Operators find that sharing ASAP reports generates significant operational benefits.
Pilots, maintenance techs, and most other aviation workers are fully aware that the safety of aviation operations depends on their day-to-day efforts. But doing the right thing that will keep you, your colleagues, and your customers safe—minute by minute, throughout each day—isn’t always easy. Human beings make mistakes; we forget; we interpret a supervisor’s direction differently than it was intended.
When operators aren’t aware of those mistakes or deviations, they lose the opportunity to correct them or address the underlying conditions that could contribute to future accidents or incidents. But what if pilots and others could actually report safety-related events or violations without fear of being penalized by the FAA or terminated by their employer? That’s now possible through the Aviation Safety Action Program (ASAP), a new member benefit available through HAI.
Under ASAP, aviation employees throughout the company—from maintenance to the flight deck—can submit voluntary reports of safety-related occurrences without fear of losing their jobs or being reprimanded by the FAA and losing their certificates, as long as certain conditions are met (see the “ASAP Defined” section at the end of the article).
In March 2021, HAI launched an ASAP reporting capability in partnership with the Air Charter Safety Foundation (ACSF, online at acsf.aero). A well-known third-party facilitator of ASAP, ACSF has managed more than half of all ASAP participating companies for the business and general aviation industry since 2012.
ACSF works alongside aircraft operators and the FAA to receive, review, and respond to ASAP reports. “Having a neutral third party in the discussion helps to develop consensus,” notes the safety manager for an East Coast–based sports organization.
ASAP Brings Big Benefits
ASAP is just one tool used in a robust safety management system (SMS) to improve both an organization’s just culture and reporting culture. We don’t know what we don’t know, which is why the employee hazard reports submitted through ASAP are so powerful. Sharing hazards and other safety issues can prevent others from making the same errors. ASAP’s nonpunitive, solution-oriented focus on safety also supports an organization’s just culture.
The program has posted impressive results so far. As ACSF president, I can attest to the fact that more than 90% of our 7,000 ASAP safety reports have been “sole source.” This means more than 6,300 of those safety events may never have been disclosed if it weren’t for ASAP. This level of active participation validates the entire ASAP program.
Beyond the ability to improve safety, ASAP’s solution-oriented approach benefits operational efficiencies and policies. For example, after a large regional air ambulance provider reported the inability to reach air traffic control (ATC) in remote areas, its safety manager said, “If someone in the back has a life-threatening medical emergency and we can’t get clearance to get off the ground, that’s a problem.”
The organization developed operational procedures to remedy the issue. It now has a dedicated phone number to obtain departure clearances. Because ASAP reports are shared, its findings will help other operators, as well.
The air ambulance company also uncovered safety-related maintenance issues through ASAP. “We identified shortcomings with OEM maintenance manuals, which were updated,” its safety manager explains. “And we drafted content for the AIM [Aeronautical Information Manual, published by the FAA].” ASAP helped improve the level of safety within the company and among different certificate holders and OEMs, and led the FAA to adjust its policies.
ASAP Findings Improve Training
A just culture recognizes that most safety events are caused by honest mistakes, which are often caused by gaps in policies, procedures, or training. Operators have used ASAP to revise their flight operations and maintenance manuals and close training gaps.
Making such ongoing improvements to company policies and procedures is an important part of a just culture. “When a pilot isn’t terminated in these instances, we can offer remedial training and take corrective actions to help ensure that these events don’t happen again,” says the air ambulance safety manager.
Participants are encouraged to regularly incorporate information from ASAP reports into safety newsletters or team meetings.
Is It Really Nonpunitive?
One of the biggest reasons not all operators have signed up for ASAP is that some believe the program isn’t truly nonpunitive.
But that belief is quickly discouraged in the wake of these reported events and their positive outcomes. “As a safety manager, my job isn’t to find blame; it’s to find cause,” says the sports organization’s safety manager. “The benefit of having an ASAP is in the results—of gaining knowledge of the unintentional error or safety threat. It’s gratifying we can capture data and find solutions that often prove lifesaving.”
“ASAP was an easy sell to my boss,” says the safety manager for a Part 91 operator. “Our SMS policy has a statement about no retribution, so if a pilot makes an honest error, the FAA and company can’t take punitive action. And since the ASAP memorandum of understanding is signed by three entities [the employer, the FAA, and the ACSF], it’s a formal promise that adds strength and trust in the program.”
Sharing Data Benefits Industry
Another key benefit of ASAP is that program participants have access to findings to help other aircraft operators improve their safety policies and procedures. For example, through ASAP, the air ambulance company identified what to do when an operator has four helicopters arriving in a landing zone and ATC is unavailable. The operator’s corrective action was to work with the FAA and a local ATC to develop a procedure for the first aircraft landing on scene, the second, and so on. These procedures are now available to other operators in the area.
Sharing safety data has big benefits for ASAP participants, enabling them to use lessons learned by others to improve efficiencies and even save lives. This is even true of OEMs.
“It doesn’t cost us one extra cent to learn from another’s safety event, and we don’t pay the operators’ costs of experiencing it,” notes the sports organization safety manager.
“We think ASAP is an invaluable program if it’s understood and managed correctly,” says the operations director of an air tour operator. “This program isn’t for people who like to fly under the radar. If you really want to create a just culture and culture of compliance and risk management, ASAP opens up and mitigates those pockets of resistance.”
ASAP in Action: A Case Study
The following case study, provided by a tour operator, shows why ASAP provides value for both the aviation employee and his or her organization.
The Reported Incident: On one air tour flight, a chip light flickers. Standard policy requires landing as soon as possible. The light continues to flicker and then turns solid. By this time, the pilot is 10 minutes from base. He turns around and heads back to the base, choosing not to land anywhere closer, despite many available options.
The light turns out to be faulty and not a serious issue. But positive outcome aside, there are still questions about the pilot’s decision to fly for 10 minutes with the chip light on.
The director of operations reviews the company’s just culture policy, and he considers the pilot’s decision to be reckless. That is, until the pilot explains that decision.
The ASAP Investigation: The pilot tells the ASAP event review committee (ERC) that he previously had flown in Alaska with a chip light on and wasn’t able to set down, so he is comfortable flying with it illuminated. Also, the pilot relates that the tour company had previously told him, “If you’re going to land, make sure you land somewhere that it doesn’t end up in the news.” With further investigation by the ERC, what looked like reckless behavior turned into a company procedural issue.
Outcome: As a result of the ASAP investigation, that tour operator has embraced more conservative aeronautical decision-making and changed its communication and training protocols. There’s no longer a “go, no matter what” attitude. “Now, we tell them you can take off and turn around,” the operator notes. “And you can cancel the flight; we’ll applaud that decision. ASAP has gotten us closer to the mindset that we don’t need ‘macho’ in any way.”
The ASAP process helped the operator to focus on deeper issues than the actions of one pilot. “This ASAP reporting helped us really look at what sort of attitudes are in the pilots’ minds when we train them. And we have to pay attention to what we say during training,” he says. “When the pilots are in the air, we want them to only make aeronautical decisions. We encourage them to have a far more conservative mindset when flying tours.”
Is ASAP Worth It?
The last word on ASAP is best summed up by those who’ve used it. “Anyone who’s not using ASAP is doing themselves a significant disservice,” notes the Part 91 operator.
“ASAP more than pays for itself,” says the tourism operator. “And it’s brought items to our attention that might otherwise have fallen through the cracks.”
New to Safety? Start Here
For those operators who’ve yet to implement an SMS, HAI and ACSF are here to help by providing education, mentoring, resources, and tools. Our teams will take operators through the process of setting up an SMS and getting started with ASAP. As an added bonus, HAI members who participate in ASAP will get free access to the actively managed, Web-based ACSF SMS Tool, which helps teams manage all aspects of safety.
Flight departments can use this tool to document aviation safety data, perform risk assessments, and assign corrective actions, among other things. The platform also serves as an internal reporting program and offers multiple reporting options for each safety event. Users can voluntarily submit reports for an ASAP ERC meeting and export reports to the FAA’s Aviation Safety Information Analysis and Sharing (ASIAS) system. Visit acsf.aero/acsf-sms-tool for more information.
What ASAP Is. An Aviation Safety Action Program (ASAP) fosters a voluntary, cooperative, nonpunitive environment for the self-reporting of any events or concerns that could affect the safety of a flight. Flight department employees (pilots, aviation mechanics/engineers, dispatchers, schedulers, and so on) use ASAP to self-identify and report significant safety concerns and issues.
Types of Reportable Events. Reportable events may include (but are not limited to) operational deficiencies, noncompliance with regulations, or deviations from company policies and procedures. Examples include flying an unstable approach, airspace violations, altitude or route deviations, logbook errors, and OEM aircraft design or configuration issues.
Events Not Accepted by ASAP. The FAA takes no action against an employee who submits a report that is accepted as being appropriate for the ASAP process. However, not all events reported to ASAP are protected from punitive action.
An employee’s report may be dismissed from ASAP if his or her actions demonstrate an intentional disregard for company safety policies or the federal aviation regulations, or if he or she is involved in criminal activity, substance abuse, or the intentional falsification of information. When an employee’s report is dismissed from ASAP, the events contained in that report may be evaluated by the employer or the FAA for further disciplinary action.
ASAP Resolution Process. Each ASAP report is investigated by an organization’s event review committee (ERC), which typically meets every two to three months or as needed. An ERC consists of three members: a management representative from the operator, an employee representative (pilot, mechanic, dispatcher, as appropriate), and a qualified FAA inspector from the appropriate flight standards district office. A representative from the Air Charter Safety Foundation (ACSF) is also present as a neutral third-party ASAP facilitator.
Committee members work together to review, analyze, and resolve the reported safety event. Using consensus and a nondisciplinary approach, the committee determines corrective actions that address all causal factors related to the event, including training gaps or ambiguities in company policies.
After the ERC determines to its satisfaction that all corrective actions have been properly completed, the ERC notifies the submitter that the report is closed.
ASAP Benefits. Employees of a participating ASAP organization have access to a nonpunitive reporting system that encourages them to submit safety events that might otherwise never be reported. Participating companies can take advantage of a structured, collaborative process to resolve those events and address all causal factors while strengthening their just culture. De-identified information from ASAP reports is also available to other organizations participating in the ACSF ASAP, and those companies are encouraged to use that data, including all corrective actions taken, to inform their own training programs and develop mitigation strategies for their operations. In addition, ACSF publishes a quarterly ASAP newsletter.
How to Join ASAP
Register. HAI members can register at rotor.org/ASAP. A one-time setup fee and annual administration fee based on the number of users is required for ASAP participation and member support.
Sign an MOU. ACSF will organize the co-signing of a memorandum of understanding (MOU) between all three parties—your operation, your local FAA flight standards district office (FSDO), and the ACSF. Once the MOU is finalized, the ACSF will work with you to begin your program participation.
Conduct Training. An ACSF representative will offer train-the-trainer coursework for your company ASAP representative as well as for your FSDO and its ASAP representative. Then, your company ASAP rep will train fellow employees in the program rules as well as report submission.