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Federal Aviation Administration Aviation Safety Action Programs Training Module A: Building ASAP Foundations Version Date: 30 April 2012.

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Presentation on theme: "Federal Aviation Administration Aviation Safety Action Programs Training Module A: Building ASAP Foundations Version Date: 30 April 2012."— Presentation transcript:

1 Federal Aviation Administration Aviation Safety Action Programs Training Module A: Building ASAP Foundations Version Date: 30 April 2012

2 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April Outline for Objective 1 Locate/use ASAP guidance materials and supporting resources related to program development and management Topics (T) and Activities (A): T1-1Purpose of ASAP T1-2Benefits of ASAP to stakeholders T1-3Participation criteria T1-4History of ASAP T1-5ASAP guidance materials and supporting resources T1-6Contents and role of ASAP Advisory Circular 120–66B T1-7Elements and role of an ASAP MOU T1-8 Contents and role of the ASAP Report Process Chart T1-9Contents and role of ASAP section of FAA Order T1-10Contents and role of EDP section of FAA Order T1-11Contents and role of 14 CFR Part 193 and FAA Order T1-12Practical guidance and lessons learned T1-13Safety Management System (SMS) A1-14Practice applying ASAP guidance and procedures to start-up OVERVIEW OBJECTIVE 1 OBJECTIVE 2 OBJECTIVE 3 OBJECTIVE 4 OBJECTIVE 5 OBJECTIVE 6 OBJECTIVE 7

3 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April About Objective 1 Locate/use ASAP guidance materials and supporting resources related to program development and management OBJECTIVE 1

4 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T1-1: Purpose of ASAPOBJECTIVE 1

5 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T1-1: Purpose of ASAPOBJECTIVE 1

6 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T1-1: Purpose of ASAPOBJECTIVE 1

7 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April Benefits to Stakeholders All stakeholders realize benefits from ASAP: ASAP Managers ERC members Respective organizations –Certificate holders T1-2: Benefits of ASAP to stakeholdersOBJECTIVE 1

8 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T1-2: Benefits of ASAP to stakeholdersOBJECTIVE 1

9 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T1-2: Benefits of ASAP to stakeholdersOBJECTIVE 1

10 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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.pdfhttp://www.faa.gov/about/initiatives/asap/media/asap_ participants.pdf T1-3: Participation criteriaOBJECTIVE 1

11 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T1-4: History of ASAPOBJECTIVE 1

12 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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) T1-4: History of ASAPOBJECTIVE 1

13 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T1-4: History of ASAPOBJECTIVE 1

14 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T1-4: History of ASAPOBJECTIVE 1

15 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T1-4: History of ASAPOBJECTIVE 1

16 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April Differences Between ASAP and VDRP ASAP and VDRP are two voluntary safety programs that involve self-reporting of safety- related events. There are several distinct characteristics of each, which are described in the table on the following page T1-4: History of ASAPOBJECTIVE 1

17 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T1-4: History of ASAPOBJECTIVE 1

18 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 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 T1-5: ASAP guidance materials and supporting resourcesOBJECTIVE 1

19 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April ASAP Guidance Materials and Supporting Resources (Cont'd) Supporting Resources –FAA Order 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 Specifies ASAP information is protected from public disclosure and provides the rationale for its protection T1-5: ASAP guidance materials and supporting resourcesOBJECTIVE 1

20 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T1-5: ASAP guidance materials and supporting resourcesOBJECTIVE 1

21 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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) T1-6: Contents and role of ASAP Advisory Circular 120–66BOBJECTIVE 1

22 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T1-6: Contents and role of ASAP Advisory Circular 120–66BOBJECTIVE 1

23 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T1-6: Contents and role of ASAP Advisory Circular 120–66BOBJECTIVE 1

24 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T1-6: Contents and role of ASAP Advisory Circular 120–66BOBJECTIVE 1

25 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T1-6: Contents and role of ASAP Advisory Circular 120–66BOBJECTIVE 1

26 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T1-6: Contents and role of ASAP Advisory Circular 120–66BOBJECTIVE 1

27 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T1-6: Contents and role of ASAP Advisory Circular 120–66BOBJECTIVE 1

28 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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) T1-6: Contents and role of ASAP Advisory Circular 120–66BOBJECTIVE 1

29 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T1-6: Contents and role of ASAP Advisory Circular 120–66BOBJECTIVE 1

30 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T1-6: Contents and role of ASAP Advisory Circular 120–66BOBJECTIVE 1

31 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T1-6: Contents and role of ASAP Advisory Circular 120–66BOBJECTIVE 1

32 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T1-6: Contents and role of ASAP Advisory Circular 120–66BOBJECTIVE 1

33 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T1-6: Contents and role of ASAP Advisory Circular 120–66BOBJECTIVE 1

34 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T1-6: Contents and role of ASAP Advisory Circular 120–66BOBJECTIVE 1

35 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 –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 T1-7: Elements and role of an ASAP MOUOBJECTIVE 1

36 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T1-7: Elements and role of an ASAP MOUOBJECTIVE 1

37 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April ASAP Report Process Chart T1-8: Contents and role of the ASAP Report Process ChartOBJECTIVE 1

38 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April Order –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 –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) T1-9: Contents and role of ASAP section of FAA Order OBJECTIVE 1

39 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April Order –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 T1-9: Contents and role of ASAP section of FAA Order OBJECTIVE 1

40 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April Order –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 T1-10: Contents and role of EDP section of FAA Order OBJECTIVE 1

41 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April ASAP's Use of Order –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 T1-10: Contents and role of EDP section of FAA Order OBJECTIVE 1

42 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April CFR Part 193 and Order Title 49 of USC –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 –FAA order specifying that ASAP information is protected from public disclosure and why it is important to protect such information from disclosure T1-11: Contents and role of 14 CFR Part 193 and FAA Order OBJECTIVE 1

43 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T1-11: Contents and role of 14 CFR Part 193 and FAA Order OBJECTIVE 1

44 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T1-12: Practical guidance and lessons learnedOBJECTIVE 1

45 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T1-13: Safety Management System (SMS)OBJECTIVE 1

46 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April Identify Resources Specifying ASAP Guidance and Procedures Detailed information about this activity can be found in the Student Guide for Module A on pages A1-14: Practice applying ASAP guidance and procedures to start-upOBJECTIVE 1

47 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April Outline for Objective 2 Explain the importance of and strategies for integrating ASAP into each party's safety culture Topics (T) and Activities (A): T2-1Importance of and strategies for integration T2-2Importance of and strategies for building professional relationships T2-3Importance of and strategies for gaining buy-in for ASAP A2-4Practice identifying strategies for ASAP integration and acceptance OVERVIEW OBJECTIVE 2 OBJECTIVE 1 OBJECTIVE 3 OBJECTIVE 4 OBJECTIVE 5 OBJECTIVE 6 OBJECTIVE 7

48 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April About Objective 2 Explain the importance of and strategies for integrating ASAP into each party's safety culture OBJECTIVE 2

49 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T2-1: Importance of and strategies for integrationOBJECTIVE 2

50 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T2-1: Importance of and strategies for integrationOBJECTIVE 2

51 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T2-1: Importance of and strategies for integrationOBJECTIVE 2

52 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T2-1: Importance of and strategies for integrationOBJECTIVE 2

53 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T2-1: Importance of and strategies for integrationOBJECTIVE 2

54 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T2-2: Importance of and strategies for building professional relationshipsOBJECTIVE 2

55 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T2-2: Importance of and strategies for building professional relationshipsOBJECTIVE 2

56 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T2-2: Importance of and strategies for building professional relationshipsOBJECTIVE 2

57 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T2-3: Importance of and strategies for gaining buy-in for ASAPOBJECTIVE 2

58 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T2-3: Importance of and strategies for gaining buy-in for ASAPOBJECTIVE 2

59 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April Identify Strategies for ASAP Integration and Acceptance Detailed information about this activity can be found in the Student Guide for Module A on pages A2-4: Practice identifying strategies for ASAP integration and acceptanceOBJECTIVE 2

60 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April Outline for Objective 3 Obtain required resources to ensure ASAP success Topics (T) and Activities (A): T3-1Resources required for ASAP success A3-2Practice identifying the resources required for ASAP success OVERVIEW OBJECTIVE 1 OBJECTIVE 2 OBJECTIVE 3 OBJECTIVE 4 OBJECTIVE 5 OBJECTIVE 6 OBJECTIVE 7

61 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April About Objective 3 Obtain required resources to ensure ASAP success OBJECTIVE 3

62 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T3-1: Resources required for ASAP successOBJECTIVE 3

63 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T3-1: Resources required for ASAP successOBJECTIVE 3

64 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T3-1: Resources required for ASAP successOBJECTIVE 3

65 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T3-1: Resources required for ASAP successOBJECTIVE 3

66 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April Estimate the Resources Required for ASAP Success Detailed information about this activity can be found in the Student Guide for Module A on pages A3-2: Practice identifying the resources required for ASAP successOBJECTIVE 3

67 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April Outline for Objective 4 Identify and obtain the best qualified individuals to serve in key ASAP support roles Topics (T) and Activities (A): T4-1Roles and responsibilities of ERC members T4-2Roles and responsibilities of other key ASAP support staff T4-3Qualities needed to support key ASAP roles and responsibilities T4-4Other considerations for selection of individuals for key ASAP roles A4-5Practice identifying qualities needed of ERC members OVERVIEW OBJECTIVE 1 OBJECTIVE 2 OBJECTIVE 3 OBJECTIVE 5 OBJECTIVE 6 OBJECTIVE 7 OBJECTIVE 4

68 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April About Objective 4 Identify and obtain the best qualified individuals to serve in key ASAP support roles OBJECTIVE 4

69 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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) T4-1: Roles and responsibilities of ERC membersOBJECTIVE 4

70 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T4-1: Roles and responsibilities of ERC membersOBJECTIVE 4

71 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T4-2: Roles and responsibilities of other key ASAP support staffOBJECTIVE 4

72 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T4-2: Roles and responsibilities of other key ASAP support staffOBJECTIVE 4

73 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T4-2: Roles and responsibilities of other key ASAP support staffOBJECTIVE 4

74 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T4-2: Roles and responsibilities of other key ASAP support staffOBJECTIVE 4

75 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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) T4-2: Roles and responsibilities of other key ASAP support staffOBJECTIVE 4

76 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T4-3: Qualities needed to support key ASAP roles and responsibilitiesOBJECTIVE 4

77 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T4-3: Qualities needed to support key ASAP roles and responsibilitiesOBJECTIVE 4

78 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T4-3: Qualities needed to support key ASAP roles and responsibilitiesOBJECTIVE 4

79 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T4-3: Qualities needed to support key ASAP roles and responsibilitiesOBJECTIVE 4

80 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T4-3: Qualities needed to support key ASAP roles and responsibilitiesOBJECTIVE 4

81 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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? T4-4: Other considerations for selection of individuals for key ASAP rolesOBJECTIVE 4

82 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April Identify Individuals to Serve on ERC Detailed information about this activity can be found in the Student Guide for Module A on pages A4-5: Practice identifying qualities needed of ERC membersOBJECTIVE 4

83 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April Outline for Objective 5 Select or develop a data management system Topics (T) and Activities (A): T5-1Desirable features of a data management system T5-2Data to collect and track in the data management system T5-3Guidance for event type and causal contributor taxonomies T5-4Guidance regarding ASAP recordkeeping requirements OVERVIEW OBJECTIVE 1 OBJECTIVE 2 OBJECTIVE 3 OBJECTIVE 4 OBJECTIVE 6 OBJECTIVE 7 OBJECTIVE 5

84 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April About Objective 5 Select or develop a data management system OBJECTIVE 5

85 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 and attachment capabilities Includes user-friendly data analysis tools T5-1: Desirable features of a data management systemOBJECTIVE 5

86 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T5-2: Data to collect and track in the data management systemOBJECTIVE 5

87 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T5-2: Data to collect and track in the data management systemOBJECTIVE 5

88 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T5-2: Data to collect and track in the data management systemOBJECTIVE 5

89 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T5-3: Guidance for event type and causal contributor taxonomiesOBJECTIVE 5

90 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T5-3: Guidance for event type and causal contributor taxonomiesOBJECTIVE 5

91 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T5-3: Guidance for event type and causal contributor taxonomiesOBJECTIVE 5

92 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April Use of Event Type/Causal Contributor Taxonomies (Cont'd) ERC discusses and records any sub- categories 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 T5-3: Guidance for event type and causal contributor taxonomiesOBJECTIVE 5

93 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T5-4: Guidance regarding ASAP recordkeeping requirementsOBJECTIVE 5

94 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April Identify and explain supportive internal policies and procedures needed to ensure ASAP success Topics (T) and Activities (A): T6-1Potential challenges for ASAP start-up T6-2Internal policies and procedures to establish at start-up T6-3Existing certificate holder policies or agreements to consider T6-4Documentation of internal policies and procedures A6-5Practice identifying the need for internal policies and procedures OVERVIEW OBJECTIVE 1 OBJECTIVE 2 OBJECTIVE 3 OBJECTIVE 4 OBJECTIVE 5 OBJECTIVE 6 OBJECTIVE 7 Outline for Objective 6

95 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April About Objective 6 Identify and explain supportive internal policies and procedures needed to ensure ASAP success OBJECTIVE 6

96 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T6-1: Potential challenges for ASAP start-upOBJECTIVE 6

97 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T6-2: Internal policies and procedures to establish at start-upOBJECTIVE 6

98 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T6-2: Internal policies and procedures to establish at start-upOBJECTIVE 6

99 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T6-2: Internal policies and procedures to establish at start-upOBJECTIVE 6

100 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T6-2: Internal policies and procedures to establish at start-upOBJECTIVE 6

101 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T6-2: Internal policies and procedures to establish at start-upOBJECTIVE 6

102 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 –ASAP T6-2: Internal policies and procedures to establish at start-upOBJECTIVE 6

103 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T6-2: Internal policies and procedures to establish at start-upOBJECTIVE 6

104 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T6-2: Internal policies and procedures to establish at start-upOBJECTIVE 6

105 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 s may be possible with an electronic data collection and dissemination tool T6-2: Internal policies and procedures to establish at start-upOBJECTIVE 6

106 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T6-2: Internal policies and procedures to establish at start-upOBJECTIVE 6

107 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T6-2: Internal policies and procedures to establish at start-upOBJECTIVE 6

108 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T6-2: Internal policies and procedures to establish at start-upOBJECTIVE 6

109 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T6-2: Internal policies and procedures to establish at start-upOBJECTIVE 6

110 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T6-3: Existing certificate holder policies or agreements to considerOBJECTIVE 6

111 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T6-4: Documentation of internal policies and proceduresOBJECTIVE 6

112 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 A6-5: Practice identifying the need for internal policies and proceduresOBJECTIVE 6

113 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April Outline for Objective 7 Develop and submit an ASAP Memorandum of Understanding (MOU) Topics (T) and Activities (A): T7-1MOU development and its role in ASAP T7-2MOU elements and submission requirements T7-3MOU acceptance, renewal, and withdrawal procedures OVERVIEW OBJECTIVE 1 OBJECTIVE 2 OBJECTIVE 3 OBJECTIVE 4 OBJECTIVE 5 OBJECTIVE 6 OBJECTIVE 7

114 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April About Objective 7 Develop and submit an ASAP Memorandum of Understanding (MOU) OBJECTIVE 7

115 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T7-1: MOU development and its role in ASAPOBJECTIVE 7

116 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T7-1: MOU development and its role in ASAPOBJECTIVE 7

117 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T7-1: MOU development and its role in ASAPOBJECTIVE 7

118 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T7-1: MOU development and its role in ASAPOBJECTIVE 7

119 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T7-2: MOU elements and submission requirementsOBJECTIVE 7

120 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T7-2: MOU elements and submission requirementsOBJECTIVE 7

121 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T7-2: MOU elements and submission requirementsOBJECTIVE 7

122 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T7-2: MOU elements and submission requirementsOBJECTIVE 7

123 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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) T7-2: MOU elements and submission requirementsOBJECTIVE 7

124 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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) T7-2: MOU elements and submission requirementsOBJECTIVE 7

125 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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) T7-2: MOU elements and submission requirementsOBJECTIVE 7

126 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T7-3: MOU acceptance, renewal, and withdrawal proceduresOBJECTIVE 7

127 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T7-3: MOU acceptance, renewal, and withdrawal proceduresOBJECTIVE 7

128 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T7-3: MOU acceptance, renewal, and withdrawal proceduresOBJECTIVE 7

129 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T7-3: MOU acceptance, renewal, and withdrawal proceduresOBJECTIVE 7

130 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T7-3: MOU acceptance, renewal, and withdrawal proceduresOBJECTIVE 7

131 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T7-3: MOU acceptance, renewal, and withdrawal proceduresOBJECTIVE 7

132 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 T7-3: MOU acceptance, renewal, and withdrawal proceduresOBJECTIVE 7

133 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April Module A Summary

134 Federal Aviation Administration Module A: Building ASAP Foundations Version Date: 30 April 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 SUMMARY


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