Aviation Safety Action Program and Employee Safety
Reporting
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(Last Revision: Nov. 16, 2010)
What happens when a pilot suffers fatigue
as a result of the noisy remodeling of one of the crew
hotels? There's an increased chance he may screw up on the
flight deck. Or, what happens when a new flight procedure is
worded unclearly? He might take too long to perform it
properly or perform it incorrectly. What happens when newer,
faster airplanes are introduced into National Airspace
System? Existing air traffic control procedures may become
outdated and traffic separation may suffer. All of these
conditions happen throughout a nationwide system all the
time. Any one of them could cause an accident at any time
with the right conditions and triggers. What if we could
identify these threats to safety and correct them before
they become an accident? This is what ASAP is all about.
Objectives
The objectives of the Aviation Safety
Action Program are to prevent accidents and incidents. The
means by which we accomplish these objectives are by
identifying flight safety concerns and achieving corrective
action. Consequently, ASAP analyzes risks, increases
education and awareness, validates program effectiveness,
measures system performance and ensures accountability. As a
result, increased compliance with the FARs is achieved. The
scope of events that are considered under ASAP include any
observation that highlights a potential flight safety
concern. The actions taken in this program reflect the
desire of all parties to solve problems rather than to take
legal enforcement or Company disciplinary action against an
employee. ASAP combines essential self-reporting elements of
previous self-reporting programs and provides solutions to
the identified hazards in order to prevent incidents and
accidents.
Other Pilot Reporting Programs and
Voluntary Disclosure
Events occur in the National Airspace
System each day that highlight potential safety problems.
Timely and accurate reporting of these events is essential
to flight safety analysis and corrective action. Prior to
ASAP, three programs in particular had proven the advantages
of self-reporting in the United States: the NASA Aviation
Safety Reporting System (ASRS), the US Air Altitude
Awareness Program and the Air Carrier Voluntary Disclosure
Reporting Program. Each of these programs has proven
uniquely valuable in identifying common and potential safety
concerns. However, their overall success has been limited by
a variety of constraints.
ASRS was established in 1976 to identify
potential safety problems while providing limited
protections to airmen reporting under provisions of FAR Part
91.25. Since its inception, ASRS has received and processed
hundreds of thousands of confidential reports. Its value as
an aviation safety research database is recognized
worldwide. However, due to the requirements of
confidentiality and jurisdiction, its ability to correct
identifiable airline hazards is severely limited. Prior to
ASAP, many events, which were reported to ASRS, did not come
to the attention of the FAA or the company. Data from ASRS
implied that numerous significant events were occurring in
the National Airspace System that were unrecognized by the
airlines. Yet typically, ASRS cannot report details of
specific events back to the airlines or the FAA, and the
individual airmen involved were unlikely to report them to
anyone other than ASRS prior to ASAP. Therefore, the safety
analyses of these events were not always available to those
who could take preventative and corrective action.
The US Air Altitude Awareness Program
expanded the concept of pilot reporting to corrective and
preventative action. US Air and the Air Line Pilots
Association (ALPA), working jointly with the FAA, developed
a pilot reporting program designed to examine and reduce the
number of altitude deviations occurring at US Air. The
program proved highly successful, both in its analysis of
the causes of these events and in reducing their frequency.
The program also validated the ASRS concept of pilot
self-reporting programs as enhancements to safety. The
result was a proactive approach to finding solutions to a
specific problem. Although highly successful, this
innovative test program was limited in duration and stopped
short of addressing other safety-related concerns.
Similarly, the Air Carrier Voluntary
Disclosure Reporting Program has been successful in
providing a framework for cooperation between the FAA and
individual air carriers. Under this program, airlines have
detected errors and reported both problems and comprehensive
fixes to the FAA. This cooperative relationship has resolved
several potentially serious safety problems. However, many
significant operational events remain ineligible for report
under this program due to the exclusion of individual airmen
by the Advisory Circular, except under special
circumstances. Extension of the spirit and application of
the program to individual employees under ASAP has produced
greater enhancement to safety within the National Airspace
System by providing the company a clearer view of the scope
and frequency of flight safety concerns.
Accident Prevention
Recently, public attention has turned to
the annual rate of aviation accidents worldwide. Although
downward trends in hull losses per million cycles have been
noted in certain years, other years have produced dramatic
increases in accidents involving passenger injuries and/or
fatalities. The worldwide aviation accident rate has not
declined in recent years and is a growing concern due to the
projected annual increase in the total number of flights.
Historically, airlines and government
aviation authorities have acquired limited knowledge of
aviation safety by examining failures through accident
investigation or enforcement of rules and regulations.
Corrective actions in many cases are limited to individual
operators and specific events. Although these responses to
known flight safety concerns have had measurable success in
the past, greater threats may lie outside our traditional
realm of knowledge. Our challenge is to access previously
unidentified areas of concern that can lead to accidents. If
the global aviation accident rate is to be significantly
reduced, we must continue to develop enhanced prevention
strategies that identify risks and accomplish corrective
actions.
ASAP prevents accidents and incidents
through the following essential steps:
-
Identifying hazards (most critical)
-
Analyzing risks
-
Accomplishing corrective actions (most
important)
-
Validating and verifying effectiveness
-
Educating and increasing employee
awareness
-
Measuring overall system performance
-
Ensuring a continuing system of
accountability
The program objectives are served only
after all steps have been accomplished. However, hazard
identification and corrective action are the most critical
and important steps in achieving accident prevention.
Corrective Action Based Incentives
and Sole-Source Reporting
The key ingredient to risk identification
and corrective action is to provide incentive for
individuals and air carriers to report those events that
pose flight safety concerns. In order to ensure the benefit
of self-reporting, ASAP offers certain non-punitive
enforcement-related incentives to encourage individual
employees and the certificate-holding airline to report
incidents of inadvertent non-compliance with the FARs. ASAP
is based on the principles of identification and corrective
action rather than immunity. ASAP offers an alternative to
traditional FAA legal enforcement and Company disciplinary
action. In cases where an individual meets the criteria for
participation and complies with the corrective actions
recommended by the Event Review Team, (ERT), the event is
closed with administrative action or no action in lieu of
legal enforcement. Through ASAP, the FAA furthers its
statutory authority in a way that best tends to reduce or
eliminate the possibility of recurrence of accidents in air
transportation. (Title 49, United States Code Section
44701 (a) 5 & (c)).
I Screwed Up and Here's Why
The Aviation Safety Action Program is a
formal non-liability reporting system whereby an employee
can tell his company, I made a mistake and here's why.
By fully revealing all of the causal factors and
contributors to a mistake, a safety analyst can think about
ways to help other employees avoid the same mistake; any one
of which could cause an accident. By identifying the causes
of errors and controlling their causal factors, we can
reduce the likelihood of an accident. But first, we need to
know what happened and under what conditions it happened.
You Can't Fix What You Don't See
Before ASAP, too many employees were most
likely to hide mistakes from management because of their
perceived negative management reaction. Unfortunately, too
often, this puts management in a situation of not knowing a
problem exists. If you don't know a problem exists, you
have no chance of fixing it. The first airline to formally
introduce an ASAP Program provided an astonishing look into
reality verses perception. The airline's FAA Certificate
Management Office was aware of 55 pilot altitude deviations
occurring in ASAP's first year. ASAP revealed that there
were 550!
With ASAP, the sole objective is to learn
as much as possible about why a mistake was made and to
devise corrections to reduce the likelihood of that mistake
occurring again. The correction may be simply training, an
improved or better written procedure, a new procedure, a
different way of conducting an operation, a re-design of
physical spaces or anything that helps. ASAP fosters a
spirit of cooperation and its success can be measured in a
simple count of the same mistakes occurring in the future.
ASAP Management
I was the Flight Safety Manager in charge
of ASAP when it was first started at my airline. After a lot
of work with my company management and the FAA, upon launch
the ASAP reports starting flowing in; in small measure at
first. We listed and tracked these reports with a simple
Microsoft Excel worksheet. Soon, we began collecting and
categorizing causal factors of errors in order to determine
the scope of their occurrence; also using Excel
spreadsheets. Later we began collecting human factor data
because of the common human factor threads we could see in
similar mistakes being made. Then we began categorizing
errors and the phase of flight operations under which they
were occurring. Then we began extracting data to present in
regular reports to the FAA and company management. As the
program became more well known and trusted by our employees,
the number of reports increased. The program was so
successful that we were soon drowning in data. Up to half of
our productive work days were being taken up with manually
extracting categorized data for reports to management and
the FAA, not to mention manually tracking errors and the
proposed corrections that would reduce the likelihood of
them occurring.
Database Software to the Rescue
If you have ever evaluated software to try
to determine if it can provide you with what you need, I
don't have to tell you that it's a lot of work. And, if
you have had the unfortunate experience of having a software
salesman promise you the moon only to find out his product
didn't work as promised; you are in good company. Here's
one simple piece of advice to avoid a lot of wasted time and
effort: don't ask if a software program will perform a
function, ask to see it perform the function; in a working
program, in real time. Ask to see a department set up. Ask
to see a user created with various security and access
levels. Ask to see an ASAP report filed as if you were an
employee. Ask to see a report analyzed by a safety analyst.
Ask to see a panel created to analyze and create a
mitigation strategy. Ask to see that mitigation requested by
a recipient. Ask to see a recipient's response. Ask to see
how notification emails are automated and how reports are
created. Then, and only then, buy it with a 100% money-back
guarantee.
Get your head out of the data with a good
software tool that allows you more time for managing your
program. Don't waste a lot of your time manually extracting
data for reports. Have them at your fingertips, updated
automatically in real time and ready for printing at will.
Don't hire more safety analysts to handle increased data
demands. Handle your data without manual intervention.
Don't hire more analysts to study and report on monitoring
data for your mitigations. Have your software monitor data
sets and give you alerts when your preset control limits are
exceeded. Your life will be a lot easier and your upper
management and your FAA inspectors will be confident in your
safety program management.
Non-Liability Reporting a
Requirement of SMS
SMS, as defined by ICAO and the FAA
requires the inclusion of a non-liability safety reporting
program.
EMPLOYEE GROUPS
ASAP can be set up for any distinct
employee group and a general reporting system for all
company employees more commonly known as an Employee Safety
Reporting System can be should be set up for everyone.
Pilots, flight attendants, dispatchers, mechanics,
production workers or any organized group can participate in
their own program for their own internal management or
safety department management oversight. A good Safety
Management System (SMS) provides all employees a vehicle
whereby they can report unsafe conditions or safety issues
for management attention.
For more information on how your company
can quickly gain these advantages, please
email one of our Senior Consultants to find out more
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