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Conditions for effective FDA programmes
16.3.39 Several conditions that are fundamental to successful FDA programmes are discussed below.
Protection of FDA data
16.3.40 Airline management and pilots both have legitimate concerns regarding the protection of FDA
data, for example:
a) use of data for disciplinary purposes;
b) use of data for enforcement actions against individuals or against the company, except in cases of
criminal intent or intentional disregard of safety;
c) disclosure to the media and the general public under the provisions of State laws for access to
information; and
d) disclosure during civil litigation.
16.3.41 The integrity of FDA programmes rests upon protection of the FDA data. Any disclosure for
purposes other than safety management can compromise the voluntary provision of FDA data, thereby
compromising flight safety. Thus, preventing the misuse of FDA data is a common interest of the State, the
airlines and the pilots.
Chapter 16. Aircraft Operations 16-11
Essential trust
16.3.42 As with successful incident reporting systems, the trust established between management and
its pilots is the foundation for a successful FDA programme. This trust can be facilitated by:
a) early participation of the pilots’ association in the design, implementation and operation of the FDA
programme;
b) a formal agreement between management and the pilots, identifying the procedures for the use and
protection of data. (Appendix 3 to this chapter provides a sample agreement between an airline and
its aircrew); and
c) Data security, optimized by:
1) adhering to stringent agreements with the pilots’ associations;
2) strictly limiting data access to selected individuals within the company;
3) maintaining tight control to ensure that identifying data are removed from the flight data records
as soon as possible;
4) ensuring that operational problems are promptly addressed by management; and
5) destruction of all identified data as soon as possible.
16.3.43 Access to crew identification information during follow-up should be available only to
specifically authorized persons and used only for the purpose of an investigation. Subsequent to the
analysis, the data enabling this identification should be destroyed.
Requisite safety culture
16.3.44 Consistent and competent programme management characterizes successful FDA
programmes. Indicators of an effective safety culture include:
a) top management’s demonstrated commitment to promoting a proactive safety culture, championing
the cooperation and accountability of all organizational levels and relevant aviation associations
(pilots, cabin crew, AMEs, dispatchers, etc.);
b) a non-punitive company policy. (The main objective of the FDA programme must be to identify
hazards, not to identify individuals who may have committed an unsafe act.);
c) FDA programme management by a dedicated staff within the safety or operations departments, with
a high degree of specialization and logistical support;
d) potential risks are identified through the correlation of the results of the analysis by persons with
appropriate expertise. (For example, pilots experienced on the aircraft type being analysed are
required for the accurate diagnosis of operational hazards emerging from FDA analyses.);
e) focus on monitoring fleet trends aggregated from numerous operations, rather than on specific
events. The identification of systemic issues adds more value for safety management than (perhaps
isolated) events;
16-12 Safety Management Manual (SMM)
f) a well-structured, de-identification system to protect the confidentiality of the data; and
g) an efficient communication system for disseminating hazard information (and subsequent risk
assessments) to relevant departments and outside agencies to permit timely safety action.
Implementing an FDA programme
16.3.45 Typically, the following steps are required to implement an FDA programme:
a) implementation of pilot association agreements;
b) establishment and verification of operational and security procedures;
c) installation of equipment;
d) selection and training of dedicated and experienced staff to operate the programme; and
e) commencement of data analysis and validation.
16.3.46 Bearing in mind the time required to obtain crew/management agreements and develop
procedures, a start-up airline with no FDA experience would not likely achieve an operational system in less
than twelve months. Another year may be required before any safety and cost benefits appear.
Improvements in the analysis software, or the use of outside specialist service providers, may shorten these
time frames.
16.3.47 Integrating the FDA programme with other safety monitoring systems into a coherent SMS will
　
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