Air Charter Safety Foundation
818 Connecticut Ave NW, Suite 900
Washington, DC 20006
Phone Number (888) 723-3135
- What is the difference between the FAA NASA ASRS and ACSF-ASAP reports?
NASA ASRS is an anonymous, voluntary reporting program. When a report is submitted, it goes into a database managed by NASA that helps identify system-wide safety issues. Filing a report with NASA provides a waiver of sanction from FAA action, should FAA learn about the event independently, i.e., an altitude deviation. In this case, FAA can initiate administrative action against you, and your ASRS report receipt will provide a waiver from any imposed penalty, e.g., a license suspension; however, the administrative action will become part of your FAA file/record.
ASAP, on the other hand, is a confidential, voluntary reporting program. When you submit a report into ASAP, an event review committee works to determine the root cause of the event with your input, in order for the company to make any corrective actions that will help prevent a recurrence of the event and improve safety in your operation. A de-identified copy of your report goes into a database to help identify critical safety issues. Should the FAA learn about your event outside of ASAP, and your report has been accepted into ASAP, you are only obligated to participate in any corrective action that results. There is no FAA administrative action for reports accepted into ASAP.
The whole focus of ASAP is to determine the root cause of an event and not to place blame. The ASAP database cannot be accessed through a Freedom of Information Act (FOIA) request and is not reportable under PRIA.
- How is our (company) confidentiality/anonymity protected among all of the other ASAP participants within the ACSF setup? What exactly do the other operators see?
Each company has its own secure server to maintain their data, which you will always be able to access. Once events have been closed, they are de-identified and pushed onto the ACSF aggregate server. They are generic narratives, similar to NASA ASRS report summaries, so as not to reveal the company.
- Just looking over the MOU, in section 11, paragraph B.... it describes the process for deemed "low risk" events, how does this differ from "high risk" reports?
This paragraph is no longer relevant for accepted reports. Under the new FAA compliance and enforcement policy that became effective October 1, 2015 all reports are treated similarly regardless of whether they are sole-source or non-sole-source. There is no longer any administrative action for reports that are accepted under the rules of the program. The event review committee (ERC) determines the appropriate corrective action and works with the company to remediate.
- How do we sign up?
The first step is to become an ACSF Member. The second step is to sign the FAA/ACSF ASAP Memorandum of Understanding (MOU). The third step is to set-up ASAP training with employees and your FSDO. The fourth step is to enroll company employees in either the WBAT system, PRISM or Baldwin Aviation SMS software in order to submit ASAP reports.
- How long until we are "live" with the program?
It depends how quickly you and your FSDO can sign/process the necessary paperwork & schedule training - ranges from 30-90 days.
- How many reports have you found, the average participating group to submit annually from each, the maintenance side and the pilot side?
The number of reports varies widely by the size of the operation. 95 percent of all reports are submitted by pilots. Maintenance participation lags significantly because they don’t have a reporting culture, and they don’t see a threat of a violation as much as pilots who are out operating in the system on a daily basis.
- What is the litmus test for report elevation to ERC level and what typically gets handled internally?
The types of reports handled by the ERC are safety-related events, e.g., altitude deviation, non-compliance with regulations/SOPs, or anything else related to the safety of flight. The types of reports that get handled internally are usually hazard reports. When a general hazard report comes into ASAP, the ERC members can review it and decide that it’s something better handled internally, without ERC involvement.
- How frequently does the ERC typically meet? What time commitment is typically involved?
For smaller operations, the ERC usually meets quarterly. We usually do the first meeting in person, so everyone can see how the process works. After that, we can do web meetings to make the best use of everyone’s time. The typical ERC meeting for a small operation is two or three hours; could be more could be less, depending on the nature and complexity of the events being reviewed.
- How much control over corrective actions does the FAA typically wield in the ERC process? i.e. Would our safety committee come up with a recommendation that we think works and pitch that to the ERC or does the FAA tend to dictate the corrective action or is it more of a collaboration?
The ERC meets to determine what corrective actions, if any, are needed in response to the event. All decisions of the ERC are reached by consensus, not a majority vote. It is a collaborative process.
- We have deliberately removed management from our safety committee processes to guard anonymity and help encourage reporting. Our management is very safety conscious, so this is simply a perception issue. Any ideas on how we would place management on the ERC without it appearing to be a reversal to the employees?
The ERC is composed of three of the following: a company rep, employee rep, and an FAA rep. An ACSF rep is there as a facilitator, but does not get to vote on the events. The whole purpose of having a management representative is to have someone with the authority to commit resources as needed for corrective actions. The MOU contains very specific language that states that the company will not use any information submitted in an ASAP report to take punitive action against the person who submits a report that is accepted by the ERC.
- When setting up an ASAP program, what exactly does ACSF provide the Operator or Flight Department?
ACSF offers end users a complete turnkey package which includes administration, training, management of the safety data, quarterly reports and complete coordination of the Event Review Committee (ERC) personnel. The ACSF-ASAP program manager facilitates the ERC meetings. The ASAP program allows operators and flight departments to have knowledge of safety events that would otherwise not be discovered or disclosed to the company….with FAA protection.
View the FAA Safety Briefing January-February 2017 Issue.
Page 7: Sharing the Wealth - ASAP Expansion Improves Airspace Safety for All