Strengthening Voluntary Safety Reporting Programs
Voluntary safety reporting programs such as the Aviation Safety Action Program (ASAP) and the Flight Operations Quality Assurance (FOQA) are important, collaborative tools that enhance aviation safety through the analysis of voluntarily reported safety events and discrepancies that lead to the prevention of accidents and incidents. The purpose of ASAP and FOQA is to encourage and use voluntarily reported safety information provided by frontline employees and airlines, respectively, to identify safety risks. Without these valuable safety reports, unidentified risks go unmitigated and remain within the system.
For example, more than a decade ago the implementation of stabilized approach technology and procedures became a top safety priority upon discovering the frequency of nonstabilized approaches being reported by pilots. More recently, data sources have been combined to identify potential risks that are initially identified through the voluntary safety programs. Ground radar data, historical weather information, and other data sources were used to identify instances when aircraft traffic and terrain warning systems were repeatedly alerting to false alarms. The safety programs triggered these studies, which ultimately led to the discovery that improvements to airspace and procedures design would reduce the false alarms. These examples prove that the underlying safety program reporting by the operators is the best source to identify potential risk areas to investigate and ultimately mitigate.
We can improve and increase the safety benefit of ASAP and voluntarily submitted aviation safety information by automatic acceptance of ASAP reports. Several ASAPs already have automatic acceptance protocols built in (at American and Delta Air Lines, for example). However, where ASAP reports are not automatically accepted, the safety benefit is delayed, sometimes by weeks or longer, waiting for an Event Review Committee (ERC) to meet and review the reports. Under an automatic-acceptance scenario, the safety benefit of the information would be realized immediately. However, a report could be excluded when the ERC convenes and it is determined to meet established exclusionary criteria. The automatic acceptance model works and should be universal to ASAP.
FOIA Protection for Security ASAP Reports Submitted to TSA
While these safety reporting programs have proven to be a significant benefit to the improved safety of our industry, we do not yet have similar programs in place for “frontline” employees to confidentially report security-related events and incident encounters. Airline pilots and other frontline aviation employees are well suited to serve as the “eyes and ears” of the industry. They know their workplace very well, will recognize something that is out of place or suspicious because of their intimate knowledge of the aviation domain, and want to help make aviation more secure. Developing and implementing a security-focused enhancement to ASAP would provide TSA and FAA with near real-time data that could be used to identify security risks to our aviation system and enhancements to mitigate those risks.
One of the impediments to developing and implementing confidential reporting programs for security is the lack of protections from Freedom of Information Act (FOIA) disclosure by TSA of voluntarily submitted information. For FAA safety ASAP reports, the confidential data submitted is exempted from FOIA disclosure per legislation in the Federal Aviation Reauthorization Act of 1996 (P.L. 104-264). That exemption should be extended to TSA for confidential security-reporting programs.
- ASAP reports should be automatically accepted into the program, allowing reports that do not meet the criteria to be excluded after review, if necessary.
- Congress should expand the FOIA exemption already in force for ASAP reports submitted to the FAA per the Federal Aviation Reauthorization Act of 1996 (P.L. 104-264) to security-related reports submitted to the TSA.
- TSA, in collaboration with the FAA and industry partners, should expand the use of the ASAP reporting process—along with its enforcement protections for the reporting employee—to specifically include security-related information from frontline employees.