachute Center also lacked the integrity to honor his. Should it be expected either would maintain a true safety culture without help and oversight?
A cost free solution would be to enlist USPA members, of which there are 40,000, to provide some of that oversight. What if the USPA encouraged all Group Members to support the formation of safety committees staffed by volunteer USPA members at their drop zones? To qualify, committee members would have to be C or D license holders, pilots, A&Ps, FAA DARs or safety professionals. Another criteria would be that they not derive anything more than incidental income from the drop zone.
Places like Skydive Chicago or Perris have enough revenue to do most, if not all the things that USPA’s Skydiving Aircraft Operations Manual and the drop zone’s Flight Operations Handbook call for with paid staff members. For those drop zones the need for a committee of volunteers is less urgent but it would still have value and their role of oversight could still be vital. For operations like the Oahu Parachute Center or Skydive Chesapeake independent oversight is absolutely critical. Fulfilling specific, day-to-day functions and services at drop zones with revenue problems would allow them to go further toward optimizing procedures and equipment and thereby increasing safety.
New drop zones or ones that serve small markets are less likely to hire Jumpmasters, load masters, boarding escorts, landing monitors and all the other personnel to operate as safely as the manuals would have it. It is undeniable that they are also more likely to cut corners when it comes to safety. (Graphic evidence of that is provided with the picture at the top of this post.)
Group Membership Categorization
To mitigate the cost and alleviate the condition of more roles to fill than individuals to fill them a different organization is in order. What if there were two categories of USPA Group Members? One is a “Legacy” Group Member while the other is a “Committee” Group Member and the drop zone owner would choose the type.
The USPA’s Group Membership Manual would change to add a “Type of Group Membership” section, which would include the terms of the two categories.
Legacy Group Member
Operators who choose this category of Group Membership provide most or all of the functions and services called for in USPA’s Skydiving Aircraft Operations Manual and the drop zone’s Flight Operations Handbook with paid staff members. Functions and services called for in the Aircraft and Flight Operations manuals not carried out by paid personnel may be provided by qualified volunteers who are members of a formally recognized and instituted drop zone Safety Committee according to terms outlined in the following section; “Safety Committee Group Member”.
Safety Committee Group Member
These Group Members use qualified volunteers who are members of a formally recognized and instituted drop zone Safety Committee to provide some of the functions and services called for in USPA’s Skydiving Aircraft Operations Manual and the drop zone’s Flight Operations Handbook.
A True Safety Culture
In this system volunteers provide oversight. The cost to provide the functions and services called for in USPA’s Skydiving Aircraft Operations Manual and the drop zone’s Flight Operations Handbook is mitigated. Consequently, it will be expected and the Group Member Pledge will state, that the Group Member will do his best to provide every function and service called for in both manuals. In such a system, drop zones can be rated. Those who provide most or all of the safety related functions most or all of the time will be rated more highly than those that don't.
This new system calls for USPA members to be actively involved in the safety of every jump. They, in fact, will be elements of a working and ever present Safety Culture.
In a 2008 report titled, “The Safety Culture Indicator Scale Measurement System (SCISMS)”, the FAA states that Safety Culture is, “an enduring value”, common to, “each member of each group in every level of an organization. It refers to the extent to which individuals and groups will commit to personal responsibility for safety; act to preserve, enhance and communicate safety information; strive to actively learn, adapt and modify behavior based on lessons learned from mistakes; and be HELD ACCOUNTABLE OR STRIVE TO BE HONORED in association with these values.
Drop zones are businesses. Currently, USPA license holders are not members of the organization to which the safety culture applies. They are customers. Safety is integral to business operations, not customer relations, so jumpers are NOT honored within the organization for association with the values stated in the definition. Safety Committees would consist of rank and file members of the jumping community whose efforts would be recognized daily and therefor honored.
Terms:
| 1 | Committee Membership |
| 1.1 | Open to C & D license holders, pilots, A&Ps, FAA DARs or safety professionals |
| 1.2 | Closed to professionals who derive more than incidental income from the drop zone operator. |
| 2 | Role of the USPA Safety and Training Advisor |
| 2.1 | The S&TA should advise the committee, attend the meetings and review their work but he doesn’t necessarily need to be a member or approve their activities. |
| 3 | Terms - Drop zone owners and committee members agree to the following terms. |
| 3.1 | Whistle Blower Protection |
| 3.1.1 | Suggestions to the Safety Committee can be submitted anonymously and by any customer of the drop zone. |
| 3.1.2 | Reprisals against USPA members for identifying valid safety deficiencies are prohibited. |
| 3.1.3 | Members of the committee can only be denied the drop zone’s business services for just cause, which needs to be put in writing. |
| 3.2 | Owner Protection from "Disgruntled Customers" |
| 3.2.1 | The committee must be unanimous in their decision in order for any condition or practice to be deemed unsafe or in need of correction. |
| 3.3 | Review of Certain non-financial Business Records (Property Lease) |
| 3.3.1 | The benefit of review of certain business records is illustrated by what happened on two consecutive Saturdays in 2021 at Skydive Chesapeake. The drop zone either didn’t have a lease or they had one that allowed others to use their facilities and landing area for purposes other than skydiving that put skydivers in danger. On March 20, 2021 the property owner was allowed to operate a welder in the packing loft while customers and children were present and parachutes were being packed. The following Saturday the owner had an event for which he used the parachute landing area for another aviation activity. The operators couldn't prevent him from displacing the landing area without lease terms that precluded such a disruption. For that day, the landing area, which was originally chosen for it's distance from obstacles was displaced to an adjacent, plowed field separated from the drop zone by power lines. These are examples of the "Normalization of Deviation" that an operation’s safety committee would scrutinize and prevent. |
| 4 | Function & Activities |
| 4.1 | Forum & voice for anyone’s criticisms, inquiries and suggestions regarding safety |
| 4.2 | Safety Audits |
| A | Equipment: Aircraft Per FAR Part 91.409. Mock-ups, fuel stations, other equipment and facilities to standards. |
| B | Personnel: Pilots - Verification that initial pilot training is complete and that testing of experienced pilots has been conducted according to the USPA’s Jump Pilot Training Syllabus. Credential verification |
| C | Personnel: Skydiving Instructors - Verify that all are qualified and current. |
| D | Personnel: Loadmasters, Jumpmasters and Ground Crew members - Verify Loadmasters and Jumpmasters are qualified and that all ground operations functions and services are fully and properly conducted according to the USPA Aircraft Operations Manual and the drop zone’s Flight Operations Handbook |
| E | Procedures - Fueling operations, weight and balance for every flight, checklists, USPA Basic Safety Requirements compliance, aircraft emergency procedures, loadmaster and jump master responsibilities, proper use of restraints per AC 105-2E, gear checks, parachute landing procedures, off-field landings, ground crew procedures, boarding procedures |
| 5 | Accident and Incident Reports |
| 5.1 | Contribute to and assist in writing accident and incident reports and help to implement recommendations based on lessons learned. |
| 6 | Education |
| 6.2 | Qualify committee personnel and others to function in safety roles. |
| 7 | Oversight of any and all safety matters. Remain continuously vigilant! |
Whistle Blower Protection
From the points made in previous posts in this blog, particularly those concerning conflicts of interest, it’s clear that when it comes to safety oversight, the current methods are insufficient. The NTSB has learned, and the record indicates, that there are a lot of cracks through which a resource limited, overworked or unscrupulous operator could pass. Currently, if a regular skydiver sees an operator ignoring, or worse, exploiting such a crack he’s on his own. A Safety Committee, operating with the full cooperation of the owner, would give anyone with a concern someone to go to.
The USPA does have a whistle blower policy. It is Appendix B of the Governance Manual. It covers directors, officers, employees and contractors of the Organization, not members.
It is Viable
This is viable. Americans volunteer more than almost any society in the world. Drop zones are quite representative of the country so there won’t be a shortage of people who want to join the committee. Ben Harris, Skydive Chesapeake’s co-owner, wrote that there needs to be a divide between his operation and the community. Every community affected by his operation including skydivers, the drop zone’s neighbors, the town of Ridgely, the aviation community in general and even Harris’ own interests stand to benefit from such a reform.
I agree with Rob that this could work and be a positive development to the USPA and all skydivers.
I haven’t read all the above posts, but the idea of forming safety committees at dropzones is a good one. I wonder how many DZs already have such; many other workplaces do. I think it would promote more awareness on the part of everyone, and help the S&TA do their job.
I’m not sure how this part of the above proposal would work: “Reprisals against USPA members for reporting on safety deficiencies will be prohibited.” After all, the owner of any operation has to be able to ground any skydiver, and be able to do so without due process, and it might be difficult to distinguish whether something is a reprisal.
Another possibility alluded to above is to broaden the ability of members to contact the USPA, with the assurance of anonymity if requested. I don’t know if USPA maintains a database of complaints, so they can see if there is a recurring pattern at any given DZ, which could trigger further action.
A third is to have the USPA conduct safety audits, randomly selecting a couple dozen dropzones a year for these. I realize members might not want to cough up more dues to support this, but like the threat of a random IRS audit, it could have some positive effect.
The smaller the dropzone, the greater the possibility for conflicts of interest. I am especially worried about places run by two guys that only do tandems out of their Cessna, without any sport jumpers around who can at least give informal oversight, and might recognize deviance creep.
In the outline that was ultimately the thing that established my whistle blower status there were things that committee members could do daily. At Cross Keys and Delmarva, and probably everywhere, someone is at the airplane when people load to ensure no one walks into a prop. At SC, when we were there, staff often weren’t aware of jumpers landing off the field or even cut-aways until Judi told them. I think the principle of not allowing reprisals is valid even if the implementation in some cases is tricky. The rank and file member is still taking a risk if he reports on safety matters but the proposal called for denial of service action against a committee member to be accompanied by a statement of cause. In my case my suspension from the drop zone was for a phony reason and that was accompanied by a formal document. The reason for banning me from Skydive Chesapeake was never put in writing.
Dropzone suspensions should always be in writing, for the protection of the DZ operator. If someone is suspended for drinking alcohol on the DZ in the middle of operations, if there is nothing in writing and the person comes back the next day, shares a bottle in a corner of the DZ, and something bad happens as a result, it will look a lot better in court to have made the suspension in writing, and duly recorded.
That’s a very good point. Safety is the only thing that would take precedent over legal matters. In your example the first response has to be to make the operation safe so the guy with a high blood alcohol level has to stay on the ground. After that, liability for the operator, the pilot and everyone else has to be considered and that would have to include a written account of the offense. Third might be moral / ethical considerations and those would affect how the suspension process is applied. For example, the jumper should be able to tell his side of the story. The work of the Safety Committee could be based on such a hierarchy. I think we’re getting somewhere.