The European Cockpit Association (ECA) raises concerns over potential pitfalls associated with so-called performance-based safety regulation and oversight in a new position paper released Wednesday. Although the ECA acknowledges benefits to the approach, it also warns of its potential to encourage de-facto self-regulation, leading to “disastrous” consequences such as those produced by failures in oversight of the financial, oil drilling and nuclear industries.

The theory of performance-based regulation (PBR) has gained support among many in the industry as growth in air traffic stands to make prescriptive processes, in which regulators tell the airlines exactly what actions they must take to improve safety performance, increasingly unwieldy and ineffective. A performance-based system, as described in last year’s publication of A-NPA 2014-12 by the European Aviation Safety Agency (EASA), concentrates on measurable safety outcomes rather than prescriptive processes, theoretically improving several aspects of safety regulation, including its ability to tailor oversight activities to reflect the greatest need. According to EASA, other possible benefits include better efficiency through “targeting” of resources, improved focus on the individuals in the aviation system and their role in safety, and, potentially, more active involvement and interaction of all actors in managing the system.

The ECA, however, urges a careful, gradual approach—using what it calls regular feedback loops—in the transition from a compliance-based approach to a performance-based system. It also contends that the compliance-based system must remain in place to set a floor of strict standards, and that performance-based regulation must serve to complement it, rather than replace it.

“You have got to make sure that the new ‘model’ works before you do away with the old one,” said ECA president Dirk Polloczek. “Compliance and ‘box ticking’ exercises, which are common nowadays, are not sufficient in our current dynamic industry. But loosely specified performance-based regulation standards—combined with ‘light-touch’ oversight—can also pose a threat. This is why the implementation of PBR will have to be a gradual, step-by-step process that includes regular assessment and feedback loops, an ‘emergency break’ mechanism and ability to be strictly overseen.”

According to the ECA, a performance-based system will require more human and technical resources than what it calls today’s checking of compliance with prescriptive rules. Therefore, it stresses, successful implementation will depend to a large extent on the ability of national aviation authorities and EASA to supply those resources. It will also depend on a “totally transparent” approach by all “stakeholders” that engenders mutual trust and cooperation among authorities, companies and employees.

“It must be clear to all stakeholders that for a performance-based regulation scheme to function, it will require effects and commitment way beyond the level that we are accustomed today,” said the ECA paper. “A performance-based scheme is not a means to achieve a light regulation and/or save money or resources. Quite the contrary: it will require a lot of extra effort, resources and expertise, particularly in the initial phases of implementation, but also thereafter.”