Transcript Aviation Safety Action Programs Training Module A: Building ASAP

Federal Aviation
Administration
Aviation Safety
Action Programs
Training Module A:
Building ASAP
Foundations
Version Date: 30 April 2012
Outline for Objective 1
OVERVIEW
OBJECTIVE 1
Locate/use ASAP guidance materials and
supporting resources related to program
development and management
Topics (T) and Activities (A):
OBJECTIVE 2
OBJECTIVE 3
OBJECTIVE 4
OBJECTIVE 5
OBJECTIVE 6
OBJECTIVE 7
T1-1
T1-2
T1-3
T1-4
T1-5
T1-6
T1-7
T1-8
T1-9
T1-10
T1-11
Purpose of ASAP
Benefits of ASAP to stakeholders
Participation criteria
History of ASAP
ASAP guidance materials and supporting resources
Contents and role of ASAP Advisory Circular 120–66B
Elements and role of an ASAP MOU
Contents and role of the ASAP Report Process Chart
Contents and role of ASAP section of FAA Order 8900.1
Contents and role of EDP section of FAA Order 8900.1
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
About Objective 1
• Locate/use ASAP guidance materials and supporting
resources related to program development and
management
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
3
OBJECTIVE 1
T1-1: Purpose of ASAP
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-1: Purpose of ASAP
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-1: Purpose of ASAP
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-2: Benefits of ASAP to stakeholders
Benefits to Stakeholders
All stakeholders realize benefits from ASAP:
• ASAP Managers
• ERC members
• Respective organizations
– Certificate holders
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-2: Benefits of ASAP to stakeholders
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-2: Benefits of ASAP to stakeholders
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-3: Participation criteria
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-4: History of ASAP
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-4: History of ASAP
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)
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-4: History of ASAP
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-4: History of ASAP
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-4: History of ASAP
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-4: History of ASAP
Differences Between ASAP and
VDRP
• ASAP and VDRP are two voluntary safety
programs that involve self-reporting of safetyrelated events. There are several distinct
characteristics of each, which are described
in the table on the following page
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-4: History of ASAP
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-5: ASAP guidance materials and supporting resources
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-5: ASAP guidance materials and supporting resources
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-5: ASAP guidance materials and supporting resources
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-6: Contents and role of ASAP Advisory Circular 120–66B
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)
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-6: Contents and role of ASAP Advisory Circular 120–66B
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-6: Contents and role of ASAP Advisory Circular 120–66B
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-6: Contents and role of ASAP Advisory Circular 120–66B
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-6: Contents and role of ASAP Advisory Circular 120–66B
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-6: Contents and role of ASAP Advisory Circular 120–66B
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-6: Contents and role of ASAP Advisory Circular 120–66B
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-6: Contents and role of ASAP Advisory Circular 120–66B
AC–120–66B: Exclusion Criteria
for 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)
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-6: Contents and role of ASAP Advisory Circular 120–66B
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-6: Contents and role of ASAP Advisory Circular 120–66B
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-6: Contents and role of ASAP Advisory Circular 120–66B
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-6: Contents and role of ASAP Advisory Circular 120–66B
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-6: Contents and role of ASAP Advisory Circular 120–66B
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-6: Contents and role of ASAP Advisory Circular 120–66B
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-7: Elements and role of an ASAP MOU
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-7: Elements and role of an ASAP MOU
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-8: Contents and role of the ASAP Report Process Chart
ASAP Report Process Chart
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-9: Contents and role of ASAP section of FAA Order 8900.1
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)
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
38
OBJECTIVE 1
T1-9: Contents and role of ASAP section of FAA Order 8900.1
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
39
OBJECTIVE 1
T1-10: Contents and role of EDP section of FAA Order 8900.1
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
40
OBJECTIVE 1
T1-10: Contents and role of EDP section of FAA Order 8900.1
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-11: Contents and role of 14 CFR Part 193 and FAA Order 8000.82
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-11: Contents and role of 14 CFR Part 193 and FAA Order 8000.82
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-12: Practical guidance and lessons learned
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 1
T1-13: Safety Management System (SMS)
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
45
OBJECTIVE 1
A1-14: Practice applying ASAP guidance and procedures to start-up
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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Outline for Objective 2
OVERVIEW
OBJECTIVE 1
OBJECTIVE 2
OBJECTIVE 3
OBJECTIVE 4
Explain the importance of and strategies for
integrating ASAP into each party's safety culture
Topics (T) and Activities (A):
T2-1
T2-2
T2-3
A2-4
Importance of and strategies for integration
Importance of and strategies for building professional
relationships
Importance of and strategies for gaining buy-in for ASAP
Practice identifying strategies for ASAP integration and
acceptance
OBJECTIVE 5
OBJECTIVE 6
OBJECTIVE 7
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 2
About Objective 2
• Explain the importance of and strategies for
integrating ASAP into each party's safety
culture
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 2
T2-1: Importance of and strategies for integration
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 2
T2-1: Importance of and strategies for integration
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
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 2
T2-1: Importance of and strategies for integration
Importance of Integration
• Encourages acceptance of ASAP within each
party's environment
• Builds trust in ASAP among parties
• Facilitates ERC processes by incorporating
familiar terminology and tools
• Increases efficiency during the start-up phase
by incorporating tools and materials currently
used by other safety programs
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 2
T2-1: Importance of and strategies for integration
Strategies for Integration during
Start-up
• Continue reviewing existing safety goals and
values to ensure thorough understanding
– Use various approaches to gather information, review
existing safety programs and documents
• Align ASAP's goals and processes with other
safety programs and processes
– Adopt same terminology, tools, processes, resources
• Make ASAP understood and visible
– Educate others, participate in organizational safety
meetings, safety committees, and other opportunities
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
52
OBJECTIVE 2
T2-1: Importance of and strategies for integration
Strategies for Integration during Life
of ASAP
• Empower ERC to work without interference
– Discourage external influences, otherwise ERC's
ability to reach consensus will be undermined
– Empower ERC to make and follow up on
recommendations to internal and external entities
regarding resolutions to identified threats to safety
• Encourage continuity of ERC representatives
during early stages to promote partnership
between ERC members
Module A: Building ASAP Foundations
Version Date: 30 April 2012
Federal Aviation
Administration
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OBJECTIVE 2
T2-2: Importance of and strategies for building professional relationships
Importance of Developing
Professional Relationships
• Builds buy-in for ASAP
– Others will follow ERC's lead in support of ASAP
• Achieves timely investigations
– Quickly identify sources and gather of information
• Develops trust in ASAP
– ERC members are respected and likely to be trusted
• Assists in obtaining practical guidance and
lessons learned from other ERCs with similar
experiences
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OBJECTIVE 2
T2-2: Importance of and strategies for building professional relationships
Strategies for Developing
Professional Relationships
• Get to know stakeholders
– Set up introduction meetings
– Attend meetings stakeholders are likely to attend
• Create opportunities to communicate with
stakeholders to ensure they understand that:
– All parties helped develop the MOU and any policies
– The ASAP Manager serves as a liaison between ERC
and stakeholders
– ERC members use consensus decision-making, and
are empowered and given the necessary resources
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OBJECTIVE 2
T2-2: Importance of and strategies for building professional relationships
Strategies for Developing
Professional Relationships (Cont'd)
• Show recognition and appreciation for the
contributions of stakeholders in verbal and
written form
– Acknowledge contributions of each party to the MOU
and ASAP outcomes using various communication
methods
– Encourage management to acknowledge the
contributions of the ERC and other stakeholders
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OBJECTIVE 2
T2-3: Importance of and strategies for gaining buy-in for ASAP
Importance of Gaining Buy-in
• Creates a shared vision of the program
• Increases support for the program and its
ERC, especially during challenging situations
• Supports many outcomes, such as:
– ASAP Manager/ERC commitment; ASAP training;
adequate resources; employee participation; interest in
program results
• Fosters cooperative relationships
• Encourages open communication
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OBJECTIVE 2
T2-3: Importance of and strategies for gaining buy-in for ASAP
Strategies for Gaining Buy-in
• Openly discuss potentially divisive issues
before signing the MOU
• Include many stakeholders in MOU
development including representatives of all
parties to the MOU
• Educate stakeholders about ASAP and its
benefits
• Develop and maintain transparency in the
ERC process
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OBJECTIVE 2
A2-4: Practice identifying strategies for ASAP integration and acceptance
Identify Strategies for ASAP
Integration and Acceptance
• Detailed information about this activity can be
found in the Student Guide for Module A on
pages 134-136
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Outline for Objective 3
OVERVIEW
OBJECTIVE 1
OBJECTIVE 2
Obtain required resources to ensure ASAP
success
Topics (T) and Activities (A):
T3-1
A3-2
Resources required for ASAP success
Practice identifying the resources required for ASAP success
OBJECTIVE 3
OBJECTIVE 4
OBJECTIVE 5
OBJECTIVE 6
OBJECTIVE 7
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OBJECTIVE 3
About Objective 3
• Obtain required resources to ensure ASAP
success
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OBJECTIVE 3
T3-1: Resources required for ASAP success
Resources Needed
• Personnel
– ASAP Manager and ERC members are required
personnel to run an ASAP:
• ERC members consist of a representative and alternate from
the certificate holder, the FAA, and the employee group (if
applicable)
• ASAP Manager also may be the certificate holder
representative
– ASAP Manager and ERC members are required
resources that must be secured at ASAP start-up
– A data analyst may be helpful but not required
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OBJECTIVE 3
T3-1: Resources required for ASAP success
Resources Needed (Cont'd)
• Training
– Most stakeholders will require ASAP training
• Resources to develop, administer, and participate in training
– Training content and delivery must be customized due
to differences in stakeholder needs
– Regular retraining and frequent course offerings are
required due to the dynamic nature of personnel
• Data collection, dissemination tools/support
– ASAPs maintain their own records for administration
and evaluation, typically using an electronic tool
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OBJECTIVE 3
T3-1: Resources required for ASAP success
Strategies for Obtaining Resources
• Establish buy-in with stakeholders who can
help obtain required resources
• Consult with other established ASAPs to help
plan for required resources
– Inquire about type/amount of resources, unanticipated
resources required, obstacles experienced
• Evaluate tools and methods used by other
ASAPs
– Consider adopting effective procedures or materials
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OBJECTIVE 3
T3-1: Resources required for ASAP success
Challenges to Obtaining Resources
• Expense of taking employees "off the line" to
serve as ERC members or ASAP Managers
• Fluctuations in type and amount of resources
needed over time
– Due to changes in volume of ASAP reports over time
• Necessity to analyze data and disseminate
results to fully achieve ASAP's goals
• Tendency to underestimate challenges
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OBJECTIVE 3
A3-2: Practice identifying the resources required for ASAP success
Estimate the Resources Required
for ASAP Success
• Detailed information about this activity can be
found in the Student Guide for Module A on
pages 150-154
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Outline for Objective 4
OVERVIEW
OBJECTIVE 1
OBJECTIVE 2
OBJECTIVE 3
OBJECTIVE 4
Identify and obtain the best qualified individuals to
serve in key ASAP support roles
Topics (T) and Activities (A):
T4-1
T4-2
T4-3
T4-4
A4-5
Roles and responsibilities of ERC members
Roles and responsibilities of other key ASAP support staff
Qualities needed to support key ASAP roles and
responsibilities
Other considerations for selection of individuals for key
ASAP roles
Practice identifying qualities needed of ERC members
OBJECTIVE 5
OBJECTIVE 6
OBJECTIVE 7
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OBJECTIVE 4
About Objective 4
• Identify and obtain the best qualified
individuals to serve in key ASAP support
roles
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OBJECTIVE 4
T4-1: Roles and responsibilities of ERC members
ERC's Roles and Responsibilities
• Oversee program
– Work with ASAP Manager to ensure ASAP guidance,
the MOU, and other internal policies and procedures
are followed (e.g., ERC SOP)
• Review and investigate ASAP reports
– Verify report completeness; conduct investigation;
reach consensus on report acceptance/exclusion,
identifying causal contributors to event, determining
corrective action(s) and/or recommendation(s)
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OBJECTIVE 4
T4-1: Roles and responsibilities of ERC members
ERC's Roles and Responsibilities
(Cont'd)
• Promote safety
– Identify root causes of events; make recommendations
to prevent recurrence; follow up on repeated
instances; disseminate identified safety issues and
recommended preventive measures
• Represent and promote ASAP to stakeholders
– Take opportunities to get to know stakeholders and
share ASAP information with them
• Collaborate with ASAP Manager on program
reviews and reports
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OBJECTIVE 4
T4-2: Roles and responsibilities of other key ASAP support staff
FAA ERC Member's
Roles and Responsibilities
• Determine if FAA has independent evidence
of a reported event
• Assist with determining a possible violation
• Provide ERC with pertinent facts to an event
• Assist with reaching consensus on the final
resolution of a report
• Assist with tracking completion of corrective
action(s) and/or recommendation(s)
• Refer excluded events to the FAA
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OBJECTIVE 4
T4-2: Roles and responsibilities of other key ASAP support staff
FAA ERC Member's
Roles and Responsibilities (Cont'd)
• For complicated or controversial events
– Consult with FAA or industry personnel in a
confidential manner to gain better understanding of an
event
– Notify FAA management of potentially controversial
events submitted to ASAP without disclosing the
submitter's identity
– Provide briefings and information to other FAA
personnel regarding safety events and associated
results of ERC/FAA investigations without disclosing
the submitter's identity
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OBJECTIVE 4
T4-2: Roles and responsibilities of other key ASAP support staff
ASAP Manager's
Roles and Responsibilities
• Provide oversight of the ASAP report
submission and review process
– Receive, record, de-identify, and distribute reports;
confirm receipt of report; track report status; respond
to report inquiries; provide feedback to submitter;
serve as liaison between ERC and stakeholders; share
safety issues with the employee group representative
• Facilitate the ERC meeting
– Coordinate/announce meeting date/time; develop and
distribute agenda; keep meeting on task, encourage
teamwork, provide submitter information as necessary
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OBJECTIVE 4
T4-2: Roles and responsibilities of other key ASAP support staff
ASAP Manager's
Roles and Responsibilities (Cont'd)
• Perform ASAP record maintenance/tracking
– Maintain database with ERC consensus decisions
regarding report acceptance/exclusion, causal
contributors, corrective action(s) and/or
recommendation(s) and their completion, etc.
• Perform or oversee ASAP data analyses
– Collaborate with data analyst, if applicable, to
summarize and identify trends in ASAP data
• Perform or oversee program reviews/reports
– Collaborate with ERC to prepare and distribute reports
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OBJECTIVE 4
T4-2: Roles and responsibilities of other key ASAP support staff
Data Analyst's
Roles and Responsibilities
• Convert raw data from ASAP reports into
meaningful summary information, such as:
– Number/type of reports
– Proportion of reports in a category to total events
– Patterns in causal contributors
– Frequency of events before/after a policy change
– Frequency of reports over time
– Frequency of a particular recommendation for change
– Effectiveness of corrective action(s) and/or
recommendation(s)
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OBJECTIVE 4
T4-3: Qualities needed to support key ASAP roles and responsibilities
Qualities of a Successful
ERC Member
• Commitment to safety
– Allows ERC members to focus on common goals
• Expert knowledge about the work of the
employee group
– Helps ERC members to communicate with and receive
respect from stakeholders, understand report context,
determine acceptable performance, and identify cause
• Knowledge of general system safety principles
– Helps ERC members identify and mitigate threats to
safety
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OBJECTIVE 4
T4-3: Qualities needed to support key ASAP roles and responsibilities
Qualities of a Successful
ERC Member (Cont'd)
• Effective communication skills
– Verbal and listening skills are critical to ERC success
• Other personal characteristics
– Professional maturity, open-mindedness, commitment
to maintaining confidentiality, integrity, belief in the
goal of improving safety, trust in ASAP and pride in
being part of the ERC, freedom from personal or
organizational biases, and commitment to full
participation in ERC meetings are critical to promoting
good teamwork among ERC members
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OBJECTIVE 4
T4-3: Qualities needed to support key ASAP roles and responsibilities
Qualities of a Successful ASAP
Manager
• Commitment to safety
• Familiarity with ASAP, the certificate holder's
other safety programs, and safety principles
• Expert knowledge of employee group's work
• Commitment to maintaining confidentiality
• Skill in meeting and teamwork facilitation
• Strong communication skills, interpersonal
skills, and working relationships
• Respected by peers
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OBJECTIVE 4
T4-3: Qualities needed to support key ASAP roles and responsibilities
Benefits of a
Non-voting ASAP Manager
• Increases likelihood that the ASAP Manager
has sufficient time for ASAP responsibilities
• Enables the ASAP Manager to maintain
confidentiality
• Puts the ASAP Manager in a position to
encourage teamwork
• Results in more timely and bias-free review of
ASAP reports
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OBJECTIVE 4
T4-3: Qualities needed to support key ASAP roles and responsibilities
Qualities of a Successful
ASAP Data Analyst
• Commitment to safety
• Competency with computers and data
analysis programs
• Skill in basic data analysis and interpretation
• Understanding of the employee group's work
and type of reports likely to be submitted
• Competence in working with confidential data
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OBJECTIVE 4
T4-4: Other considerations for selection of individuals for key ASAP roles
Questions to Guide ERC
Participation Policy
• Can individuals take enough time away from
job responsibilities to perform ASAP duties?
• What responsibilities will alternate ERC
members have?
• Is there a specific period of time an individual
should be expected to serve on the ERC?
• What are the performance expectations for
key ASAP personnel, and how will
performance concerns be addressed?
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OBJECTIVE 4
A4-5: Practice identifying qualities needed of ERC members
Identify Individuals to Serve on ERC
• Detailed information about this activity can be
found in the Student Guide for Module A on
pages 186-192
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Outline for Objective 5
OVERVIEW
OBJECTIVE 1
OBJECTIVE 2
OBJECTIVE 3
Select or develop a data management system
Topics (T) and Activities (A):
T5-1
T5-2
T5-3
T5-4
Desirable features of a data management system
Data to collect and track in the data management system
Guidance for event type and causal contributor taxonomies
Guidance regarding ASAP recordkeeping requirements
OBJECTIVE 4
OBJECTIVE 5
OBJECTIVE 6
OBJECTIVE 7
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OBJECTIVE 5
About Objective 5
• Select or develop a data management system
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OBJECTIVE 5
T5-1: Desirable features of a data management system
Data Management System Features
• Collects, analyzes, tracks, and protects
confidential data
• Collects data to support all stakeholder needs
• Includes data fields needed by the ERC
• Customizes data fields in data submission
form for each employee group
• Allows for remote submissions
• Includes email and attachment capabilities
• Includes user-friendly data analysis tools
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OBJECTIVE 5
T5-2: Data to collect and track in the data management system
Data to Collect during ASAP Report
Submission
• Important data include:
– Information about the submitter
– Information about the event, the situation overall, as
well as possible causal contributors
– Permission to submit report to ASRS and/or VDRP
• Some data fields may be pre-populated by the
data management system
– Based on identity of submitter
– Based on time/date of entry
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OBJECTIVE 5
T5-2: Data to collect and track in the data management system
Data to Collect during ASAP Report
Submission (Cont'd)
• The following data fields may also be useful:
– Flight number
– Departure airport
– Scheduled arrival airport
– Landing airport
– Phase of flight
– Weather
– Aircraft position, altitude, speed, configuration
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OBJECTIVE 5
T5-2: Data to collect and track in the data management system
Data to Collect during the ERC's
Report Review Process
• The following information may be useful:
– Information regarding important dates/milestones in
the processing of the report
– Consensus decisions made by ERC regarding the
report, including:
• Report acceptance/rejection; whether sufficient evidence
exists for 14 CFR violation; event type and causal
contributors; risk category; corrective action(s) and/or
recommendation(s)
– Whether event should be submitted to VDRP
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OBJECTIVE 5
T5-3: Guidance for event type and causal contributor taxonomies
Importance of an Effective Taxonomy
• Improves the ERC's understanding of the
submitter's intended event type(s) and causal
contributor(s)
• Provides critical information regarding the
root cause(s) of the event
• Helps identify reports with common elements
– Required for identifying systematic threats to safety
• Facilitates communication about ASAP
reports to all stakeholders
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OBJECTIVE 5
T5-3: Guidance for event type and causal contributor taxonomies
Characteristics of an Effective
Taxonomy
• A comprehensive set of non-overlapping
categories
• Familiar terminology
• Definitions and examples
• Option to record "other" issues that may not
be reflected in the existing taxonomy
• Only high-level categories from the taxonomy
for report submitters' use
• Full taxonomy for ERC's/data analyst's use
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OBJECTIVE 5
T5-3: Guidance for event type and causal contributor taxonomies
Use of Event Type/Causal
Contributor Taxonomies
• Report submitter selects high-level categories
for the event type and causal contributors
– Complete as part of ASAP report submission process
• ERC reviews the report submitter's categories
– If the report submitter has not already specified the
event type or causal contributors, ERC should discuss
and record appropriate classifications
– If report submitter has specified the event type or
causal contributors, ERC should evaluate their
appropriateness and need for additional categories
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OBJECTIVE 5
T5-3: Guidance for event type and causal contributor taxonomies
Use of Event Type/Causal
Contributor Taxonomies (Cont'd)
• ERC discusses and records any subcategories that specify a finer level of detail of
understanding, as presented in the full
taxonomy, that apply to the reported event
– Use information from all reports about the same event
– Incorporate information gained through the event
investigation
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OBJECTIVE 5
T5-4: Guidance regarding ASAP recordkeeping requirements
Guidance Regarding
ASAP Recordkeeping
• ERC should maintain documents and records
needed to administer and evaluate ASAP
– ASAP records should be maintained for at least 2
years to evaluate effectiveness of corrective action(s)
and/or recommendation(s)
• All official documents and records should be
maintained in accordance with Federal
Aviation Regulations and applicable law
– No reference to ERC-recommended training should be
included in an airmen's training record
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Outline for Objective 6
OVERVIEW
OBJECTIVE 1
OBJECTIVE 2
OBJECTIVE 3
OBJECTIVE 4
Identify and explain supportive internal policies
and procedures needed to ensure ASAP success
Topics (T) and Activities (A):
T6-1
T6-2
T6-3
T6-4
A6-5
Potential challenges for ASAP start-up
Internal policies and procedures to establish at start-up
Existing certificate holder policies or agreements to consider
Documentation of internal policies and procedures
Practice identifying the need for internal policies and
procedures
OBJECTIVE 5
OBJECTIVE 6
OBJECTIVE 7
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OBJECTIVE 6
About Objective 6
• Identify and explain supportive internal
policies and procedures needed to ensure
ASAP success
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OBJECTIVE 6
T6-1: Potential challenges for ASAP start-up
Potential Challenges
at Start-up and Beyond
• Building trust and establishing buy-in
• Selecting the ASAP Manager, ERC members,
and their alternates
• Dealing with potentially sensitive issues like:
– Education on reportable events and protections offered
– Keeping ERC members focused on safety, bias-free
– De-identification of reports
– Sharing of ASAP data with other safety programs
– Attendance of non-ERC members at ERC meetings
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OBJECTIVE 6
T6-2: Internal policies and procedures to establish at start-up
Internal Policies and Procedures
to Establish for Start-up and Beyond
• ASAP training
• Managing, analyzing, and retaining ASAP
reports and data
• ASAP report review process
• Communicating ASAP data to stakeholders
• Conducting reviews of internal policies and
procedures
• Handling and sharing ASAP reports across
multiple ASAPs within the certificate holder
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OBJECTIVE 6
T6-2: Internal policies and procedures to establish at start-up
ASAP Training
• Understanding of ASAP and its benefits by all
stakeholders is necessary to:
– Develop trust in the program
– Promote a shared understanding of the program
– Ensure support and buy-in of the program across
organizational levels
– Ensure support of the ERC and its consensus
decisions and recommendations
• ASAP training is a program requirement and
should be viewed as an on-going process
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OBJECTIVE 6
T6-2: Internal policies and procedures to establish at start-up
ASAP Training (Cont'd)
• Develop policies regarding the following:
– Content of training and retraining
– Frequency of ASAP training/retraining offerings
– Process for administering training/retraining (e.g.,
classroom setting, web-based applications)
– Individual(s) in charge of conducting training/retraining
– Process for tracking individuals' completion of training
(e.g., individual(s) in charge; software or system used)
– Incentives in place for completing training/retraining or
consequences for not doing so
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OBJECTIVE 6
T6-2: Internal policies and procedures to establish at start-up
Managing/Analyzing/Retaining Data
• Managing ASAP reports and data
– Certificate holder's process for collecting ASAP reports
• Consider specifying the data management system to be used,
and what data fields will be included in the tool (e.g., event
type and causal contributor)
• Consider specifying taxonomies that will be used to categorize
event types and causal contributors
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OBJECTIVE 6
T6-2: Internal policies and procedures to establish at start-up
Managing/Analyzing/Retaining Data
(Cont'd)
• Managing ASAP reports and data (Cont'd)
– De-identification of ASAP reports
• Submitter identity may not be shared outside the ERC but
ERC should consider whether to remove report submitter's
identity for the initial report review and the appropriate process
• Consider specifying who will remove the information, and
when/at what point in the report review process will the ERC
be given that information
• Analyzing ASAP reports and data
– Data analyst's access to report submitters' identity
– Procedure for selecting an ASAP data analyst
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OBJECTIVE 6
T6-2: Internal policies and procedures to establish at start-up
Managing/Analyzing/Retaining Data
(Cont'd)
• Retaining ASAP reports and data
– Length of time and manner of ASAP data retention
• Consider specifying procedures regarding the ERC's
maintenance of documents and records for the effective
management and evaluation of the ASAP's performance
• Consider specifying procedures regarding the ASAP
Manager's maintenance of all official ASAP documents and
records that is in accordance with Federal Aviation
Regulations and applicable law
• Consider specifying exactly how long data should be retained
to effectively manage and evaluate the performance of the
ASAP, as prescribed by the 8900.1–ASAP
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OBJECTIVE 6
T6-2: Internal policies and procedures to establish at start-up
ASAP Report Review Process
• Pre-meeting preparation for ERC
• Location and frequency of meetings
• Event-related information gathering
requirements of all ERC members
• ERC meeting conduct rules
• Attendance of non-ERC members at ERC
meetings
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OBJECTIVE 6
T6-2: Internal policies and procedures to establish at start-up
ASAP Report Review Process (Cont'd)
• Materials to be available during the meeting
– Consider creating a manual of the specific policies and
procedures to be used as a resource during the ERC
meeting
• Specific procedures regarding protecting
report submitter's identity during an ERC's
investigation
– Consider specifying procedures for the rare situation in
which a submitter reports on another employee who
may or may not be covered by the MOU
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OBJECTIVE 6
T6-2: Internal policies and procedures to establish at start-up
Communicating ASAP Data
• Procedure for determining the type of data
report submitters want or need to receive
– Many opportunities for communication exist, such as:
• Receipt of report; acceptance/exclusion decision; any
corrective action(s) and/or recommendation(s) directed to the
submitter; any ERC recommendation(s) directed to the
certificate holder or other entities; final report resolution
• Procedure for communicating data to report
submitters
– Automatically generated e-mails may be possible with
an electronic data collection and dissemination tool
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OBJECTIVE 6
T6-2: Internal policies and procedures to establish at start-up
Communicating ASAP Data (Cont'd)
• Procedure for determining the type of data
stakeholders want or need to receive
– Consider whether the ERC or upper management will
determine the information each stakeholder needs
• Procedure for sharing data with stakeholders
– Consider who will create ASAP communications, their
contents, method and frequency of communications
• Participation in ASAP InfoShare Meetings
– Consider who may attend and whether funding is
available to support attendance or travel
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OBJECTIVE 6
T6-2: Internal policies and procedures to establish at start-up
Communicating ASAP Data (Cont'd)
• Whether ASAP data will be shared with other
programs that maintain safety data
– If yes, specify the programs eligible to receive data
• Completion of FAA requirements, such as
quarterly/yearly reports and FAA audits
– Consider who will be responsible for their completion
• Consider what the ASAP can reasonably
commit to beyond what is required by the
guidance
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OBJECTIVE 6
T6-2: Internal policies and procedures to establish at start-up
Managing Multiple ASAPs
• Whether and which information will be shared
across ASAPs
– Consider if, when, and how reports will be shared
• Whether cross-ASAP meetings within the
certificate holder will be held when different
employee groups report the same event
• Whether multiple ASAPs will be expected to
work together to develop mutually agreeable
solutions to common problems
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OBJECTIVE 6
T6-2: Internal policies and procedures to establish at start-up
Conducting Internal Reviews
•
•
•
•
•
•
•
Individual(s) responsible for internal review
Procedures for conducting the internal review
Frequency of internal review process
Information/deliverables from internal review
Expectations regarding use of results
Individual(s) to implement the expectations
Ways in which these policies may change
when the certificate holder implements SMS
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OBJECTIVE 6
T6-3: Existing certificate holder policies or agreements to consider
Existing Policies and Procedures
•
•
•
•
Fixed base operator requirements
Labor union contracts
Crew scheduling rules and processes
Handling of safety-related events, accidents,
and mishaps, including required paperwork
• Performance appraisal policies or procedures
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OBJECTIVE 6
T6-4: Documentation of internal policies and procedures
Importance of Documentation
• Documenting policies and procedures:
– Allows ERC members to refer to them at a later time
– Assists new/alternate ERC members with learning
– Allows stakeholders/others to review and refer to them
• Primary approaches to documenting include:
– Develop ASAP SOP Manual
– Develop ASAP website
– Add information to existing manuals, internal websites
– Create an MOU that defines additional processes
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OBJECTIVE 6
A6-5: Practice identifying the need for internal policies and procedures
Identify the Need for Internal
Policies and Procedures
• Detailed information about this activity can be
found in the Student Guide for Module A on
pages 252-262
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Outline for Objective 7
OVERVIEW
OBJECTIVE 1
OBJECTIVE 2
OBJECTIVE 3
Develop and submit an ASAP Memorandum of
Understanding (MOU)
Topics (T) and Activities (A):
T7-1
T7-2
T7-3
MOU development and its role in ASAP
MOU elements and submission requirements
MOU acceptance, renewal, and withdrawal procedures
OBJECTIVE 4
OBJECTIVE 5
OBJECTIVE 6
OBJECTIVE 7
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OBJECTIVE 7
About Objective 7
• Develop and submit an ASAP Memorandum
of Understanding (MOU)
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OBJECTIVE 7
T7-1: MOU development and its role in ASAP
MOU and its Role in ASAP
• Must meet all criteria specified in AC–120–
66B
• Serves as a foundational program document
that supports ASAP objectives
• Should be developed collaboratively
• Should be understood by all stakeholders
• May be prepared using the FAA's automated
MOU generator
• Must be approved by the FAA
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OBJECTIVE 7
T7-1: MOU development and its role in ASAP
Initiating MOU Development
• Prepare a draft MOU containing as much
specific information as possible
– FAA strongly encourages certificate holders to use the
automated MOU generator
• Review the draft
– For the purpose of identifying any questions or
concerns, especially regarding the wording
• Document any questions or concerns raised
• Meet to discuss and resolve any questions or
concerns
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OBJECTIVE 7
T7-1: MOU development and its role in ASAP
Using the FAA's Automated
MOU Generator
• Accessible via the FAA's ASAP website
• Can be used for either a Demonstration or
Continuing Program
• Minimizes time for FAA's review/approval
• Populates the MOU with information specific
to certificate holder and type of ASAP based
on responses to 22 background items
• Produces MOU as either text or Microsoft®
Word document
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OBJECTIVE 7
T7-1: MOU development and its role in ASAP
FAA's MOU Checklist
• MOUs developed without automated MOU
generator require:
– Completion of the ASAP MOU checklist found in
Appendix 2 of AC–120–66B
• Consists of 27 "Yes/No" questions that also require paragraph
references to support answers provided
– Legal review by the Office of the Chief Counsel,
Enforcement Division
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OBJECTIVE 7
T7-2: MOU elements and submission requirements
Elements of an ASAP MOU
• An MOU created using the FAA's automated
MOU generator contains 16 sections
• Each of these 16 sections can be linked to the
28 MOU elements described in AC–120–66B
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OBJECTIVE 7
T7-2: MOU elements and submission requirements
Description of MOU Sections
1. Description of Certificate Holder (E-1)
– Describes type of operator, operation size, number of
employees, whether labor union represents employees
2. Purpose of ASAP (E-5)
– Describes purpose of ASAP
3. Benefits of ASAP (E-6, E-20e)
– Describes benefits of ASAP
4. Applicability of Program (E-1, E-15)
– Describes employee group and type of events covered
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OBJECTIVE 7
T7-2: MOU elements and submission requirements
Description of MOU Sections (Cont'd)
5. Program Duration (E-2, E-3, E-16 thru E-19)
– Specifies the type of program, duration, and conditions
6. Reporting Procedures (E-9, E-22)
– Describes report form, timely submission, procedures
for addressing non-reporting employees
7. Points of Contact
– Identifies ERC representatives and ASAP Manager;
indicates whether ASAP Manager is a voting member
8. ASAP Manager
– Describes ASAP Manager's report processing tasks
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OBJECTIVE 7
T7-2: MOU elements and submission requirements
Description of MOU Sections (Cont'd)
9. Event Review Committee (E-10, E-12, E-20a)
– Describes the duties associated with the ERC
– Specifies ASAP Manager will maintain data and
frequency of data reviews
– Describes tasks for program reviews and renewals
10. ERC Process (E7, E-10, E-20b, E-26)
– Describes additional ERC processes and procedures
– Specifies corrective action must be satisfactorily
completed and the consequences of failing to do so
– States incentives for accepted sole-source reports
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OBJECTIVE 7
T7-2: MOU elements and submission requirements
Description of MOU Sections (Cont'd)
11. FAA Enforcement
– Criteria for Acceptance (E-11, E-24, E-27)
– Administrative or Informal Action (E-20d, E-20e)
– Sole-Source Reports (E-20c)
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OBJECTIVE 7
T7-2: MOU elements and submission requirements
Description of MOU Sections (Cont'd)
11. FAA Enforcement
– Reports Involving Qualification Issues (E-23)
– Excluded from ASAP (E-24)
– Corrective Action (E-23)
– Repeated Instances of Noncompliance (E-21)
– Closed Reports (E-25)
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OBJECTIVE 7
T7-2: MOU elements and submission requirements
Description of MOU Sections (Cont'd)
12. Employee Feedback (E-14)
– Describes distributing ASAP information and feedback
13. Information and Training (E-14)
– Describes plan for providing information and training
14. Revision Control
– States standard revision control processes will be used
15. Recordkeeping (E-8, E-28)
– Describes ASAP record and report maintenance
16. Signatories (E-4)
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OBJECTIVE 7
T7-3: MOU acceptance, renewal, and withdrawal procedures
FAA Review of Demonstration
Programs
• Certificate Holding District Office (CHDO)
– Forwards to Flight Standards Division Regional Office
(RO) and ASAP Program Office
– Evaluates whether FAA resources are available for
effective administration
• ASAP Program Office
– Verifies whether automated MOU meets criteria or
forwards non-automated MOU for legal review
• Director of Flight Standards Service
– Authorizes MOU acceptance
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OBJECTIVE 7
T7-3: MOU acceptance, renewal, and withdrawal procedures
FAA Review of Demonstration
Program Extensions
• CHDO manager reviews the modified MOU
– If modified MOU is accepted, CHDO sends electronic
request for extension to ASAP Program Office
Manager within Voluntary Safety Program Branch
• ASAP Program Office reviews modified MOU
– If modified MOU is accepted, ASAP Program Office
authorizes extension request via electronic message to
the CHDO
• CHDO manager grants request via letter to
certificate holder
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OBJECTIVE 7
T7-3: MOU acceptance, renewal, and withdrawal procedures
Becoming a Continuing Program
• ERC gathers and analyzes data to evaluate
program effectiveness
– Number and proportion of reports within a category;
patterns in causal contributors; frequency of particular
ERC recommendations; changes in type of reports
• ERC prepares a final report
– Submits at end of Demonstration Program or 60 days
prior to end date if applying for Continuing Program
• FAA conducts an on-site program review
– Typically conducted during a regular ERC meeting
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OBJECTIVE 7
T7-3: MOU acceptance, renewal, and withdrawal procedures
FAA Review of Continuing Programs
• Certificate Holding District Office (CHDO)
– Forwards to Flight Standards Division Regional Office
(RO) and ASAP Program Office
– Evaluates whether FAA resources are available for
effective administration
• ASAP Program Office
– Verifies whether automated MOU meets criteria or
forwards non-automated MOU for legal review
• Director of Flight Standards Service
– Authorizes MOU acceptance
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OBJECTIVE 7
T7-3: MOU acceptance, renewal, and withdrawal procedures
FAA Review of Continuing Program
Renewals
• ERC initiates a renewal request every 2 years
– Evaluates whether safety objectives are being met
– Prepares final report documenting results of evaluation
– Submits renewal request and final report to CHDO at
least 60 days prior to renewal date
• CHDO Manager reviews renewal request
– Signs approvals and notifies ASAP Program Office
• FAA conducts an on-site program review
– Conducted during regular ERC meeting, when feasible
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OBJECTIVE 7
T7-3: MOU acceptance, renewal, and withdrawal procedures
MOU Revision Control Procedures
• Each revision to an MOU should include:
– Change control sheet (identifies the revision number)
located at the front of the document
– Brief summary of each change
– List of pages to be removed or replaced
– List of all pages containing a revision
– Table of contents and page numbers on each page
– Calendar date on each page of the MOU to indicate
when the MOU was prepared or revised
– A revision number on revised pages
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OBJECTIVE 7
T7-3: MOU acceptance, renewal, and withdrawal procedures
MOU Modifications and Termination
• Any modifications to the MOU must be
accepted by all signatories
• An MOU may be terminated by any party at
any time for any reason
• Failure of any ERC representative to follow
the MOU's terms may result in its termination
• Modification/termination of an MOU will not
adversely affect a submitter
– ERC will use MOU in place at time of submission
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Module A
Summary
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SUMMARY
Module A Summary
• This concludes the training materials for
"Module A: Building ASAP Foundations"
• It is hoped that you gained an understanding
of the fundamentals of ASAP via the seven (7)
learning objectives presented and that you
are ready to apply what you learned
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