Integrate ASAP into your SMS for Enhanced Aviation Safety Reporting

ASAP and SMS:

FAA Advisory Circular AC 120-66C explains how to develop an Aviation Safety Action Program (ASAP) within your organization. Many people are reluctant to report an error or other event that may involve a regulatory violation. The objective of ASAP is to encourage safety reporting by offering protection from civil penalties and/or certificate suspension when these events occur. Risk controls and corrective actions can then be implemented to prevent recurrence.

But aren’t we already doing that with our reporting system in the SMS? What about Aviation Safety Reporting System (ASRS) reports? Some companies also use the Voluntary Disclosure Reporting Program (VDRP). Do we really need another safety reporting program?

The good news is that these programs can now be integrated into a properly developed 14 CFR Part 5 Safety Management System.

Background:

NASA’s ASRS confidential reporting system was established in 1976 to identify potential safety concerns in our aviation system. The program worked because 14 CFR § 91.25 specifically prohibits use of these reports for enforcement purposes. But because ASRS cannot report event details back to a reporter’s company, safety analyses are often unavailable to department managers who can take preventative / corrective actions to mitigate risk.

Likewise, FAA Advisory Circular AC 00-58B Voluntary Disclosure Reporting Program sets forth procedures for operators to voluntarily report 14 CFR violations. The VDRP provides operators with a way to avoid civil penalties when an unintentional violation is discovered, and fosters a cooperative relationship between the operator and their principal inspectors.

With the advent of Safety Management Systems, audit findings and reports of irregularities, occurrences, errors and apparent violations enter the SMS for hazard identification and risk mitigation. Understanding the causes of errors is particularly important (as this is where most violations occur), so we can develop strategies for reducing, eliminating, capturing, and tolerating errors.

But if those errors include potential regulatory violations, few certificated airmen will report them for fear of certificate suspension and/or a record of violation. That’s where ASAP comes in; it brings protection from enforcement action into your SMS.

A New Paradigm

Modern Safety Management Systems now have integrated ASAP, ASRS, and VDRP reporting. These programs, together with a positive and non-punitive safety culture, are essential to a successful employee reporting program.

Under the ASAP, airmen can now freely report apparent violations, and be assured of protection from FAA enforcement actions. The company can also report unintentional violations to FAA using VDRP, and corrective action plans (CAPs) can be implemented for employees, operational departments, and the company as a whole – all in a single web-accessible management tool.

Conclusion

ASAP helps prevent accidents and incidents by encouraging pilots, mechanics, cabin crews, and other covered group to report their errors, minor events and potential violations.

Investigation of each ASAP report identifies hazards and the causes of errors; risks are analyzed and assessed. The ASAP Event Review Committee (ERC) then determines if corrective actions for the reporter are necessary, and if the organization should implement risk controls to prevent recurrence of the reported event.

SMS processes such as follow-ups, periodic risk control assessments, and safety performance monitoring provide assurance that actions are completed and CAPs remain effective. De-identified lessons learned can also be shared with specific employee groups to increase employee awareness.

ASAP offers vast improvement over traditional FAA legal enforcement and company disciplinary action. If a reporter meets criteria for participation and complies with the ERC’s corrective actions, the event is closed with administrative action or no action in lieu of legal enforcement.

Through ASAP, both FAA and the company benefit from increased reporting, identification of hazards and enhanced system safety. Over time this translates into continuous improvement within the organization and in our aviation system as a whole.