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OUTLINE OF COMMENTS BEFORE
NATIONAL CIVIL AVIATION REVIEW COMMISSION
presented by Captain David Haase, Executive Central Air Safety Chairman
SAFETY PROGRAM MANAGEMENT

• The concept of safety management and quality assurance is basic and fundamental, yet many operators do not have such programs
• There is a need for formal programs to assess risk and institute mitigation measures.
• These programs allow an operator to determine what is actually happening in "real" world by using:
• Data Collection
• Information Sharing Exchange
• Within the program, a comparison of actual performance to established standards can then be conducted
• If desired performance is not up to specification
• recommendations to address deficiencies are identified and instituted
• performance is monitored to determine if the corrective action was successful
• These programs are essential to all operations functions within a carrier, but particularly for flight operations and aircraft maintenance/overhaul

• Data collection tools include the following:
• Partnership programs allowing for voluntary disclosure of safety related events.
• FOQA ( to extent resources allow)
• Internal Audit Programs for the carrier and its code sharing partners
• These pro-active programs require a defined management structure to function effectively
• The FAR’s require "Director of Safety" Position
• The responsibilities of that position are not yet defined by the FAA
• Data collection and overall program safety program management should be responsibility of a "Director of Safety"

FAA 90 DAY SAFETY REVIEW
The Focus of this Review was FAA Surveillance and Oversight

• The overall purpose was to determine how the FAA could improve its Surveillance and Oversight of:
• Flight Operations
• Maintenance
• The concern was how the FAA could make improvements to its oversight programs considering
• FAA Resource Limitations
• Budget Limitations

• The report indicated that aviation safety oversight requires better management of programs
• Data collection is needed to allow analysis
• Effective data collection requires not only FAA resources but also outside resources
• Analysis of the data will provide FAA with information to allow them to deploy resources where they are most needed

• Use of Shared Programs that would allow FAA to modify direct oversight for better effectiveness by:
• Reducing direct oversight at well established carriers with FAA approved internal Quality Assurance Programs
• Increasing direct oversight and spending more time at newer or weaker carriers
• Implementation of internal carrier operated safety/quality assurance programs should include:
• FOQA Programs
• Partnership Programs
• Internal Audit

FAA INTERNATIONAL RESPONSIBILITIES
International Representation - ALPA Global Pilot Strategy

• ALPA now represents members in U.S. and Canada, and provides services to other associations in Europe and the Far East
• ALPA was concerned with the implementation of international code sharing agreements
• concerned about effect on membership labor agreements
• concerned about the effects on safety because many countries safety standards are less than those in the U.S.
• ALPA developed a Global Strategy including One Level of Safety Internationally
• Designed to address the level playing field concept and effect upon safety
• Example: Flight Time/Duty Time limitations where some countries limitations are far less restrictive than the U.S.

• The Accident Risk is much higher outside the U.S./Canada/Europe/Oceania and this disparity is of significant concern
• U.S. should lead, not follow: seek a common standard worldwide
• FAA has done this in some areas
• Example: Global Positioning Satellite program

• Harmonization of Aircraft Certification Rules - driven by manufacturers cost concerns
• Already well underway
• FAA/JAA Harmonization in 14th year
• Progress has been slow but substantial
• Harmonization of Operating Rules - driven by cost concerns
• Very limited progress to date
• FAA International Aviation Safety Assessment Program (IASAP) - driven by Avianca Accident and resulting public concern
• Affects only foreign carriers that operate into the U.S. (Part 129)
• Fully support that program
•  
• ICAO Assessment Program - driven by IASAP program
• Chicago Convention Provisions not enforced
• Some states do not file differences, much less try to comply with the Standards and Recommended Practices
• A more formal program needed
• Active FAA role in ICAO Assessment needed

• Examples of work FAA could do if it were proactive
• International partnership in data sharing with other regulatory agencies
• Controlled Flight Into Terrain
• More participation in already existing program developed by Flight Safety Foundation and ICAO
• FAA was previously active, now it does not participate on the implementation team
• Many states do not require Ground Proximity Warning Systems
• Participation in development of standards for Enhanced Ground Proximity Warning Systems
• TCAS
• TCAS on freighters is not required today in U.S.
• It will be required on freighters in Europe in January 1998. In India rule to be effective in December 1997
• ICAO proposal being developed and requires active FAA participation
• Air Carrier Airport and Facilities Assessments
• FAA cannot tell other states how to set up their airports and facilities
• FAA can require U.S. carriers to fulfill their obligation to conduct operator assessments of destination airports and facilities.
• FAR Part 129 Oversight of Foreign Carriers
• Remove roadblocks to enforcement due to State Department and other political considerations.
• An overall review needs to be conducted to determine how and where the FAA can be proactive to improve safety globally

SAFETY DATA/INFORMATION PROGRAMS
Data/Information Programs Provide Valuable Safety Information

• Programs provide early warning clues to help prevent accidents
• Programs properly run have support of pilots

• Programs are Non Punitive
• Data needs to be protected to assure it will continue to be collected and used for safety purposes
• Punitive programs will not result in significant data collection

• Flight Crew Privacy a major concern
• Should be used for Accident Investigation Purposes Only
• They now have special protection from public disclosure
• There should be no action that would lessen the effectiveness of the present CVR rule

• Benefits of data collection have been manifold, and they are fundamental for tracking progress toward meeting safety goals
• Build on successful present protection practices
• Provide the same special protection to Flight Recorder, FOQA and Partnership data that is now provided to cockpit voice recorders
• Assure no degradation of present data protection and non-punitive provisions