A compliance colleague in the investment management industry posted a note regarding this picture:
He argued that the picture was not a compliant landing, particularly, arguing that “Compliance” needs to “monitor the entire flight plan, to make sure things are on track for a good landing.” Although the picture is great and my colleague is a great source of compliance insight, I could not disagree more.
Compliance cannot and will not be everywhere at all times to ensure that all landings will be smooth. We cannot monitor every flight from the control tower and we cannot be on the radio with the pilot to ensure that s/he is aware of the wind conditions, for example, as s/he is approaching the runway. The reality of the situation is that Compliance simply needs to help build a process and regularly test that it is working. If the control tower failed to provide updated information to the pilot or the pilot failed to listen to it on approach, and an accident occurred, my view is that, save for Compliance not correcting a known deficiency, procedural error(s) by the pilot or control tower led to the outcome. Compliance should play a key role in examining why these procedural errors occurred and then help implement controls or new procedures to mitigate a recurrence. In other words, Compliance definitely needs to ensure that landings are compliant and are following a process, but it cannot monitor all activity to essentially police or control an outcome. The business or in this case, the aviation team (pilot and control tower), needs to follow the procedures built for landings and work with Compliance to make improvements if something is awry.