Wealth of Guidance and Experience Encourage Wider Adoption of

116 Pages·2004·1.87 MB·English

by  Flight Safety Foundation

Flight Safety
D I G E S T
JUNE–JULY 2004
Wealth of Guidance
and Experience
Encourage Wider
Adoption of FOQA
Flight Safety Digest
Flight Safety Foundation
Vol. 23 No. 6–7 June–July 2004
For Everyone Concerned With the Safety of Flight
www.fl ightsafety.org
OFFICERS AND STAFF In This Issue
Chairman, Board of Governors Hon. Carl W. Vogt
President and CEO Stuart Matthews
Executive Vice President Robert H. Vandel
Treasurer James S. Waugh Jr.
Wealth of Guidance and Experience
ADMINISTRATIVE Encourage Wider Adoption of FOQA
Manager, Support Services Linda Crowley Horger
On Jan. 1, 2005, nonpunitive fl ight-data monitoring will
FINANCIAL become an international standard for operators of some
commercial transport aircraft. Air carriers that already have
Director of Finance established fl ight operational quality assurance programs have
and Administration Crystal N. Phillips 1 turned them into indispensable risk-management tools.
Accountant Millicent Wheeler
MEMBERSHIP
Director, Membership Radio Procedures Most Common Factor STATS
and Development Ann Hill in Airspace-related Occurrences in
Membership Services Australian MBZs
Coordinator Ahlam Wahdan
A study of reported airspace-related occurrences during the
PUBLICATIONS
1994–2001 period, involving regular public transport aircraft 99
Director of Publications Roger Rozelle and charter aircraft within mandatory broadcast zones (MBZs),
Senior Editor Mark Lacagnina found that the occurrence rate increased signifi cantly. The
report said, however, that the increase probably was related to an
Senior Editor Wayne Rosenkrans
improved reporting climate.
Senior Editor Linda Werfelman
Associate Editor Rick Darby
Web and Print Fatigue Management on Flight Deck
Production Coordinator Karen K. Ehrlich Y
R
Said to Depend on ‘Scientifi cally
Production Designer Ann L. Mullikin A
R Validated’ Techniques
Production Specialist Susan D. Reed B
I
Librarian, Jerry Lederer L Effective countermeasures exist for on-the-job fatigue,
Aviation Safety Library Patricia Setze
103 but their full application requires a multidisciplinary and
industrywide consensus on the nature of the problem and
TECHNICAL
its solutions. Such a consensus is emerging, but progress is
Director of Technical Programs James M. Burin slow, says Fatigue in Aviation.
Technical Programs Specialist Joanne Anderson
Managing Director of
Internal Evaluation Programs Louis A. Sorrentino III First Offi cer Retracts Flaps
S
Q-Star Program Administrator Robert Feeler Instead of Landing Gear After Takeoff F
Manager, Data Systems E
and Analysis Robert Dodd, Ph.D. The report on the incident said that the captain had called RI
Manager of Aviation for retraction of the landing gear during the Boeing 717’s B
Safety Audits Darol V. Holsman departure from an airport in Australia. Instead, the fi rst offi cer
108
moved the fl aps/slats lever.
Founder Jerome Lederer
1902–2004
Flight Safety Foundation is an international membership organization
dedicated to the continuous improvement of aviation safety. Nonprofi t
and independent, the Foundation was launched offi cially in 1947 in
response to the aviation industry’s need for a neutral clearinghouse to
disseminate objective safety information, and for a credible and knowl-
edgeable body that would identify threats to safety, analyze the problems
and recommend practical solutions to them. Since its beginning, the
Foundation has acted in the public interest to produce positive infl uence
on aviation safety. Today, the Foundation provides leadership to more
than 910 member organizations in more than 142 countries.
Cover photo composite: Copyright © Photodisc Inc.
WI DE R AD OP T ION OF FOQA
Wealth of Guidance and Experience
Encourage Wider Adoption of FOQA
On Jan. 1, 2005, nonpunitive flight-data monitoring will become an international
standard for operators of some commercial transport aircraft. Air carriers that
already have established flight operational quality assurance programs have
turned them into indispensable risk-management tools.
— FSF EDITORIAL STAFF
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ir carriers have many incentives to that “data-protection issues are so critical to the ac-
learn safety lessons from analyzing ceptance and success of FOQA that … such issues
data recorded during routine fl ight must be resolved before FAA releases an advisory
operations — not from accidents circular on FOQA.”1 Guidance documents from
— international specialists said in the context other countries — such as the U.K. Civil Aviation
of the April 2004 publication of a U.S. Federal Authority’s 2003 Civil Aviation Publication 739,
Aviation Administration (FAA) advisory circular Flight Data Monitoring — also provide informa-
(AC) about fl ight operational quality assurance tion for air carriers to consider.
(FOQA, also called fl ight-data monitoring; see
“Flight Operational Quality Assurance,” page 23). By the FSF defi nition, FOQA programs obtain
Flight Safety Foundation (FSF) had said in a 1993 and analyze data recorded in fl ight operations to
study that FOQA programs have provided one of improve fl ight crewmembers’ performance, air
the most powerful safety tools available, but also carrier training programs, operating procedures,
FLIGHT SAFETY FOUNDATION (cid:127) FLIGHT SAFETY DIGEST (cid:127) JUNE–JULY 2004 1
WI DE R AD OP T ION OF FOQA
air traffi c control (ATC) procedures, airport main- Standard,” page 3). “Nonpunitive” means that
tenance and design, and aircraft operations and information obtained from FOQA would not be
design. They typically use quick-access recorders used, for example, as the basis for an air carrier to
(QARs) to obtain data for hundreds or thousands take disciplinary action against a pilot or for a civil
of fl ight parameters, but also may use digital fl ight aviation authority to apply regulatory sanctions
data recorders (DFDRs), wireless data-transmis- against an air carrier. “Protection of data sources”
sion systems or other storage media and methods. means that data could not be disclosed publicly or
When QARs are used, fl ight data are retrieved for purposes other than aviation safety.
during routine station stops and processed by
computer software to identify, at a minimum, The Global Aviation Information Network
any deviations or exceedances from the expected (GAIN) Operator’s Flight Safety Handbook said
fl ight parameters. More sophisticated types of data in 2002 that the main objective of a FOQA pro-
analysis have evolved among the world’s most ex- gram is to improve safety by identifying trends,
perienced air carriers. not individual acts.2
Although a few U.S. air carriers had established “The purpose of a FOQA program is to detect
FOQA programs during the 1990s under an FAA latent patterns of behavior among fl ight crews,
policy providing protection from enforcement weaknesses in the ATC system and anomalies
actions based on FOQA data, the federal law on in aircraft performance which portend poten-
protection of voluntarily submitted information tial aircraft accidents,” GAIN said. “A successful
was enacted in 1996, and related U.S. Federal FOQA program encourages adherence to standard
Aviation Regulations (FARs) became effective operating procedures (SOPs), deters nonstandard
beginning in 2001. The FOQA AC provides the behavior and so enhances fl ight safety.”
most complete guidance yet for U.S. air carriers
on acceptable methods of establishing a FOQA Air carriers with FOQA programs have used fl ight
program with all of the available regulatory pro- data to identify problems such as unstabilized ap-
tections. Its publication means that they have an proaches and rushed approaches; exceedance of
unprecedented opportunity to establish FOQA fl ap limit speeds; excessive bank angles after take-
programs with less concern about issues that had off; engine over-temperature events; exceedance of
been impediments to some air carriers. recommended speed thresholds; ground-proxim-
ity warning system (GPWS)/terrain awareness and
The Foundation expects that as early as 2006, warning system (TAWS) warnings; onset of stall
FOQA might be proven to be a feasible tool conditions; excessive rates of rotation; glide path
for operators of corporate tur- excursions; and vertical acceleration.
bojet aircraft (see “Flight Plan
for Corporate FOQA: Aircraft FOQA programs worldwide can be traced to
Wanted,” page 4). pioneering work by British Airways and TAP Air
Portugal in the early 1960s and to many non-U.S.
In recent years, however, interna- airlines that shared their expertise during FSF
tional opinion has shifted toward seminars and workshops in the 1980s and 1990s.
viewing FOQA as a safety method Fully operational programs had been established
that should be mandatory rather by about 70 air carriers worldwide as of September
than voluntary. The 188 contract- 2002, and another 50 air carriers then were at vari-
ing states of the International ous stages of establishing programs, a U.K. study
Civil Aviation Organization said.3 By comparison, the 1993 FSF study had
(ICAO) have agreed that “a found approximately 25 air carriers with FOQA-
fl ight-data analysis program,” on like programs.
a nonpunitive basis with protec-
tion of data sources, will become Historically, some air carriers were deterred be-
a standard for some commercial cause they perceived FOQA as relatively expensive
transport aircraft beginning Jan. in initial capital costs of hardware and operational
1, 2005 (see “DFDR Specialists costs, to include computer software and special-
Prompt ICAO Data-monitoring ized personnel. Others cited concerns about the
2 FLIGHT SAFETY FOUNDATION (cid:127) FLIGHT SAFETY DIGEST (cid:127) JUNE–JULY 2004
WI DE R AD OP T ION OF FOQA
potential for unintended uses of fl ight data. The
Foundation’s position has been that what air car-
riers without FOQA miss is detailed knowledge of
how their aircraft are being operated — knowledge
that can prevent an accident — and capability to
compare a specifi c fl ight with a fl eet profi le to
analyze systemic aspects of fl ight operations.
DFDR Specialists Prompt
ICAO Data-analysis Standard
The idea for an ICAO standard and recom-
mended practice (SARP) for flight-data
monitoring was discussed at the ICAO Flight Data
Recorder Panel divisional meeting in November
1998 and resulted in a working paper by the ICAO
Secretariat, said Michel Béland, technical offi cer,
ICAO Operations/Airworthiness Section. ICAO “This amendment also was a compromise so as Gabriel Gregio, safety
then was asked to take steps to promote fl ight- not to impose an undue burden cost-wise on the analyst for TAM
data monitoring as part of an operator’s accident operators of smaller aircraft. Nevertheless, the Brazilian Airlines, uses
prevention and fl ight safety program.4 standard made the ‘fl ight-data analysis program’
computer software
mandatory for contracting states as of the effective
to quickly identify
Proposed Amendment 26 to the SARPs in Annex date; if states do not comply, they are required to
apparent exceedances
6, Part 1, was drafted during the ICAO Accident notify a difference to ICAO [i.e., to formally state
Investigation and Prevention divisional meeting that they do not comply with the SARP].” The of predetermined
in September 1999 and was circulated to ICAO SARP explicitly mandates that such programs be aircraft operating
contracting states. Most states supported the nonpunitive and contain safeguards to protect the parameters. (FSF Photo)
proposed amendment; the ICAO Air Navigation data sources.
Commission then recommended adoption; and
the ICAO Council adopted the amendment in Consistent with these ICAO SARPs, the European
2001, Béland said. The fi nal amendment recom- Joint Aviation Authorities in June 2004 adopted
mended effective Jan. 1, 2002, fl ight-data moni- its notice of proposed amendment (NPA), NPA
toring for aircraft with certifi cated takeoff weight OPS–35, Flight Data Monitoring, to Joint Aviation
of more than 20,000 kilograms (44,000 pounds) Requirements–Operations (JAR–OPS) 1.037,
and established a standard requiring fl ight-data Accident Prevention and Flight Safety Programme.
monitoring effective Jan. 1, 2005, for aircraft with Effective Jan. 1, 2005, the amendment mandates
certifi cated takeoff weight of more than 27,000 that fl ight-data-monitoring programs be estab-
kilograms (60,000 pounds). lished and utilized on airplanes having a maximum
certifi cated takeoff weight greater than 27,000 ki-
“This standard has been under discussion by lograms. A new advisory circular joint (AJC), AJC
the Flight Data Recorder Panel and circulating 1.037(b), Flight Data Monitoring Programme, will
since the early 1990s,” Béland said. “Essentially, provide guidance information for European air
the key driver was to have a proactive approach carriers.
to safety where operators are in a position to
identify undesirable trends and take corrective
FSF President Sees Limits
measures before an incident or accident occurs.
Affecting Voluntary FOQA
Quite a number of operators of large transport
jets already have been doing this with some
very positive results, including improved fuel For U.S. air carriers, the decision to establish
effi ciency. Those with very long experience have a FOQA program is voluntary, although FAA
said that this is the best safety program they ever approval of the FOQA program is required to
have implemented. Continued on page 6
FLIGHT SAFETY FOUNDATION (cid:127) FLIGHT SAFETY DIGEST (cid:127) JUNE–JULY 2004 3
WI DE R AD OP T ION OF FOQA
Flight Plan for Corporate FOQA: Aircraft Wanted
Flight Safety Foundation (FSF), investigations, which provide only partial mixed fleet comprising relatively few
a leading advocate of flight answers to the question of what efforts aircraft.
operational quality assurance should be initiated or supported to
(FOQA) worldwide and a catalyst in the improve safety. “Unlike an airline that can set up a
early 1990s for the establishment of air system and spread the cost over a
carrier FOQA programs in the United “Without data, efforts to reduce the large number of airplanes, typical
States,1 currently is seeking operators of accident rate represent only guesses as corporate operators with one airplane
corporate aircraft with digital data buses to how best to allocate resources,” the or two airplanes might not be able to
to participate in a one-year demonstration task force said. justify setting up a FOQA program on
program to explore the adaptation of this their own,” said Vandel.
proven safety tool for corporate aircraft Among specific recommendations was
operators. the development of a process to bring To establish a FOQA program, an operator
FOQA to corporate aviation. must develop a system that captures
As of June 8, 2004, 15 operators had digital flight data, transforms the data
expressed interest in participating in the Corporate aviation is similar to the air into an appropriate format for analysis
corporate FOQA (C-FOQA) demonstration carrier industry in having an excellent and assists in analyzing the data and
program, which will begin in January safety record. Data show, for example, generating reports. Commercial software
2005; five operators, including one in that the accident rate for U.S. corporate is available for data-processing and data-
Europe, that operate nine airplanes had aircraft (business aircraft flown by analysis, but the cost of the software likely
committed to participating. The goal is to professional pilots) in 2003 — 0.028 per would be prohibitive for many corporate
have at least 25 airplanes involved in the 100,000 flight hours — was a record flight departments. Moreover, the amount
demonstration program. low for this segment of the U.S. aviation of data and the varieties of data that would
industry.4 The accident rate for scheduled be obtained from a mixed, small fleet of
“The Foundation encourages any U.S. air carriers was 0.313 per 100,000 airplanes likely would not justify an in-
operator that has an airplane equipped flight hours. house FOQA program.
with a digital data bus and a digital flight
data acquisition unit to participate in the CAC Chairman Edward R. Williams, vice “Few individual corporate operators
demonstration program,” said Robert H. president of general aviation services and can afford to purchase the rather
Vandel, FSF executive vice president.2 director of flight operations for Global expensive software and hardware
Aerospace, said, “While air carriers required to implement a FOQA
“Many air carriers have embraced FOQA are far ahead of our community in the program,” said CAC Vice Chairman
as a means to further improve an already FOQA process, the corporate aviation Edward D. (Ted) Mendenhall, former
excellent safety record,” Vandel said. “We community operates in a very similar director of operations and chief of
are working to make this tool available to environment with equal, or in some safety at Gulfstream Aerospace.6 “One
corporate aviation operators. We believe instances slightly higher, risks. To improve of the major challenges is that for any
that there are many applications of FOQA our already enviable safety record, this individual corporate operator with a few
for corporate aviation, with the only community cannot defer any longer the airplanes, trying to run a FOQA program
limitation being our imagination.” development of this highly productive on its own just doesn’t make economic
method of revealing our own types of sense because not enough data can be
The C-FOQA program is being conducted risks in an effort to develop individual generated to provide the feedback that
by the FSF Corporate Advisory Committee risk-avoidance strategies. the operator needs.”
(CAC) with the National Business Aviation
Association (NBAA) Safety Committee. “We believe that further risk reduction for A C-FOQA operating model developed
The genesis of the program was a 1999 corporate aviation will result from data by the CAC addresses both issues
recommendation by the FSF Approach- recorded in flight, not from subjective by establishing a program that many
and-landing Accident Reduction (ALAR) responses to accidents.”5 corporate operators, in effect, can share.
Task Force for more widespread use of Basically, the operators would collect data
flight-data-monitoring programs such as There are significant differences between recorded in their airplanes and transmit
FOQA.3 corporate flight departments and air the data to a third party (i.e., a company
carriers that must be addressed in that specializes in FOQA-data processing)
The task force said that safety- adapting FOQA for corporate aviation. that would de-identify the data, aggregate
improvement efforts largely have been One obvious difference is size. A corporate the data and generate reports for the
based on the findings of accident flight department typically operates a operators.
4 FLIGHT SAFETY FOUNDATION (cid:127) FLIGHT SAFETY DIGEST (cid:127) JUNE–JULY 2004
WI DE R AD OP T ION OF FOQA
While an air carrier typically analyzes that FOQA data will not be used as the recorders (QARs), which collect FOQA
FOQA data to identify safety-related basis of punitive action against pilots data. Several manufacturers have been
trends that directly affect the carrier’s unless the data disclose willful misconduct installing DFDRs in corporate airplanes
operations, third-party analysis of or a serious violation of standard operating since the late 1990s. Installation
aggregate corporate-aviation data would procedure. of a QAR costs about US$20,000.
identify trends affecting specific aircraft Participating operators will download
types, specific phases of operation (e.g., “Since most business aviation operations FOQA data from the QARs into laptop
approach and landing), specific events do not have organized labor unions, a LOA computers.
(e.g., unstabilized approaches) and between flight department management
operations at specific airports. and pilot groups is not a viable option “Virtually any laptop computer that you
[because] human resources departments can purchase today would be adequate,”
“By using de-identified aggregate data, [likely] would not approve of a formal Mendenhall said. “The operators will be
the same value will come to a corporate agreement with an employee group where provided the software to enable them
operator that comes to an airline,” Vandel no labor union currently exists,” the CAC to transmit the data via the Internet for
said. “For example, if we get a significant committee report said. processing and analysis by the third-party
number of a specific type of corporate provider. The data will be encrypted when
airplane involved in a collective C-FOQA The C-FOQA operating model developed it is sent over the Internet.”
program, we would be able to determine by the CAC addresses this issue
how this fleet is operated for comparison by ensuring that flight department Mendenhall said that interest within the
with how a specific operator’s airplane is management normally would have access corporate aviation community recently
operated. The variance would provide only to de-identified aggregate data, which has grown.
good management information. A flight would prevent the identification of individual
department manager might say, ‘That pilots. “This is something new to us in corporate
is how I want my aircraft to be operated aviation,” he said. “Air carriers have
within our safety margins,’ or the manager The operating model is based on the conducted demonstration programs
might want to make some changes. findings of CAC working groups that for themselves before launching FOQA
C-FOQA would give the manager the explored regulatory issues and legal programs. The C-FOQA demonstration
awareness and the ability to make that issues, equipment requirements and program will show us whether this
determination.” costs, and procedures for data collection is indeed feasible and beneficial for
and analysis, as well as a visit by CAC corporate aviation.”
Vandel said that, as in air carrier operations, representatives to a major air carrier with
corporate aircraft operating costs also a FOQA program. Operators interested in participating in
could be reduced by timely identification the C-FOQA demonstration program
of problems such as improper rigging of The demonstration program will help can contact James Burin, FSF director of
flight-control surfaces, which leads to determine the feasibility of the operating technical programs, at [phone],
increased fuel costs. model. extension 106. ■
Another major issue that is being “The Foundation will function as — FSF Editorial Staff
addressed by the CAC is the protection administrator of the demonstration
of C-FOQA data from use by companies program,” said Mendenhall, who is
Notes
to punish employees. coordinating the C-FOQA effort. “The
Foundation will have a working agreement
“For FOQA to gain the acceptance of with each operator as to what equipment 1. FSF Editorial Staff et al. “Aviation
the business aviation community, it must and reports will be provided to them, as Safety: U.S. Efforts to Implement
be perceived solely as a program to well as a working agreement with the Flight Operational Quality Assurance
enhance the safety of flight operations,” third-party provider as to what data- Programs.” Flight Safety Digest
a CAC committee report said.7 “Should processing and reporting services they Volume 17 (July–September 1998).
data derived from a program be available will provide.
for use to justify punitive actions against 2. Vandel, Robert. Interview by
pilots, many of the potential benefits of “The operators also will be required to Rosenkrans, Wayne. Alexandria,
FOQA will be unattainable.” agree that they will not use the data for Virginia, U.S. June 2, 2004. Flight
punitive purposes.” Safety Foundation, Alexandria,
An air carrier typically addresses this issue Virginia, U.S.
by entering into a formal agreement with Corporate airplanes with digital data
the union that represents its pilots. A letter buses that can accommodate digital 3. FSF Editorial Staff et al. “Killers in
of agreement (LOA) signed by the air flight data recorders (DFDRs) are most Aviation: FSF Task Force Presents
carrier and by the union typically specifies suitable for installation of quick-access Facts About Approach-and-landing
FLIGHT SAFETY FOUNDATION (cid:127) FLIGHT SAFETY DIGEST (cid:127) JUNE–JULY 2004 5
WI DE R AD OP T ION OF FOQA
and Controlled-flight-into Terrain edition). Alexandria, Virginia, U.S.: Alexandria, Virginia, U.S. June 7,
Accidents.” Flight Safety Digest Flight Safety Foundation, 2004. 2004. Flight Safety Foundation,
Volume 17, Volume 18 (November– Alexandria, Virginia, U.S.
December 1998, January–February 5. Williams, Edward R. E-mail
1999). communication with Lacagnina, 7. Boyle, Matt; Stein, Peter; Sands,
Mark. Alexandria, Virginia, U.S. June Jeff. “Corporate FOQA — Legal
4. Garvey, William. “The Year in 14, 2004. Flight Safety Foundation, Considerations.” Flight Safety
Review.” In Quality Safety: Oasis Alexandria, Virginia, U.S. Foundation FOQA for Business
in the Desert: Proceedings of the Aviation Task Force Legal/
49th Annual Corporate Aviation 6. Mendenhall, Edward D. Telephone Regulatory Issues Committee
Safety Seminar (compact disc interview by Lacagnina, Mark. Report, Oct. 10, 2002.
qualify for protections provided by the will not establish voluntarily FOQA pro- examples in which errors in the aviation
FARs. Neither a regulatory framework grams,” he said. “As a result, we will not be system have been revealed as a result of
to mandate U.S. FOQA programs — nor using one of the best tools we have to get FOQA-data analysis, leading to correc-
any regulatory protections for pilots, air the best safety results. My other concern tive actions.”
carriers or FOQA data under such a is that FAA is a role model for civil avia-
framework — exist. tion authorities in many other countries,
Understanding of FOQA
so that if FAA does not mandate FOQA
Varies Among Airlines
“For air carriers worldwide, FOQA is programs, others will not mandate them.
the right thing to do,” Stuart Matthews, For airlines lacking FOQA programs,
FSF president and CEO, said in June nothing that could be improved with “We have tried over the years to
2004. “My personal viewpoint is that FOQA data would get any better, and talk with people at a number of
FAA should mandate FOQA programs none of the benefi ts to aviation safety air carriers who still do not understand
but, as the Foundation long has main- from FOQA could begin.” the benefi ts embedded within a FOQA
tained, FOQA must be allied with the program,” said Robert H. Vandel, FSF
protection of data. I do not advocate Clear guidelines also will be necessary to executive vice president. “I have not met
any change that would leave pilots and enable future “apple-to-apples” analyses people from an air carrier with a FOQA
airlines open to punitive actions as a re- of aggregate data from many air carriers program, however, who did not sing
sult of the use of the confi dential data and many nations, he said. its praises. FOQA may not identify the
that FOQA programs should provide. precursors to all types of accidents, but
Mandating FOQA programs would Air carriers that have not established it allows air carriers to defi ne and look
have to be done in such a way that U.S. FOQA programs because of liability for measurable precursors to many types
laws or regulations are changed so that concerns should reconsider whether the of accidents. FOQA data will show the
data still could not be used for punitive absence of a FOQA program could be trends — whether line operations are go-
purposes. That is very, very diffi cult to construed by society as a failure to imple- ing the way they were designed and giving
achieve in some cultures — including ment industry best practices, Matthews time to make changes that improve not
the United States — but there are prec- said. only safety but the basic operation of an
edents in countries such as Denmark. airline. This is a very powerful tool that
FOQA is one of the best tools we’ve got “My current concern is that many smaller greatly assists the industry in preventing
to improve safety.”5 air carriers still are not using FOQA— human error.”6
either in the United States or in other
A disadvantage of the voluntary basis of countries,” Matthews said. “We know Vandel said that the historical variations
FOQA in the United States has been that that all around the world, other airlines among nations in choosing to establish
relatively few air carriers have established have been using fl ight-data monitoring FOQA programs involve a variety of
FOQA programs at a time when univer- for years and have been proving its value. factors.
sal participation would enhance aviation Data published in 1996 showed that air
safety, he said. carriers that have used FOQA the longest “Air carriers have been demonstrating the
also were the safest in terms of accident benefi ts of FOQA in the United States for
“In the United States, it seems quite likely rates. FOQA programs have been prov- the better part of a decade, and it is time
that a considerable number of air carriers en to prevent accidents — with many to move forward and ensure that all air
6 FLIGHT SAFETY FOUNDATION (cid:127) FLIGHT SAFETY DIGEST (cid:127) JUNE–JULY 2004
WI DE R AD OP T ION OF FOQA
carriers establish FOQA programs,” Vandel said. willing to go to senior management and explain
“The deeper we drive this method down into the why FOQA has become so important, the benefi ts
global aviation system, the safer the system will and limitations, the fi nancial package required to
be. It’s not only the major air carriers that need implement a program and the return on invest-
FOQA programs, but the regional air carriers as ment. The solution is education. If senior man-
well. Smaller air carriers can fi nd ways around the agement understands the rationale but declines
problem that one airline might not have a suf- to pursue FOQA, so be it. The problem lies with
fi cient number of aircraft in its fl eet to identify those who decline while they only have a cursory
statistically signifi cant operational trends. They understanding of FOQA.”
should look further at how to pool their data.”
Some Specialists Avoid
Air carriers have implemented FOQA programs
Reopening Old Issues
during global economic downturns and when fuel
prices were abnormally high, Vandel said, and
sometimes have realized signifi cant cost savings Beliefs on whether FOQA should be made
as a secondary benefi t. mandatory in the United States vary among
safety specialists.
“The leadership of every airline needs to take a
fresh look at the cost of a FOQA program, which is “For most of us who have been involved in U.S.
not insignifi cant, but also should be realistic about FOQA development, now is not the time for manda-
what an accident would cost,” Vandel said. “While tory FOQA,” said Capt. Edmond L. Soliday, former
turning their fl ight data into meaningful informa- vice president, corporate safety, quality assurance
tion is when management begins to understand and security for United Airlines and member of the
FOQA. In addition to identifying when an aircraft FSF Board of Governors. “A FOQA program reveals
is being operated incorrectly, the FOQA program what happened, but only pilots can say what they
also can tell the air carrier when aircraft are being were thinking when it happened. Without the pro-
operated properly but under policies and proce- tections currently available, we would slow down
dures that are not optimal. Our recommendation FOQA progress. Instead of a free fl ow of safety in-
is that air carriers establish fi rst a FOQA program formation from pilots who have no threat of puni-
that is fairly basic, such as by selecting one modern tive action, pilots would be thinking ‘everything I do
fl eet of aircraft, analyze fl ight data from that fl eet is recorded’ and their cooperation would be affected
and later expand the FOQA program.” by renewed concern that they might be punished
unfairly by people who do not understand the data.
Some FOQA opportunities — such as sharing de- Then a pilot begins to ‘manage the disc’ instead of
identifi ed trend information and aggregate data managing the fl ight.”7
among air carriers — involve complex issues.
Protection of FOQA data from
“A compelling argument can be made for this uses other than aviation safety
type of sharing among air carriers — but not for has been addressed by FARs
sharing fl ight-specifi c data or airline-specifi c data,” applicable only to voluntary
he said. “I doubt that any airline would have a programs, he said. Therefore,
problem freely sharing, at a negotiable level, high- mandating FOQA programs in
level information about its FOQA program — the the United States would involve
operational benefi ts and lessons. reopening regulatory issues that
already have been resolved.
“Some industry specialists believe that FAA’s
FOQA AC is right on target in telling air carriers “If FOQA programs were
not to underestimate the level of detail involved mandated in the United States,
in establishing a FOQA program. The biggest close behind would come FAA
impediment to more U.S. air carriers establish- enforcement that would mean
ing FOQA programs is failure of management to mandatory release of fl ight data
truly understand what FOQA can do for them. by the airline to the govern-
This may require a company champion who is ment,” Soliday said. “Without
FLIGHT SAFETY FOUNDATION (cid:127) FLIGHT SAFETY DIGEST (cid:127) JUNE–JULY 2004 7
WI DE R AD OP T ION OF FOQA
protections, the government then These documents include FARs Part 13, Flight
has an obligation to use FOQA Operational Quality Assurance Program; Final Rule,
data for enforcement, and the effective Nov. 30, 2001; FARs Part 193, Protection
data also may be released for un- of Voluntarily Submitted Information; FAA Order
intended uses. The only way to 8000.81, Flight Operational Quality Assurance
protect FOQA data is to ensure Program (FOQA), designating FOQA informa-
that the airline always ‘owns’ the tion as protected from public disclosure effective
data.” April 14, 2003; and FAA orders that created and
then extended until Oct. 29, 2005, the term of the
Another concern is that without FOQA Aviation Rulemaking Committee (ARC),
protections, attorneys for plain- which has assisted FAA in providing guidance
tiffs in civil lawsuits may use material on acceptable methods of compliance
the discovery process to obtain with the FARs.
FOQA data from air carriers. In
contrast, attorneys for air carri- Two of the FARs have been infl uential in the de-
ers currently can infl uence court decisions about velopment of FOQA programs by U.S. air carriers,
release of data owned by air carriers, he said. typically in a partnership with FAA. Part 13.401,
“Flight Operational Quality Assurance Program:
“If FAA were to obtain FOQA data in the future, Prohibition Against Use of Data for Enforcement
however, there would be no airline control in nar- Purposes,” codifi ed the enforcement protection
rowing the request for production of data in the available.
discovery process,” Soliday said.
The regulation, among other provisions, says,
Some industry specialists want to preserve the “Except for criminal or deliberate acts, the [FAA]
voluntary basis of U.S. FOQA programs for administrator will not use an operator’s FOQA
pragmatic reasons — chiefl y because they are data or aggregate FOQA data in an enforcement
concerned that the rule-making process might action against that operator or its employees when
consume another fi ve years to 10 years to effect such FOQA data or aggregate FOQA data is ob-
major changes, he said. tained from a FOQA program that is approved
by the administrator.” FAA does not mandate ap-
“Pragmatists worry that a major change would proval of an air carrier’s FOQA program, except
bring to a halt current FOQA programs until air to be covered by this prohibition against use of
carriers see what the new rule is going to say,” data for enforcement purposes.
Soliday said. “Mandating FOQA is the last alter-
native. It took me fi ve years to convince United Part 193 says that certain safety information and
Airlines to establish its current FOQA program. security information submitted to FAA on a vol-
Any mandated program might have to be based untary basis will not be disclosed under statutory
only on exceedance data from individual fl ights, provisions intended to encourage aircraft opera-
for example, although major air carriers now can tors to provide information that will assist FAA in
look at trends from 40,000 fl ights at a time. At the conducting its safety duties and security duties.
current state of technology, the price of establish- Part 13.401 says, “FOQA data and aggregate FOQA
ing a FOQA program for an airline with 20 air- data, if submitted in accordance with an order
planes is very steep, but we could create consortia designating the information as protected under
to deal with the cost, for example.” [FARs Part 193], will be afforded the nondisclosure
protections of [Part 193].”
Laws, Regulations Provide
Basis of Data Protection FOQA Advisory Circular
Captures Latest Methods
Since 2001, the U.S. government has addressed
nonpunitive issues and data-protection issues The FOQA AC incorporates lessons from the
with three regulations, guidance to FAA’s aviation FOQA Demonstration Project of the mid-
safety inspectors and the FOQA AC. 1990s, knowledge gained by FAA since 1996 from
8 FLIGHT SAFETY FOUNDATION (cid:127) FLIGHT SAFETY DIGEST (cid:127) JUNE–JULY 2004