House Aviation Hearing Focuses on Safety Management

The House of Representatives held a hearing this week on aviation safety issues; a significant focus of this hearing was on Safety Management Systems (SMS).  Both the private sector and the FAA testified about the importance of SMS.

FAA Associate Administrator Peggy Gilligan testified about the FAA’s progress on Safety Management Systems (SMS) implementation.  Congress passed a law requiring the FAA to implement SMS rules for air carriers.  Gilligan explained that the FAA has met its statutory deadlines for proposed SMS rule and that they are on track to be able to use SMS as a holistic tool that will allow industry and the FAA to spot safety trends, and to use these trends to be able to identify potential safety issues and correct them before they can lead to an accident or incident.

Tom Hendricks, the Vice President for Safety, Security and Operations at Airlines for America (formerly the Air Transport Association) agreed about the importance of the data-driven culture that SMS formalizes.  He expressed that data driven analysis of SMS “yields a high definition picture” that permits more refined risk assessments.  He explained that air carriers have been using data-based programs to identify emerging patterns and promptly deploy focused resources; by proactively initiating change in response to data, rather than reacting to accidents, air carriers have been able to take a disciplined approach that has significantly advanced safety.

Data is at the heart of SMS, and the most effective way to handle SMS is through data sharing, which permits air carriers to have a larger pool of data from which to draw safety conclusions.  Scott Foose, the Senior Vice President of Operations and Safety at the Regional Airline Association (RAA) testified before Congress about RAA’s efforts to support data sharing.

“When it comes to sharing of safety information, regardless of the size of the fleet or the name on the aircraft, our goal is that all airlines will work together as a team, which will improve safety overall for the industry and most importantly, for our employees and passengers.”

To this end, RAA members have been participating in several data sharing programs that allow individual air carriers to have a much richer data set on which to rely in order to identify trends that can foreshadow safety issues.

While data is an important driver for SMS, it also creates the potential for the data to be misused.  At the opening meeting of the FAA’s SMS Aviation Rulemaking Committee (ARC), we raised this important issue and the final report from the SMS ARC included draft legislation that we had prepared that would protect SMS data from being disclosed to anyone that might use it for purposes other than safety.  The reason that this data protection is important is because if the data can be used for other purposes, like litigation, or embarrassing companies in the press, then this will tend to have a chilling effect on honest reporting.  If the data is not reported honestly (even when honesty is unpopular or embarrassing), then it may not serve its safety purpose.

The subject of data protection was a major part of the testimony of Sean Cassidy, the First Vice President of the Air Line Pilots Association:

“Processes in place to protect the data gathered through various [means] need to be strengthened and expanded to provide proper protection for the data, both within and outside an organization.  Legislation should be considered to further strengthen the protection of this vital source of safety information against misuse.”

Data protection is not the only challenge facing FAA and industry in establishing SMS programs for air carriers.  Gerald Dillingham of the Government Accountability Office (GAO) testified before Congress about the data challenges facing the FAA in developing the system necessary to support SMS.  These include:

  • Changes to reporting policies that could result in changes to data that reflect changes in reporting trends rather than actual changes in the safety issues that are represented by the data
  • Incomplete data at make it difficult to account for all appropriate risks
  • Lack of coordination among data systems that makes it difficult to correlate data
  • Data reliability question, and
  • Lack of data on certain types of incidents

Dillingham applauded the FAA for its efforts, but expressed that more work needs to be done to address the challenges that his organization has identified.

Similar shortcomings were identified in the testimony of Jeffrey Guzzetti, the Assistant Inspector General for Aviation and Special Programs from the Department of Transportation’s Office of the Inspector General.  Guzzetti explained that the FAA has had problems collecting data, and optimally using the data that it does collect.  For example, he notes:

“FAA has not finalized the process to effectively communicate [Air Traffic Safety Action Program] ATSAP data to facility managers so that safety improvements can be made at the facility level. FAA has also not effectively communicated and implemented changes to performance management under ATSAP, including assignment of skill enhancement training to controllers. Improvements in these areas would enhance the Agency’s ability to identify and address risks through the use of ATSAP.”

One of the areas that Guzzetti focused on was better use of data for oversight of repair stations.  He explained that some FAA employees are simply not using the risk-based tools that headquarters has been providing, and others are going through the motions of using them but they seem to be ignoring the results.  He concluded that “to address root causes of safety problems and fully measure their impact, FAA needs to fine-tune its approach to how it collects, verifies, and uses safety data.”

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About Jason Dickstein
Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Aircraft Fleet Recycling Association and the Modification and Replacement Parts Association.

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