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Testimony of Terry Clark
Director of Flight Safety
Alaska Airlines
before the
National Civil Aviaition Review Commission

Gentlemen and Ladies,

I am Terry Clark, Director of Flight Safety for Alaska Airlines.

My testimony to this commission today deals with improving the airline industry's performance in the area of flight safety.

Various people who work within the airline industry and government are quick to point out how we have the best safety record of any industry in the world. They comment on how we set the standard and most everyone else looks to us as industry leaders.

This may or may not be a factual statement. Every flight safety expert I know, who is genuinely interested in flight safety, find these remarks irrelevant. They mean nothing, except to those who wish to pound their chest and point to themselves in an attempt to gain recognition.

The only concept which is meaningful to an individual who dedicates his or her life to flight safety is the concept of continual improvement. In other words, " We will be better tomorrow than we are today."

Continual improvement only comes from self auditing and constant evaluation of an operation. We must determine how we are doing in order to plot a course for improvement.

So how can we do this within the airline industry? Let's come back to that question.

Unfortunately, in the not too distant future an airliner will crash. There will be an investigation which will gather as many of the facts leading up to the accident as possible. Considerable effort will be expended to recover the "Black Boxes". These boxes are called the cockpit voice recorder and flight data recorder.

The questions that beg to be asked by a flight safety expert is, "Why do we only look for these black boxes when there is an accident"? Flight data recorder information would be of great value.

The cockpit voice recorder is of limited value to an analyst looking for latent problems. It only records the last 30 minutes of the flight. The flight data recorder, however, records flight parameters for a much greater time period. Normally around 75 hours. It is possible to install equipment onboard an aircraft to record up to 300 hours of data.

At the present time, are any air carriers within the United States evaluating flight data recorder information? The answer to that question is yes. Alaska Airlines, United, US Airways and Continental are doing just that. We call it Flight Operations and Quality Assurance. Better known as FOQA.

What are we learning? We are learning how "G" loading on our aircraft affects aircraft aging, how good a job our training department is doing, how our aircraft fit into the air traffic control system, what we can expect the wind profiles to be on different departures and approaches and of course reliability of various mechanical systems and parts on our aircraft just to give a few examples.

What FOQA is proving to be is absolutely the finest tool for a flight safety analyst that has ever been produced.

The European community has known this for over three decades. Why has the United States not had this tool before now?

The answer to this is simple. The FAA's enforcement policy, in the past, looks to fix blame, not fix problems. In my own airline, I can give several examples of this.

So why are air carriers considering FOQA now? Former FAA Administrator, David Henson, published a policy letter allowing for an opportunity to work together as industry and regulatory bodies by providing protections for the airlines and it employees.

The former administrators letter allowed airlines to collect data and use it strictly for self auditing and evaluation. It set reasonable guidelines for FAA inspectors to follow concerning this data.

David Henson's policy was a good start, however, for this vital safety program to be successful, we need better guidance than a policy letter.

The FAA is currently on the verge of producing a notice of proposed rule making concerning FOQA. I urge this commission to guide the FAA with the basic truth that by working together we can accomplish more than we can by working separately.

The FOQA rule must allow airlines to voluntarily participate in a FOQA program wherein the airlines and the FAA work in harmony rather than hesitantly participate based on fear of retribution by the FAA's use of the program as one solely to collect data which can be used to penalize an airline or one of it's employees.

It must provide protections from the media similar to the protections afforded to airport security issues dealing with entities that wish to do harm to the flying public.

It must also have the same protections that are currently in place for the cockpit voice recorder.

Without these protections, any initiative which deals with FOQA will fail, or worse yet, be a meaningless program which will ruefully be remembered as a great idea, but because of the FAA's commitment to enforcement outweighed it's commitment to flight safety and the willingness to work with the airline industry to save lives, it just could not come to pass.

Thank you.