What Can Compliance Data Tell Us?
Leveraging Data to Improve General Aviation Safety
By Cristy Minnis and Rune Duke, FAA Safety and Compliance Team
The FAA’s data-driven approach to improving commercial aviation safety is well known, but an open exchange of data is just as critical for General Aviation safety. Our Compliance Program and voluntary reporting programs are foundational to this effort because they produce large volumes of data that help us quickly identify and mitigate emerging safety concerns. The Compliance Program encourages an open and transparent exchange of safety data by incentivizing operators to freely explain why they made a mistake. It does this by removing the threat of legal enforcement action when violations are due to factors such as flawed systems and procedures, simple mistakes, lack of understanding, or diminished skills. In these situations, we aim to achieve compliance through training or documented improvements.
As we covered in the recent article, Measuring Success, the Compliance Program analyzes trends in the data collected to determine if safety concerns are becoming systemic.
One dataset the FAA reviews regularly is pilot deviations, such as entering airspace or crossing a runway without the proper clearance from air traffic control. At the conclusion of an investigation of a pilot deviation, the FAA will indicate the findings of the root cause analysis, which is intended to succinctly answer the question of “how did this happen?” The FAA publishes a Root Cause Analysis Taxonomy in FAA Order 8900.1 to ensure investigators utilize a standardized way of categorizing their findings from their investigations. Below is an excerpt of the taxonomy used in pilot deviation investigations.
A review of the pilot deviation investigations for part 91 operations over the past few quarters has revealed that “mistakes” and “lapses” in human performance appear to be the leading root causes, as seen below.
When looking further into the investigation data, we see that we used Compliance Actions to address over 60 percent of the pilot deviations associated with mistakes and lapses. This supports the stance of the program that we recognize honest mistakes do occur, and that if the pilot is willing to work with the FAA, we will address these mistakes at the most effective and efficient level possible — typically without resorting to legal enforcement action. However, when these actions are deemed intentional or reckless, or if the person is unwilling or unable to return to compliance, we generally pursue legal enforcement. Moving beyond pilot deviations, a review of all enforcement and administrative actions against specific certificate types closed in FY23 shows that the top cited regulation was 91.13A: careless or reckless operations. Below you can see the top 5 cited regulations across specific certificates.
Voluntary reporting programs also have been instrumental in improving commercial and general aviation safety. These include the NASA Aviation Safety Reporting System (ASRS), Voluntary Disclosure Reporting Program (VDRP), and Aviation Safety Action Program (ASAP). They provide a place where operators can report deviations they have made or safety concerns they have observed without fear of reprisal. The information from the reports has helped to identify emerging safety hazards and implement mitigations. Reporting safety events or concerns is vital to improving safety. The chart below depicts the reporting across these three voluntary reporting programs.
The Compliance Program and the voluntary safety programs are key components of the FAA’s Integrated Oversight Philosophy (IOP), which can be found in FAA Order 8000.72. The purpose of the IOP is to continue to evolve the FAA’s safety oversight system while supporting risk-based decision making to meet the challenges of the constantly changing NAS. To better support awareness of the FAA’s IOP, we are drafting new text for the Pilot’s Handbook of Aeronautical Knowledge. This language will not only inform aviators of the FAA’s process when a deviation from a rule occurs, but also stress the importance and benefit of participating in voluntary reporting programs, like ASRS. Submitting safety reports to ASRS is confidential, contributes to our safety data, and may personally benefit the submitter as a sanction imposed by the FAA (e.g., a 30-day certificate suspension) would be waived, assuming the required parameters are met. NASA, which manages ASRS, also uses the reports to share lessons learned through their CALLBACK safety newsletter and ASRS Safety Alerts.
Our long-term plans include improved sharing of compliance data with the industry, including with groups like the General Aviation Joint Safety Committee (GAJSC), to increase our collective insights and ensure we take effective action, leading to improved compliance and a safer NAS.
Cristy Minnis and Rune Duke are management and program analysts in the FAA’s Safety and Compliance Team.
