With fewer accidents to investigate and learn from, it is widely held that collecting and analyzing data and then sharing the information that results from that process is essential to identifying safety risks before they result in accidents and serious incidents. Flight Safety Foundation wholeheartedly supports this thinking. Efficient and effective safety data collection and processing systems are critical to effective safety management systems and to continued improvement of the industry’s safety performance.
What may be less widely recognized is that not all safety-critical data are generated automatically by aircraft systems, components and sensors monitored by flight data recorders and flight data management systems. Valuable data and information are gathered in the form of voluntary safety reports from pilots, air traffic controllers, aircraft maintenance technicians and others throughout the system who report potential safety issues ranging from operational issues to inadvertent procedural errors to honest mistakes made during regular work activities. Once an issue is identified, it can be analyzed to determine what caused it and to develop mitigation measures — such as more training, better procedural guidance or a fatigue risk management program — that can be put in place to ensure the problem is not repeated and that safety performance is enhanced.
The same basic concept applies at the organizational level. If an aircraft operator or maintenance facility, for instance, is found not to be in compliance with applicable regulations, safety is best served by quickly and efficiently bringing that entity back into compliance, and ensuring that it remains in compliance by identifying and mitigating the underlying problems through cooperation, root cause analysis and sharing information.
Nearly three years ago, the U.S. Federal Aviation Administration (FAA) issued Order 8000.373 establishing its new compliance philosophy “as the overarching guidance for implementing the FAA’s strategic safety oversight approach to meet the challenges of today’s rapidly changing aerospace system.”
The Foundation supports the FAA’s compliance philosophy because it seeks to foster the just culture that is essential to robust voluntary reporting; because its objective is to identify safety issues that underlie deviation from standards and to correct them as quickly and effectively as possible; and because the philosophy advocates a problem-solving approach “where the goal is to enhance the safety performance of individual and organizational certificate holders.”
There is an argument to be made that fear of an enforcement action in the form of a fine or a certificate suspension or revocation can contribute to ensuring regulatory compliance, and that’s probably true in cases in which organizations or individuals are intentionally violating rules or procedures. But I think you would be hard pressed to show that penalties prevent honest mistakes or inadvertent noncompliance. Instead, fear of being penalized is more likely to lead companies and their employees not to report safety-related problems.
Cooperation, transparency and the sharing of data and information within companies, between companies, and between regulators and the regulated are essential to the industry’s safety performance. Individuals and organizations that are grossly negligent, intentionally noncompliant, or unwilling or unable to comply with regulatory standards should be subject to enforcement actions. But for most other cases, it is more important to restore compliance and understand and correct the issues that led to the noncompliance.
