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  1. Aviation Safety Action Programs Training Module A: Building ASAP Foundations Version Date: 30 April 2012

  2. Outline for Objective 1 OVERVIEW Locate/use ASAP guidance materials and supporting resources related to program development and management Topics (T) and Activities (A): T1-1 Purpose of ASAP T1-2 Benefits of ASAP to stakeholders T1-3 Participation criteria T1-4 History of ASAP T1-5 ASAP guidance materials and supporting resources T1-6 Contents and role of ASAP Advisory Circular 120–66B T1-7 Elements and role of an ASAP MOU T1-8 Contents and role of the ASAP Report Process Chart T1-9 Contents and role of ASAP section of FAA Order 8900.1 T1-10 Contents and role of EDP section of FAA Order 8900.1 T1-11 Contents and role of 14 CFR Part 193 and FAA Order 8000.82 T1-12 Practical guidance and lessons learned T1-13 Safety Management System (SMS) A1-14 Practice applying ASAP guidance and procedures to start-up OBJECTIVE 1 OBJECTIVE 2 OBJECTIVE 3 OBJECTIVE 4 OBJECTIVE 5 OBJECTIVE 6 OBJECTIVE 7

  3. OBJECTIVE 1 About Objective 1 • Locate/use ASAP guidance materials and supporting resources related to program development and management

  4. T1-1: Purpose of ASAP OBJECTIVE 1 Purpose of ASAP • Improve aviation safety • Obtain reports of safety-related concerns or events that may otherwise go unreported • Identify root cause(s) of safety-related events • Determine and communicate corrective action(s) and/or recommendation(s) • Track completion and evaluate effectiveness of corrective action(s) and/or recommendation(s) • Communicate ASAP successes • Build trust to encourage a reporting/safety culture

  5. T1-1: Purpose of ASAP OBJECTIVE 1 Basic Principles of ASAP • ASAPs are initiated with an MOU between representatives from the certificate holder, FAA, and employee group (if applicable) • Safety-related events are voluntarily reported by employees of the certificate holder • ASAP reports are reviewed, investigated, and resolved by the ERC • ERC members work together to reach consensus on decisions for report resolution

  6. T1-1: Purpose of ASAP OBJECTIVE 1 Basic Principles of ASAP (Cont'd) • Non-punitive corrective action(s) and/or recommendation(s) for accepted ASAP reports encourage voluntary self-reporting • Analyses of ASAP data are conducted to identify trends and develop corrective action(s) and/or recommendation(s) • Information regarding root causes and ASAP successes is disseminated to prevent future safety-related events

  7. T1-2: Benefits of ASAP to stakeholders OBJECTIVE 1 Benefits to Stakeholders All stakeholders realize benefits from ASAP: • ASAP Managers • ERC members • Respective organizations • Certificate holders

  8. T1-2: Benefits of ASAP to stakeholders OBJECTIVE 1 Benefits to Stakeholders (Cont'd) • Respective organizations (Cont'd) • FAA • Employee group representatives • Employees of the certificate holder • Supervisors, managers, safety officials of the certificate holder and FAA • Organizational entities that receive ERC recommendations

  9. T1-2: Benefits of ASAP to stakeholders OBJECTIVE 1 Benefits to Stakeholders (Cont'd) • Other certificate holders • Allows certificate holders to participate in aviation industry sharing initiatives to benchmark threats to safety and risk management performance • Provides an opportunity to learn from other certificate holders as well as share experiences with other certificate holders • Flying public

  10. T1-3: Participation criteria OBJECTIVE 1 Participation Requirements • Certificate Holder • Part 121 air carrier, Part 145 major domestic repair station, or other approved entities • Employee Groups • Flight crewmembers, flight attendants, mechanics, dispatchers, ramp service, or other approved groups • Current ASAP Participant List • http://www.faa.gov/about/initiatives/asap/media/asap_participants.pdf

  11. T1-4: History of ASAP OBJECTIVE 1 Early Demonstration Programs • The FAA, in partnership with industry, established several early Demonstration Programs to increase the flow of safety information between the air carrier and FAA • Early Demonstration Programs were successful • Led to the formal development of ASAP and its first Advisory Circular

  12. T1-4: History of ASAP Objective 1 Voluntary Safety Programs • ASRS – 1976 – AC–00–46D • Program supported by the FAA and NASA that collects and analyzes voluntarily submitted incident/accident reports to identify contributors and reduce the likelihood of aviation accidents by issuing alerts and educating through newsletters and research studies • VDRP – 1990 – AC–00–58B • Program that encourages air carriers to submit FAA violations otherwise unknown to the FAA in exchange for no penalties and a filed letter of violation (discarded after 1 year if violation does not occur again)

  13. T1-4: History of ASAP Objective 1 Voluntary Safety Programs (Cont'd) • AQP – 1991 – AC–120–54A • Program that requires a strong commitment from the air carrier to exceed minimum training standards, with the overall goals of improving training/evaluation and being responsive to changes in aircraft technology, operations, and training methodologies • IEP – 1992 – AC–120–59A • Program that has the certificate holder continuously monitor processes and systems to ensure compliance with regulatory requirements as well as identify, monitor, and improve internal policies and processes

  14. T1-4: History of ASAP Objective 1 Voluntary Safety Programs (Cont'd) • LOSA – 1994 – AC–120–90 • Program that has highly trained observers (external to the FAA) ride jumpseat to collect confidential data on environmental conditions, operational complexity, and flight crew performance for safety improvement • FOQA – 1995 – AC–120–82 • Program that requires routine collection and analysis of digital flight data generated during aircraft operations to gain greater insight into the total flight operations environment for the purpose of identifying and correcting deficiencies

  15. T1-4: History of ASAP Objective 1 Voluntary Safety Programs (Cont'd) • ASAP – 1997 – AC–120–66B • Program that encourages employees of certificate holders to report safety concerns and violations to their ERC, without fear that the FAA will use submitted ASAP reports to take legal enforcement action against them. ASAP safety data, much of which would otherwise be unobtainable, is used to develop corrective action(s) and/or recommendation(s) for identified safety concerns, and to educate the appropriate parties to prevent a recurrence of the same type of safety event

  16. T1-4: History of ASAP Objective 1 Differences Between ASAP and VDRP • ASAP and VDRP are two voluntary safety programs that involve self-reporting of safety-related events. There are several distinct characteristics of each, which are described in the table on the following page

  17. T1-4: History of ASAP Objective 1 Differences Between ASAP and VDRP (Cont'd) • Certificate holders are not provided ASAP enforcement incentives • Certificate holders may submit a violation to VDRP that was already submitted to ASAP • Failure to do so could result in FAA enforcement action • FAA investigates all VDRP reports • FAA determines if the certificate holder needs to implement a comprehensive fix to address a violation • FAA may accept ASAP-determined corrective action(s) and/or recommendations(s) as a comprehensive fix

  18. T1-5: ASAP guidance materials and supporting resources OBJECTIVE 1 ASAP Guidance Materials and Supporting Resources • ASAP Guidance Materials • FAA Advisory Circular 120–66B • Provides direction to certificate holders for tasks related to establishing and managing an ASAP • FAA ASAP Report Process Chart • Provides a graphical depiction of the process for reviewing and adjudicating an ASAP report • FAA Order 8900.1 Flight Standards Information Management Systems (FSIMS), Vol. 11, Ch. 2, Sec. 1 • Provides direction to FAA personnel for tasks related to establishing and managing an ASAP

  19. T1-5: ASAP guidance materials and supporting resources OBJECTIVE 1 ASAP Guidance Materials and Supporting Resources (Cont'd) • Supporting Resources • FAA Order 8900.1 Flight Standards Information Management Systems (FSIMS), Vol. 14, Ch. 1, Sec. 8 • Provides direction to FAA investigative personnel for tasks related to compliance and enforcement • 14 CFR Part 193 • Describes the FAA's rules for protecting voluntarily submitted information from disclosure through FOIA • FAA Order 8000.82 • Specifies ASAP information is protected from public disclosure and provides the rationale for its protection

  20. T1-5: ASAP guidance materials and supporting resources OBJECTIVE 1 ASAP Guidance Materials and Supporting Resources (Cont'd) • Supporting Resources (Cont'd) • Best Practices for Event Review Committees (American Institutes for Research (AIR), Dec 2009) • Describes the key features that facilitate the success of ASAP and strategies for achieving those features • Safety Management System (SMS) • Describes a revolutionary process in system safety and safety management that obligates organizations to manage safety with the same level of priority that other core business processes are managed

  21. T1-6: Contents and role of ASAP Advisory Circular 120–66B OBJECTIVE 1 ASAP Advisory Circular 120–66B • Key concepts include: • Basics for developing an ASAP • Processing ASAP reports • Acceptance criteria for ASAP reports • Exclusion criteria for ASAP reports • Handling non-reporting employees • Enforcement policy • Reopening reports • Memorandum of Understanding (MOU)

  22. T1-6: Contents and role of ASAP Advisory Circular 120–66B OBJECTIVE 1 AC–120–66B: Basics for Developing an ASAP • Applicability • Air carriers operating under Part 121 • Major domestic repair stations certificated by Part 145 • Development Considerations • ASAP is entered into voluntarily by representatives from the certificate holder, the FAA, and the employee group (if applicable) • Prior to starting an ASAP, a comprehensive employee and management education program must be developed and implemented by the certificate holder

  23. T1-6: Contents and role of ASAP Advisory Circular 120–66B OBJECTIVE 1 AC–120–66B: Basics for Developing an ASAP (Cont'd) • Types of ASAPs • Demonstration Programs • Certificate holder must develop a separate Demonstration Program for each employee group sought to be covered by an ASAP • Continuing Programs • If a Demonstration Program is deemed successful, the FAA may accept it as a Continuing program • Withdrawal requirements • Regardless of duration, any party to the ASAP MOU may withdraw from the program at any time

  24. T1-6: Contents and role of ASAP Advisory Circular 120–66B OBJECTIVE 1 AC–120–66B: Processing ASAP Reports • ERC consists of a representative from each: • Certificate holder, FAA, and employee group (if applicable) • ERC uses consensus decision-making to review, analyze, and resolve ASAP reports • ERC defines consensus as a result within each member's range of acceptable solutions • ERC must be empowered to make decisions within the context of ERC discussions

  25. T1-6: Contents and role of ASAP Advisory Circular 120–66B OBJECTIVE 1 AC–120–66B: Processing ASAP Reports (Cont'd) • ERC defers to FAA ERC representative where consensus is not reached on events involving apparent violation, a qualification issue, or a medical certification or qualification issue • ERC submits any reports involving an apparent Medical Certification or Medical Qualification issue to the Regional Flight Surgeon • ERC must follow the direction(s) of the Regional Flight Surgeon for medical certification/qualification issues

  26. T1-6: Contents and role of ASAP Advisory Circular 120–66B OBJECTIVE 1 AC–120–66B: Acceptance Criteria for ASAP Reports • Reports submitted in a timely manner • Within the time period specified by MOU • Within 24 hours of becoming aware of possible violation • Reports of possible violations that appear to be inadvertent, and do not appear to involve an intentional disregard for safety

  27. T1-6: Contents and role of ASAP Advisory Circular 120–66B OBJECTIVE 1 AC–120–66B: Acceptance Criteria for ASAP Reports (Cont'd) • Reports that do not appear to involve any of the Big 5 • Big 5 consists of criminal activity, substance abuse, controlled substances, alcohol, or intentional falsification • Sole-source reports that meet all acceptance criteria except timely submission • Reports of repeated violations that meet all acceptance criteria

  28. T1-6: Contents and role of ASAP Advisory Circular 120–66B OBJECTIVE 1 AC–120–66B: Exclusion Criteriafor ASAP Reports • Reports that do not appear to be inadvertent, or that involve an intentional disregard for safety • Reports that appear to involve the Big 5 • Reports not submitted in a timely manner • Reports in which submitter was not acting as an employee • Reports accepted into ASAP but employee does not complete the corrective action(s)

  29. T1-6: Contents and role of ASAP Advisory Circular 120–66B OBJECTIVE 1 AC–120–66B: Handling Non-Reporting Employees • For reports identifying an employee involved in a possible violation who is covered by the ASAP MOU but does not submit a report • ERC determines whether non-reporting employee knew (or should have known) about possible violation • For reports identifying an employee involved in a possible violation who is NOT covered by the ASAP MOU • ERC will determine on a case-by-case basis whether that employee should be allowed to submit a report

  30. T1-6: Contents and role of ASAP Advisory Circular 120–66B OBJECTIVE 1 AC–120–66B: Enforcement Policy • FAA ERC representative is empowered to: • Complete ASAP investigations on behalf of FAA • Coordinate all corrective and administrative actions between the certificate holder and the FAA • For accepted ASAP reports, the FAA: • Transfers all jurisdiction and responsibility for compliance and enforcement investigations related to the event(s) to the FAA ERC representative

  31. T1-6: Contents and role of ASAP Advisory Circular 120–66B OBJECTIVE 1 AC–120–66B: Enforcement Policy (Cont'd) • Handling of accepted ASAP reports • Sole-source reports will be closed with no FAA action and an ERC response to the submitter • Non-sole-source reports with sufficient evidence of a violation will be closed with administrative or informal action • Non-sole-source reports without sufficient evidence will be closed with an FAA Letter of No Action • Reports indicating a possible lack of qualification will be addressed with appropriate corrective action(s) recommended by the ERC

  32. T1-6: Contents and role of ASAP Advisory Circular 120–66B OBJECTIVE 1 AC–120–66B: Enforcement Policy (Cont'd) • Handling of excluded ASAP reports • Events reported but excluded from ASAP will be referred to the FAA for possible enforcement action • ASAP reports that appear to involve the Big 5 will be referred to the FAA for possible enforcement action • FAA may use such reports for enforcement purposes, and will refer such reports to law enforcement agencies, if appropriate • If concluded the event did not involve the Big 5, the report will be referred back to ERC for determination of acceptance into ASAP

  33. T1-6: Contents and role of ASAP Advisory Circular 120–66B OBJECTIVE 1 AC–120–66B: Enforcement Policy (Cont'd) • FAA recommends that certificate holders avoid disciplining employees who submit an accepted  ASAP report • Given the certificate holder is not aware of the event outside of the ASAP report (i.e., a sole-source report to the certificate holder) • FAA prohibits the use of ASAP reports as evidence to support an FAA investigation • With the exception of ASAP reports that appear to involve the Big 5

  34. T1-6: Contents and role of ASAP Advisory Circular 120–66B OBJECTIVE 1 AC–120–66B: Reopening Reports • ASAP reports should be fully evaluated, and to the extent appropriate, investigated by the FAA member of the ERC • The ERC should not accept or close a report until all members have completed their investigation of the event • A closed ASAP report can be reopened and appropriate enforcement action taken if evidence is later discovered that a violation occurred and the report should have been excluded from ASAP

  35. T1-7: Elements and role of an ASAP MOU OBJECTIVE 1 Memorandum of Understanding • Written agreement between representatives from the certificate holder, the FAA, and the employee group (if applicable) • Must meet criteria established in AC–120–66B and 8900.1–ASAP (and any revisions) • Serves as primary guidance for the ERC • Includes program objectives, key terms, guidelines, and a common frame of reference for stakeholders • Should be available for reference during ERC meetings

  36. T1-7: Elements and role of an ASAP MOU OBJECTIVE 1 Main Components of an MOU • General information • Applicability, program specifications/objectives, etc. • Program requirements • ERC roles, responsibilities, report review process • Administrative requirements • Recordkeeping, tracking and analyzing data • Statements of agreement • Voluntary agreement, MOU modifications/termination • Signatories

  37. T1-8: Contents and role of the ASAP Report Process Chart OBJECTIVE 1 ASAP Report Process Chart

  38. T1-9: Contents and role of ASAP section of FAA Order 8900.1 OBJECTIVE 1 Order 8900.1–ASAP • Guidance for establishing and managing an ASAP, in which most of the information is also presented in AC–120–66B • Information presented only in 8900.1–ASAP includes guidance regarding: • Performing the FAA ERC representative's role • Maintaining the confidentiality of report submitter's identity outside of ERC • Sharing information about the Aviation Safety Information Analysis and Sharing system (ASIAS)

  39. T1-9: Contents and role of ASAP section of FAA Order 8900.1 OBJECTIVE 1 Order 8900.1–ASAP (Cont'd) • Incorporating data (e.g., report number, event type, risk category) into the data collection and dissemination tool • Retaining data for a period of time (no less than 2 years) sufficient for evaluating effectiveness of ERC's corrective action(s) and/or recommendation(s) • Coordinating enforcement investigations between the CHDO, FSDO, and FAA ERC representative for that particular ASAP

  40. T1-10: Contents and role of EDP section of FAA Order 8900.1 OBJECTIVE 1 Order 8900.1–EDP Describes procedures and tools for Flight Standards investigative personnel • Presents the EDP flowchart • Describes the E-EDP • Not required for violations accepted into ASAP • Describes how to assess risk using potential severity of an event and its likelihood of recurrence • Presents the EDP Risk Matrix

  41. T1-10: Contents and role of EDP section of FAA Order 8900.1 OBJECTIVE 1 ASAP's Use of Order 8900.1–EDP • Administrative action is applied for events determined to be of High or Moderate risk by an ERC • Warning Notice • Letter of Correction • Informal action is applied for events determined to be of Low risk by an ERC • Oral Counseling • Written Counseling

  42. T1-11: Contents and role of 14 CFR Part 193 and FAA Order 8000.82 OBJECTIVE 1 14 CFR Part 193 and Order 8000.82 • Title 49 of USC 40123 • Federal law stating that voluntarily submitted safety and security information is protected from disclosure • 14 CFR Part 193 • FAA regulation describing the rules for protecting voluntarily submitted information within the FAA • FAA Order 8000.82 • FAA order specifying that ASAP information is protected from public disclosure and why it is important to protect such information from disclosure

  43. T1-11: Contents and role of 14 CFR Part 193 and FAA Order 8000.82 OBJECTIVE 1 Benefits of Disclosure Regulations • Regulations to restrict disclosure of ASAP information ensures success by: • Encouraging employees to submit reports • Protecting jobs from unfair responses • Protecting employees from inappropriate assumptions • Certificate holder actions that ensure confidentiality is maintained include: • Training ERC members regarding confidentiality • Protecting data collected and stored

  44. T1-12: Practical guidance and lessons learned OBJECTIVE 1 Practical Guidance and Lessons Learned • Use practical guidance for decisions about: • Start-up, buy-in, ASAP integration, resource allocation, ASAP manager/ERC team selection • Gather practical guidance from: • Best Practices for Event Review Committees (American Institutes for Research (AIR), 2009) • InfoShare Meetings • ERC members from other ASAP programs • Program managers at the FAA's Voluntary Safety Programs Branch

  45. T1-13: Safety Management System (SMS) OBJECTIVE 1 Safety Management System • SMS is a systematic approach to achieving acceptable levels of safety risk • Composed of 4 components • Safety Policy, Safety Risk Management, Safety Assurance, Safety Promotion • Makes safety management a fundamental business process • Strives to improve safety performance to reduce risk • ASAP is one way to meet the SMS voluntary employee reporting program requirement

  46. A1-14: Practice applying ASAP guidance and procedures to start-up OBJECTIVE 1 Identify Resources Specifying ASAP Guidance and Procedures • Detailed information about this activity can be found in the Student Guide for Module A on pages 106-108

  47. Outline for Objective 2 OVERVIEW • Explain the importance of and strategies for integrating ASAP into each party's safety culture • Topics (T) and Activities (A): • T2-1 Importance of and strategies for integration • T2-2 Importance of and strategies for building professional relationships • T2-3 Importance of and strategies for gaining buy-in for ASAP • A2-4 Practice identifying strategies for ASAP integration and acceptance OBJECTIVE 1 OBJECTIVE 2 OBJECTIVE 3 OBJECTIVE 4 OBJECTIVE 5 OBJECTIVE 6 OBJECTIVE 7

  48. OBJECTIVE 2 About Objective 2 • Explain the importance of and strategies for integrating ASAP into each party's safety culture

  49. T2-1: Importance of and strategies for integration Objective 2 Understanding Safety Culture • Certificate holder's senior management should assess their safety culture to ensure ASAP's acceptance • Leaders of other parties to the ASAP MOU should also assess their respective safety culture to identify and minimize obstacles • ASAP Managers and ERC members are not responsible for assessing the safety culture but should know whether an assessment occurred and the information obtained

  50. T2-1: Importance of and strategies for integration Objective 2 Goals of Safety Culture Assessment • Identify: • What others truly think about their party • What keeps them motivated • What they believe gets rewarded and punished • What are the "unspoken rules" that everyone knows • Capture information about party's current safety perspective and future safety goals • Gain broad perspective from internal and external sources