List and describe three (3) of the safety assurance programs that you learned about in this module. Which of these do you think is most effective? Why?
- Safety assurance– all planned and systematic actions necessary to afford adequate confidence that a product, a service, an organisation or a functional system achieves acceptable or tolerable safety. (Commission Regulation (EC) No 2096/2005);
Safety assurance – SMS process management functions that systematically provide confidence that organisational products/services meet or exceed safety requirements. (FAA AC No: 120-92).
Description
Safety assurance activities are at the core of the safety management system (SMS) that aviation service providers (including aircraft operators) shall implement in order to meet ICAO SARPS and regulatory requirements. Safety assurance includes organisational arrangements and systematic processes for continuous surveillance and recording of the organisation’s safety performance, as well as evaluation of the safety management processes and practices. Safety assurance is the means to demonstrate that organisational arrangements and processes for safety achievement are properly applied and continue to achieve their intended objectives.
Safety Assurance should be intrusive and enquiring and not simply an administrative “box ticking” exercise.
SMS Safety Assurance Components identified by ICAO
According to the ICAO Doc 9859 – Safety Management Manual, safety assurance includes the following activities:
- Safety performance monitoring and measurement– aircraft operators/service providers shall develop and maintain the means to verify that the safety performance of the organisation complies with the safety policy and objectives, and to validate the effectiveness of safety risk management. This is achieved by monitoring and measuring the outcomes of activities that operational personnel must engage in for the delivery of services by the organisation.
- Management of change– the aviation service provider organisation shall develop and maintain a formal process to identify and manage the changes within the organisation which may affect established processes, procedures, products and services. The management of change should ensure that required safety performance is achieved by reducing or eliminating the safety risks resulting from the changes in the organisation, the provision of services or in the operational environment.
- Continuous improvement of the SMS– the aviation service provider organisation shall develop and maintain a formal process to identify the causes of sub-standard performance of the SMS, determine the implications of sub-standard performance in operations, and eliminate such causes.
- Summary: VDRPs
Under Title 49 of the United States Code (49 U.S.C.) 40123, certain voluntarily provided safety and security information is protected from disclosure in order to encourage persons to provide the information to the Federal Aviation Administration (FAA).
Qualified Participants
Regulated entities as provided in Advisory Circular (AC) 00-58B, as amended, or, for hazardous materials, in accordance with AC 121-37, as amended.
Voluntarily Provided Information Protected from Disclosure Under This Designation
The content of all submissions by a regulated entity that are accepted under the VDRP, including, but not limited to, all of the following items:
(1) Information contained in an initial notification to the FAA:
(a) A brief description of the apparent violation, including an estimate of the duration of time that it remained undetected, as well as how and when it was discovered;
(b) Verification that noncompliance ceased after it was identified;
(c) A brief description of the immediate action taken after the apparent violation was identified, the immediate action taken to terminate the conduct that resulted in the apparent violation, and the person responsible for taking the immediate action;
(d) Verification that an evaluation is underway to determine if there are any systemic problems;
(e) Identification of the person responsible for preparing the comprehensive fix; and
(f) Acknowledgment that a detailed written report will be provided to the designated FAA official within 10 working days.
(2) Information contained in a detailed written report:
(a) A list of the specific FAA regulations that may have been violated;
(b) A description of the apparent violation, including the duration of time it remained undetected, as well as how and when it was detected;
(c) A description of the immediate action taken to terminate the conduct that resulted in the apparent violation, including when it was taken, and who was responsible for taking the action;
(d) An explanation that shows the apparent violation was inadvertent;
(e) Evidence that demonstrates the seriousness of the apparent violation and the regulated entity’s analysis of that evidence;
(f) A detailed description of the proposed comprehensive fix, outlining the planned corrective steps, the responsibilities for implementing those corrective steps, and a time schedule for completion of the fix; and
(g) Identification of the company official responsible for monitoring the implementation and completion of the comprehensive fix.
(3) FAA generated documentation and electronic information that is directly associated with an accepted VDRP submission, including, but not limited to:
(a) Acknowledgement of receipt of a VDRP submission.
(b) Notification of VDRP acceptance, request for modification, or rejection.
(c) Routine correspondence directly associated with a VDRP submission.
(d) FAA records directly associated with FAA monitoring of a comprehensive fix.
(e) FAA Letter of Correction for an accepted VDRP submission.
(f) A FAA electronic database of VDRP submissions and FAA responses.
The FAA finds that withholding VDRP information provided to the FAA is consistent with the FAA’s safety responsibilities. The VDRP specifically provides that appropriate corrective action must be taken by the regulated entity for all instances of regulatory noncompliance accepted under the program. To be accepted by the FAA, apparent violations disclosed under the program must be inadvertent, and, where applicable, must not indicate a lack, or reasonable question of a lack, of qualification of the regulated entity. Corrective action under the VDRP can be accomplished by the regulated entity and verified by the FAA without disclosure of the protected information. If the FAA determines that the steps taken by the entity are not those documented in the written report, the submission may be excluded from the VDRP, and appropriate legal enforcement action may be initiated.
Important:
The FAA will release information submitted under a VDRP as specified in part 193 and this order. To explain the need for changes in FAA policies, procedures, and regulations, the FAA may disclose de-identified (i.e., the identity of the source of the information and the names of the certificate holder, employees, and other persons, as well as any other information that could be used to ascertain the identity of the submitter, redacted) summary information that has been extracted from submissions accepted under the VDRP.
The FAA may disclose de-identified, summarized VDRP information that identifies a systemic problem in the aviation system, when other persons need to be advised of the problem so that they can take correctiveaction. The FAA may disclose de-identified aggregate statistical information concerning VDRP submissions.
The FAA may disclose independently obtained information relating to any event disclosed in a VDRP report, unless the FAA determines that in the case of an accepted VDRP submission, release of such independently obtained information would be inconsistent with the provisions of this order, or would otherwise be prohibited by public law or regulation.
The FAA also may disclose information concerning enforcement action taken for a regulatory violation initially identified in a VDRP submission, when that submission is not accepted by the FAA, or if accepted, it is later excluded by the FAA, because of the regulated entity’s failure to comply with the criteria of the VDRP.
Description
The aviation community is under constant pressure to achieve safety improvement. Operational Flight Data Monitoring (OFDM) offers an efficient solution to this challenge. OFDM is to some extent aquality assurance process but also has a vital Safety Management dimension. It involves the downloading and analysis of aircraft flight recorder data on a regular and routine basis. It is widely used by aircraft operators throughout the world to inform and facilitate corrective actions in a range of operational areas by offering the ability to track and evaluate flight operations trends, identify risk precursors, and take the appropriate remedial action. The potential of OFDM programmes has been materially enhanced by the rapid expansion in the number of data parameters which can be captured using digital recorders now routinely carried on aircraft.
Despite having an enviable safety record, the aviation industry is under constant pressure to drive down accident rates. Air accidents are headline news – from purely a commercial perspective, accidents damage consumer confidence and inhibit the growth of the industry. As an integral part of an airline’s Safety Management System (SMS), analysis of flight data allows safety managers to identify trends and fully investigate the circumstances behind minor incidents so that operational procedures and training can be improved, along with raising awareness of safety issues within the company.
Data from an aircraft is first analysed to identify any exceedances – that is to say any events where the flight manual limitations or guidelines were breached. This is a specialist task undertaken by flight data analysts using sophisticated software tools. Once an event has been identified, an engineer will review the data to confirm its validity, after which the flight safety officer further investigates the circumstances behind the event. Depending on the arrangements within the company, the pilot in command/flying the aircraft at the time of the event will be consulted by the flight safety officer or a union representative. This may result in a formal Air Safety Report (ASR) being raised, or simply an enhancement of the FDM event report. Either way, the involvement of the pilot greatly improves the value of the report.
A just or “no blame” reporting culture is essential if a complete picture of the causal factors behind an event is to be identified. Where the national legal system is such that pilots may be liable to prosecution if events are investigated openly, or the company safety culture is immature, then the anonymity of the crew can be ensured by “de-identifying” the data and through the close involvement of pilot unions or associations in the FDM process. The reluctance of pilots within an airline to contribute to the FDM process is not an indication of any lack of professionalism on their part, but an indication of fear of punishment. Resolution of this fear lies in the hands of the leadership of the company. It is important to realise that the vast majority of accidents within an organisation are the result of a combination of systemic or organisational failures and not the fault of an individual.
Each individual event needs to be investigated and appropriate management decisions made by the airline. Event data may also be pooled with other airlines so wider and longer-term trends can be identified and corrective action taken. Importantly, analysts can also analyse the collected data from normal operations to identify trends before there is a significant event or incident. Both approaches to analysis work together to give the safety officer a greater insight into what is happening within the company. Clearly, the more detailed and imaginative the analysis, the greater the value of the Flight Data Monitoring programme to the company, but equally the greater the resources required for the task.
ICAO Standards and Recommended Practices
In 2008 Annex 6, to the Chicago Convention was amended in order to introduce a number of requirments and recommendations related to the implementation of safety management and safety management systems by operators of commercial air transport aircraft and helicopters. The following paragraphs pertain to the implementation of OFDM:
Annex 6, Part I – International Commercial Air Transport – Aeroplanes
3.3.5 An operator of an aeroplane of a maximum certificated take-off mass in excess of 27 000 kg shall establish and maintain a flight data analysis programme as part of its safety management system.
Note.- An operator may contract the operation of a flight data analysis programme to another party while retaining overall responsibility for the maintenance of such a programme.
3.3.6 A flight data analysis programme shall be non-punitive and contain adequate safeguards to protect the source(s) of the data.
Note 1.- Guidance on flight data analysis programmes is contained in the Safety Management Manual (SMM) (Doc 9859).
Note 2.- Legal guidance for the protection of information from safety data collection and processing systems is contained in Annex 13 , Attachment E.
Annex 6, Part III – International Operations – Helicopters
1.3.5 ‘Recommendation’ – An operator of a helicopter of a certified take-off mass in excess of 7 000 kg or having a passenger seating configuration of more than 9 and fitted with a flight data recorder should establish and maintain a flight data analysis programme as part of its safety management system.
Note.- An operator may contract the operation of a flight data analysis programme to another party while retaining overall responsibility for the maintenance of such a programme.
1.3.6 A flight data analysis programme shall be non-punitive and contain adequate safeguards to protect the source(s) of the data.
Note 1.- Guidance on flight data analysis programmes is contained in the Safety Management Manual (SMM) (Doc 9858).
Note 2.- Legal guidance for the protection of information from safety data collection and processing systems is contained in Annex 13 , Attachment E.
Benefits
FDM strongly contributes to increased flight safety and operational efficiency by:
- Providing data to help in the prevention of incidents and accidents. Fewer flight accidents not only reduce material losses and insurance costs, but also keep passengers’ confidence high.
- Improved operational insight: providing the means to identify potential risks and to modify pilot training programs accordingly.
- Improved fuel consumption: FDM provides the ability to identify and make adjustments to company opertating procedures or specific aircraft with unusually high fuel burn rates.
- Reduction in unnecessary maintenance and repairs: FDM data can be used to help reduce the need for unscheduled maintenance, resulting in lower maintenance costs and increased aircraft availability.
- Improved ground conditions and airports: in certain cases, airlines can use the data captured from their FDM program to support requested changes to air traffic control and airport procedures.
- Reduced number of ACARSmessages: non-critical data (e.g. take-off reports, stable cruise reports) that are sent via ACARS messages, can be acquired, recorded and transmitted via flight data monitoring equipment
- Reduced reliance on flight data recorders: flight-monitoring data can be transmitted automatically over the Internet and be analyzed without delay.
- Adherence to noise restrictions: flight data monitoring helps airlines demonstrate adherence to noise restrictions in terms of being able to verify or deny actually infringement, and avoid incurring fines.
- Improved monitoring of flight crew’s cosmic radiationexposure: flight data monitoring can assist in tracking radiation exposure
- Flight Data Monitoring (FDM) programmes provide powerful tool for the proactive hazard identification.
- Summary: LOSA
Description
Line Operations Safety Audit (LOSA) is seen as an important way to help develop countermeasures to operational errors. It involves a structured programme of observation of front line activities built around the Threat and Error Management (TEM) concept. It aims to identify threats to operational safety, identify and minimise the risks which are the origin of such threats and implement measures to manage the human error aspects of the residual risk. LOSA provides a way to assess the level of organisational resilience to systemic threats in accordance with the principles of a data-driven approach.
LOSA uses trained observers to collect data about pilot behaviour and its situational context on “normal” flights from supernumerary seats on the flight deck. Such monitoring allows the capture of data which can characterise pilot strategies for managing “threats, errors and undesirable states”. The audits are conducted under strict no-jeopardy conditions; therefore, flight crews are not held accountable for their actions and errors that are observed. During flights that are being audited, observers record and code:
- potential threats to safety;
- how the threats are addressed;
- the errors such threats generate;
- how flight crews manage these errors;
- specific behaviours that have been known to be associated with accidents and incidents.
The LOSA method is seen as closely linked with Crew Resource Management (CRM) training. A particular strength of LOSA is perceived as the way it identifies examples of “superior” pilot performance that can be provide models for use in training.
Background
The initial research and project definition was a joint endeavour between The University of Texas at Austin and Continental Airlines, with funding provided by the Federal Aviation Administration (FAA). In 1999, ICAO endorsed LOSA as the primary tool to develop countermeasures to human error in aviation operations and made LOSA the central focus of its Flight Safety and Human Factors Programme for the period 2000 to 2004. The number of operators joining LOSA grew in the period following March 2001 to include some major international operators from different parts of the world and diverse cultures but a reliable picture of the extent of continued use is not known.
Role of ICAO
ICAO has promoted the potential of LOSA and acted as an enabling partner in the LOSA programme. ICAO has developed a manual (Doc 9803) that provides an introduction to the concept, methodology and tools of LOSA and to the potential remedial actions which can be undertaken using the data collected.
What is ASAP?
The purpose of an Aviation Safety Action Program (ASAP) is to identify and reduce flight safety concerns, minimize deviations from Federal Aviation Regulations and to implement corrective measures that manage risks as part of the organization’s Safety Management System.
Pilot ASAP provides the airline’s pilots with a voluntary, cooperative, non-punitive environment for the candid reporting of safety concerns.
For those reports qualified for inclusion in the program which involve substantiated but inadvertent violations or ATC deviations, the FAA will use Administrative Action or Informal Action in lieu of certificate action.
- Informal Action is verbal/phone or written discussion of the event with an ERC or Fleet representative.
- Administrative Action is a letter from the FAA that is held by the FAA for either 30 days or 2 years (depending on severity), then expunged from the pilot’s record.
- No letter is put into the pilot’s permanent records at the airline.
- Administrative Action is not considered a violation.
A Pilot ASAP report itself will not be used to initiate or support any company disciplinary action, except when the report is excluded from ASAP.
Each pilot must submit a separate, individual ASAP report for the same incident in order to be covered under Pilot ASAP for any unintentional regulatory violations resulting from an incident. The reporting pilot should describe the event in as much detail as possible to facilitate the ERC’s clear understanding of all contributing factors.
What type of events can be submitted to ASAP?
Pilot ASAP reports may be submitted for the following:
- Inadvertent violation or potential violation of FAA Regulations.
- Both pilots must report individually.
- Inadvertent deviation or potential deviation from airline Operating Procedures and/or Policies.
- Any event listed in company manuals for which a report is required.
- General flight safety concerns.
Accepted vs. Excluded Reports
ASAP Reports will be accepted into the program upon timely submission with the following exceptions:
- Only events involving the following will be excluded by the Pilot ASAP Event Review Committee (ERC) and will not receive the protective provisions or the enforcement related incentives of the program:
- Criminal activity
- Substance abuse
- Controlled substances
- Alcohol
- Intentional falsification
- Intentional disregard for safety
NOTE: Reports of events which involve criminal activity, substance abuse, alcohol, controlled substances or intentional falsification will be forwarded to the FAA, law enforcement and/or the company for enforcement or disciplinary action.
| Medical IssuesPilot ASAP is not intended to address medical certification or qualification reports. If a Pilot ASAP report is submitted that raises a medical certification or qualification issue, the FAA ERC member will refer the matter to, and follow the directions of, the FAA Regional Flight Surgeon.Events involving crew medical or incapacitation issues while on duty should be immediately reported to the airline’s Duty Pilot and followed up by submission of an Air Safety Report (ASR).ASAP vs. ASR and ASRSASAP reports and Air Safety Reports (ASR) utilize the same electronic form for submission. Both reports go to the airline’s Flight Safety department. The difference is that ASAP reports are strictly voluntary. They are routed to the ASAP Program Manager and have all identifying information (names, date, flight number) removed prior to Event Review Committee (ERC) review of the event.Both ASAP reports and the ASR meet the reporting requirement contained in company operational manuals. Pilots are thus strongly encouraged to utilize the voluntary ASAP report for both required and non-required company reports, any suspected deviation from either company procedures or FAA regulations as well as for any general flight or ground safety concerns.To encourage participation and gain insight into safety events that may have previously gone unreported, all included ASAP reports carry with them an FAA enforcement related incentive as well as a company disciplinary protection incentive.The NASA ASRS voluntary safety reporting system is independent of ASAP and carries its own, independent, and less comprehensive FAA enforcement related incentives. It is not associated with any airline and therefore does not carry with it a company disciplinary protection incentive. |
