Par 16 Page 13 recommended corrective action in a manner satisfactory to all members of the ERC. These cases may result in the reopening of the case and referral of the matter for appropriate action.
(24) A statement that any safety-related ASAP event that concerns an apparent violation(s) that is EXCLUDED from ASAP, will be referred by the FAA ERC representative to an appropriate office within the FAA for any additional investigation and reexamination and/or enforcement action, as appropriate.
(25) A statement that a closed ASAP case, including a related EIR, that involves a violation addressed with administrative action or for which no action has been taken, may be reopened if evidence is later discovered that establishes the event should have been excluded from the program.
(26) A statement that when the ERC becomes aware of an issue involving the medical qualification or medical certification of an airman, the ERC must immediately advise the appropriate Regional Flight Surgeon about the issue. The ERC will work with the Regional Flight Surgeon and the certificate holder’s medical department or medical consultants to resolve any medical certification or medical qualification issues or concerns revealed in an ASAP report, or through the processing of that report. The FAA ERC member must follow the direction(s) of the Regional Flight Surgeon with respect to any medical certification or qualification issue(s) revealed in an ASAP report.
(27) A statement that reports that appear to involve possible criminal activity, substance abuse, controlled substances, alcohol, or intentional falsification will be referred to an appropriate FAA office for further handling. The FAA may use such reports for any enforcement purposes and will refer such reports to law enforcement agencies, as appropriate.
b. Signatories. The MOU must be signed by an authorized representative of each party.
17. ACCEPTANCE/RENEWAL PROCEDURES.
a. Review. The certificate holder should initially develop and present the program to the CHDO for review. The CHDO and the certificate holder will review it to ensure that it satisfies the guidance in AC 120-66, as amended, FAA Order 2150.3A, and the applicable FAA Handbook Bulletins for Air Transportation and Airworthiness, entitled Establishment of Aviation Safety Action Programs (ASAP). Prior to acceptance, the program should be reviewed to ensure that FAA resources are available to administer the program effectively. Program proposals that require excessive agency resources should be modified, or not accepted.
b. Procedures. When the CHDO is satisfied that the program is acceptable under the guidance of ASAP, the CHDO manager forwards two copies of the MOU, the CHDO’s recommendation for acceptance, and the completed ASAP checklist (found in the applicable FAA Handbook Bulletins for Air Transportation and Airworthiness, entitled Establishment of Aviation Safety Action Programs (ASAP)) through the respective Flight Standards Division regional office to the appropriate headquarters program office(s) (i.e., Air Transportation Division, AFS-200, for operations programs and Continuous Airworthiness Maintenance Division, AFS-300, for airworthiness programs, including repair stations). For programs that encompass both operations and airworthiness, the MOU and checklist go to both offices. The program offices shall review and forward a copy of the
Par 17Page 14 MOU to the Office of the Chief Counsel, Enforcement Division, AGC-300, for appropriate legal review. All programs, except for renewals of Continuing programs, shall receive final acceptance from the Director, Flight Standards Service, AFS-1. AFS-1 will indicate acceptance of the MOU by FAA memorandum to the CHDO manager through the regional division manager. The program office(s) will be responsible for preparing the memorandum for AFS-1’s signature and submit it with the ASAP package to AFS-1. Following acceptance by AFS-1, the CHDO manager shall sign the MOU on behalf of the FAA. The certificate holder should allow a minimum of 60 days for the FAA acceptance process to be completed once its ASAP program is received at FAA headquarters for review.
c. ASAP Demonstration programs, renewal of a Demonstration program, and the initial acceptance of a Continuing program are processed in the same manner as described in paragraphs 17a and b.
d. Renewal of a Continuing Program. The renewal of a Continuing program is accomplished every 2 years after a review by the parties to the MOU to ensure the particular ASAP program is meeting its objectives. The renewal may be accomplished at the local CHDO level by the CHDO manager signing the MOU on behalf of the FAA. The CHDO manager shall notify the appropriate program office (AFS-200 or AFS-300) in writing 60 days in advance of renewing a Continuing ASAP program.
e. MOU Amendments. Any amendments to an MOU that has already been accepted, must be coordinated with the respective program office(s) (AFS-200 and AFS-300) prior to FAA acceptance.
18. RECORDKEEPING. The parties should maintain those records necessary for a program’s administration and evaluation. Records submitted to the FAA for review pursuant to the ASAP are protected to the extent allowed by law under applicable exemptions of the Freedom of Information Act. A certificate holder’s ASAP records and reporting system must not be contrary to 14 CFR.
19. JOINT ASAP/INDUSTRY ADVISORY COMMITTEE. After issuance of this AC, the FAA will support the establishment of a joint FAA/Industry Advisory Committee for the purpose of reviewing the operation and effectiveness of the ASAP. The committee will be comprised of key FAA personnel and representatives from industry who are involved with the ASAP process. The committee will meet as necessary and make recommendations for improving ASAP or for proposing changes to this AC. Any recommendations should reflect the needs of the government and industry such that continuing ASAP’s will provide the maximum aviation safety benefit to the public.
/s/ L. Nicholas Lacey Director, Flight Standards Service
Appendix 1 Par 1 Page 1 APPENDIX 1. SAMPLE MEMORANDUM OF UNDERSTANDING This is a sample of an Aviation Safety Action Program (ASAP) memorandum of understanding (MOU) for a flight crewmember employee group at an air carrier operating under Title 14 of the Code of Federal Regulations (14 CFR) part 121. It is for illustrative purposes only; the actual MOU developed by a certificate holder may be different from this sample. However, in order to be accepted by the FAA, the MOU should address the elements of an ASAP that are set forth in FAA guidance material.
MEMORANDUM OF UNDERSTANDING
1. GENERAL. ABC Airlines is a Title 14 of the Code of Federal Regulations (14 CFR) part 121 domestic air carrier engaged in scheduled passenger operations within the United States, Mexico, and Canada. It also conducts passenger charter and cargo operations. ABC Airlines operates 100 turbojet aircraft and has over 5,500 employees including 1,100 flight crewmembers (pilots and flight engineers) represented by ABC Pilot Union.
2. PURPOSE. Over the past six months ABC Airlines has experienced an increase in certain types of incidents that have raised a concern in the flight operations area. Such incidents have occurred during all phases of flight and have involved the following: noncompliance with air traffic control (ATC) clearance (e.g., routing, heading, and altitude deviations), runway and taxiway incursions, and departures without proper flight planned fuel onboard. To obtain valuable safety information that may lead to correcting these issues, ABC Airlines and its flight crewmembers, represented by ABC Pilot Union, are voluntarily entering into an Aviation Safety Action Program (ASAP) with the Federal Aviation Administration (FAA). This Memorandum of Understanding (MOU) describes the provisions of the program. This is a Demonstration program for an 18-month period. If it is determined to be successful after a comprehensive review and evaluation, the parties intend for it to become a Continuing program.
The objective of the program will be to gather safety information from the flight crewmembers that will focus on the incidents described above and to obtain information concerning any additional safety of flight item that a flight crewmember believes should be reported. The information will be analyzed in order to develop and implement solutions to safety issues identified under the program.
3. BENEFITS. The program will provide a voluntary, cooperative, nonpunitive environment for the open reporting of safety of flight concerns. Through such reporting, all parties will have access to valuable information that may not otherwise be obtainable. This information will be analyzed in order to develop corrective action to help solve safety issues and eliminate deviations from 14 CFR.
For reports qualified for inclusion in the program, the FAA will use lesser enforcement action, referred to in this document as an “enforcement related incentive,” to address certain alleged violations of the regulations by employees of ABC Airlines.
Appendix 1 Par 4Page 2
4. APPLICABILITY. The ABC ASAP applies to all flight crewmember employees of ABC Airlines. Reports involving an apparent violation that is not inadvertent or that appears to involve an intentional disregard for safety, criminal activity, substance abuse, controlled substances, alcohol, or intentional falsification are excluded from the program.
a. Apparent violations of the regulations by ABC Airlines that are discovered under this program will be handled under the Voluntary Disclosure Policy, provided that ABC Airlines voluntarily reported the alleged violations to the FAA and that the other elements of that policy are met. (See AC 00-58, Voluntary Disclosure Reporting Program, FAA Order 2150.3A, Compliance and Enforcement Program, and Compliance/Enforcement Bulletin No. 90-6.)
b. Any modifications of this MOU must be accepted by all parties to the agreement.
5. PROGRAM DURATION. The ASAP is designed to identify and correct specific problems related to flight safety at ABC Airlines. The duration of the program will be 18 months, beginning the date it is signed by all parties to this MOU. The program may be terminated at any time for any reason by ABC Airlines, the FAA, or any other party to the MOU. The termination or modification of a program will not adversely affect anyone who acted in reliance on the terms of a program in effect at the time of that action; i.e., when a program is terminated, all reports and investigations that were in progress will be handled under the provisions of the program until they are completed.
Failure of any party to follow the terms of the program ordinarily will result in termination of the program. Failure of ABC Airlines to follow through with corrective action acceptable to the FAA, to resolve any safety deficiencies, ordinarily will result in termination of the program.
6. REPORTING PROCEDURES. When a flight crewmember observes a safety problem or experiences an incident during flight, he or she should note the problem or incident and be able to describe it in enough detail so that it can be evaluated by a third party.
a. For example, if the safety incident involves a deviation from an ATC clearance, the pilot should note the date, time, place, altitude, flight number, and ATC frequency, along with enough other information describing the incident and any perceived safety problem. After the trip sequence has ended for that day, the flight crewmember should complete ABC Airlines’ ASAP Form number 123 for each safety problem or incident (hereinafter referred to as “report”) and submit it by company mail to the Director of Flight Safety, ATTN: ASAP Manager.
b. In order for the flight crewmember who submitted the report to be covered under the ASAP and eligible for any FAA enforcement-related incentive, the report must be mailed within 24 hours after the end of the flight sequence for the day of occurrence, absent extraordinary circumstances.
For example, if the incident occurred at 1400 hours (Monday) and the flight crewmember completes his or her flight sequence for that day at 1900 hours, the report should be mailed no later than 1900 hours the following day (Tuesday). In order for all flight crewmembers to be covered under the ASAP for any regulatory violations resulting from an incident, they must all sign the same report or submit separate individual reports for the same incident. If the company mail system
Appendix 1 Par 6 Page 3 is not available to the flight crewmember at the time he or she needs to file a report, the crewmember may contact the ASAP manager’s office and file a report via fax or telephone.
c. When the employee is first made aware of the event by the ASAP Event Review Committee (ERC) or certificate holder management, the ERC will review all available information to determine whether the employee knew or should have known about the apparent violation(s), prior to being notified by the ERC or certificate holder management. If the ERC determines that the employee knew or should have known about the apparent violation(s), then the report will not be covered under ASAP. On the other hand, if the ERC determines that the employee did not know or could not have known about the apparent violation(s), then the report would be covered under ASAP provided all other ASAP criteria have been met.
7. POINTS OF CONTACT. The ERC will be comprised of the ASAP manager, representing ABC Airlines Flight Department management; the ASAP coordinator for ABC Pilot Union; and an FAA inspector from the Certificate Holding District Office (CHDO) for ABC Airlines; or qualified alternates in their absence.
8. ASAP MANAGER. When the report is received by the ASAP manager, he or she will record the date and time of any incident described in the report and the date and time that the report was submitted through the company mail system. The ASAP manager will enter the report, along with all of the supporting data, on the agenda for the next ERC meeting.
The ERC will determine whether a report is submitted in a timely manner and whether extraordinary circumstances precluded timely submission. To confirm that a report has been received, the ASAP manager will send a written receipt (ABC Airlines’ ASAP Form number 234) through the company mail system to each flight crewmember who submits a report. The receipt will confirm whether or not the report was determined to be timely. The ASAP manager will serve as the focal point for information about, and inquiries concerning the status of, ASAP reports, and for the coordination and tracking of recommendations.
9. EVENT REVIEW COMMITTEE (ERC). The ERC will review and analyze reports submitted by flight crewmembers under the program, identify actual or potential safety problems from the information contained in the reports, and propose solutions for those problems. The ERC will provide feedback to the individual who submitted the report.
a. The ERC will maintain a data base that continually tracks each event and the analysis of those events. The ERC will conduct a 12-month review of the ASAP with emphasis on any recurring safety-related events of a similar nature to ensure that the comprehensive fix has been effective in preventing or reducing future occurrences. That review will include recommendations for future comprehensive fixes for known recurring events.
b. This review is in addition to any other reviews conducted by the FAA. The ERC will also be responsible for preparing a final report on the program at its conclusion. If an application for a continuing program is anticipated, the ERC will prepare and submit a report with the certificate
Appendix 1 Par 9Page 4 holder’s application to the FAA 60 days in advance of the termination date of the Demonstration program.
10. ERC PROCESS.
a. The ERC will meet as necessary to review and analyze reports that will be listed on an agenda submitted by the ASAP manager. The ERC will determine the time and place of the meeting. The ERC will meet at least twice a month and the frequency of meetings will be determined by the number of reports that have accumulated.
b. The ERC will make its decisions involving ASAP issues based on consensus. Under the ABC Airlines ASAP, consensus of the ERC means the voluntary agreement of all representatives of the ERC. The ERC representatives will strive to reach consensus on whether a reported event is covered under the program, how that event should be addressed, and the corrective action or any enforcement action that should be taken as a result of the report. For example, the ERC should strive to reach a consensus on the recommended corrective action to address a safety problem such as an operating deficiency or airworthiness discrepancy reported under ASAP. The corrective action process would include working the safety issue(s) with the appropriate departments at the airline and the FAA that have the expertise and responsibility for the safety area of concern.
Recognizing that the FAA holds statutory authority to enforce the necessary rules and regulations, it is understood that the FAA retains all legal rights and responsibilities contained in Title 49, United States Code, and FAA Order 2150.3A. In the event there is not a consensus of the ERC on decisions concerning a report involving apparent violations, a qualification issue, or medical certification or qualification issue, the FAA ERC representative will decide how the report should be handled. The FAA will not use the ASAP report in any subsequent enforcement action except as described in paragraph 10i.
c. It is anticipated that three types of reports will be submitted to the ERC: safety-related reports that appear to involve a violation(s) of the regulations; reports that are of a general safety concern, but do not appear to involve a violation(s) of the regulations; and any other reports,
e.g., involving catering and passenger ticketing issues. All safety-related reports shall be fully evaluated and, to the extent appropriate, investigated.
d. The ERC will forward nonsafety reports to the appropriate ABC Airlines department head for his/her information and, if possible, internal (ABC Airlines) resolution. For reports related to flight safety, including reports involving possible violations of the regulations, the ERC will analyze the report, conduct interviews of reporting crewmembers, and gather additional information concerning the matter described in the report, as necessary.
e. The ERC should also make recommendations to ABC Airlines for appropriate comprehensive fixes. Such comprehensive fixes might include changes to ABC Airlines’ procedures, aircraft equipment modifications, or additional training for a crewmember. Any recommended changes that affect ABC Airlines will be forwarded through the ASAP manager to
Appendix 1 Par 10 Page 5 the appropriate department head for consideration and comment, and, if appropriate, implementation. The FAA will work with ABC Airlines to develop acceptable comprehensive fixes. The ASAP manager will track the implementation of the recommended comprehensive fixes and report on the progress of the fixes to the ERC as part of the regular ERC meetings. Any recommended comprehensive fix that is not implemented should be recorded along with the reason it was not implemented.
f. The ERC will review and discuss the evidence available to support an apparent violation(s) reported under the ASAP. The ERC representatives will strive to reach consensus on whether a reported event that involves noncompliance with the regulations, a qualification issue, or medical certification or qualification issue is covered under the program, how that event should be addressed, and the corrective action or any enforcement action that should be taken as a result of the report.
g. When the ERC becomes aware of an issue involving the medical qualification or medical certification of an airman, the ERC must immediately advise the appropriate Regional Flight Surgeon about the issue. The ERC will work with the Regional Flight Surgeon and the certificate holder’s medical department or medical consultants to resolve any medical certification or medical qualification issues or concerns revealed in an ASAP report, or through the processing of that report. The FAA ERC member must follow the direction(s) of the Regional Flight Surgeon with respect to any medical certification or medical qualification issue(s) revealed in an ASAP report.
h. Any corrective action recommended by the ERC must be completed to the satisfaction of the ERC, or the ASAP report will be excluded from the program and may be referred to the FAA for further action.
i. Use of the ABC Airlines’ ASAP Report: The content of the ASAP report will not be used to initiate or support any company disciplinary action, or as evidence for any purpose in an FAA enforcement action, except when the report is excluded from ASAP and appears to involve possible criminal activity, substance abuse, controlled substances, alcohol, or intentional falsification.
11. FAA ENFORCEMENT.
a. Criteria for Acceptance. The following criteria must be met in order for a report involving a possible violation to be covered under ASAP:
(1) The employee must submit a report in accordance with paragraphs 6b and c of this MOU;
(2) The alleged regulatory violation must be inadvertent and must not appear to involve an intentional disregard for safety; and
(3) The reported event must not appear to involve criminal activity, substance abuse, controlled substances, alcohol, or intentional falsification.
Appendix 1 Par 11Page 6
b. Administrative Action. Notwithstanding the criteria in paragraph 205 of FAA Order 2150.3A, apparent violation(s) disclosed in ABC ASAP reports that are covered under the program and supported by sufficient evidence will ordinarily be addressed with administrative action. Sufficient evidence means evidence gathered by an investigation not caused by, or otherwise predicated on the individual’s safety-related report.
c. Sole-Source Reports. A report is considered a sole-source report when all evidence of the event is discovered by or otherwise predicated on the report. Apparent violations disclosed in ASAP reports that are covered under the program and are sole-source reports will ordinarily be addressed with no action. It is possible to have more than one sole-source report for the same event.
d. Reports Involving Qualification Issues. ABC Airlines’ ASAP reports covered under the program that demonstrate a lack, or raise a question of a lack, of qualification of a certificate holder employee will be addressed with corrective action, if such action is appropriate and recommended by the ERC. If an employee fails to complete the corrective action in a manner satisfactory to all members of the ERC, then his/her report will be excluded from ASAP. In these cases, the ASAP event will be referred to an appropriate office within the FAA for any additional investigation, reexamination, and/or enforcement action, as appropriate.
e. Excluded from ASAP. Any safety-related ASAP event that concerns an apparent violation(s) that is EXCLUDED from ASAP will be referred by the FAA ERC member to an appropriate office within the FAA for any additional investigation and reexamination and/or enforcement action, as appropriate.
f. Corrective Action. Employees initially covered under an ASAP will be excluded from the program and not entitled to the enforcement-related incentive if they fail to complete the recommended corrective action in a manner satisfactory to all members of the ERC. These cases may result in the reopening of the case and referral of the matter for appropriate action.
g. Repeated Instances. Repeated instances involving the same or similar type of misconduct previously addressed with administrative action under the ASAP may also be covered under the program. The determination whether a repeated instance will be covered under the ASAP will be made on a case-by-case basis by the ERC, upon consideration of the facts and circumstances surrounding the misconduct.
h. Closed Cases. A closed ASAP case including a related enforcement investigative report involving a violation addressed with the enforcement-related incentive, or for which no action has been taken, may be reopened and appropriate enforcement action taken if sufficient evidence later is discovered that establishes that the violation should have been excluded from the program.
i. Reports Involving Intentional Disregard for Safety. The following policies apply to alleged violations involving an intentional disregard for safety that are disclosed in excluded ASAP reports:
Appendix 1 Par 11 Page 7 (and 8)
(1) Alleged violations involving an apparent intentional disregard for safety that do not demonstrate a lack, or raise a question of a lack, of qualification will be addressed with no more than administrative action, provided the ASAP reports are sole-source reports.
(2) Alleged violations involving an apparent intentional disregard for safety that also demonstrate a lack, or raise a question of a lack, of qualification or medical certification or medical qualification will be referred to an appropriate office within the FAA for any additional investigation and reexamination and/or enforcement action, as appropriate.
12. EMPLOYEE FEEDBACK. The ASAP manager will publish a synopsis of the reports received from the flight crewmembers in the ASAP section of the monthly ABC Airlines Employee Newsletter. The synopsis will include enough information so that the reporting flight crewmembers can identify their reports. Employee names, however, will not be included in the synopsis. The outcome of each report will be published. Any employee who submitted a report may also contact the ASAP manager to inquire about the status of his/her report.
13. INFORMATION AND TRAINING. The details of the ASAP will be made available to all flight crewmembers and their supervisors by publication in section 5 of the ABC Airlines’ flightcrew operating manual. Each flight crewmember will receive written guidance outlining the details of the program at least 2 weeks before the program begins. Each flight crewmember also will receive additional instruction concerning the program during the next regularly scheduled recurrent training class. All new-hire flight crewmember employees will receive training on the program during initial training.
14. RECORDKEEPING. All official documents and records regarding this program will be kept by the ASAP manager and made available to the parties of this agreement at their request. All ABC Airlines’ records and documents regarding this program will be kept in accordance with the provisions outlined in the “ABC Airlines ASAP Records and Reports Manual.” The manual will not be contrary to 14 CFR and the Pilot Records Improvement Act. The ABC Airlines Pilot Union and the FAA will maintain whatever records they deem necessary to meet their needs.
15. SIGNATORIES. All parties to this ASAP are entering into this agreement voluntarily.
____________________________________ _________ Director of Safety, ABC Airlines Date ___________________________________ _________ President, ABC Airlines Pilot Union Date ___________________________________ _________ Manager, FAA CHDO Date
Index Index A acceptance, 4, 6, 7, 8, 12, 13, 14 Administrative Action, 2, 7, 8, 9, 10, 12, 5 AFS 200, 14 AFS 300, 14 AGC 300, 13 air carrier, 1, 2, 4, 11, 1 air traffic control events, 9, 10, 12 Alaska Airlines, 2 alcohol, 1, 6, 8, 13, 2, 5 Altitude Awareness Program, 2 amendment, 14 American Airlines, 2 analysis, 5, 12 APPLICABILITY, 4, 2 B background, 2 benefits, 4, 6, 11 C certificate holder, 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 12, 13, 14, 1, 3, 4, 5, 6 Certificate Holding District Office, 2, 3, 13, 14 checklist, MOU, 13 consensus, 2, 5, 6, 7, 12, 4, 5 Continuing Programs, 5, 11, 13, 14 controlled substances, 1, 6, 8, 13, 2, 5 coordination, 14, 3 corrective action, 1, 2, 3, 4, 7, 8, 10, 11, 12, 13, 1, 2, 4, 5, 6 criminal activity, 1, 6, 8, 13, 2, 5 D definitions, 2 demonstration programs, 2, 3, 4, 5, 11, 14 descriptions, required in MOU, 11, 12 development, 5 duration, 4, 5, 11, 2 E employee group, 1, 3, 4, 11, 1 employee groups, 1, 3, 4 enforcement, 1, 2, 3, 7, 8, 10, 11, 12, 13, 1 enforcement policy, 7, 8 Event Review Committee, 2, 3, 5, 6, 7, 8, 10, 11, 12, 13, 3 evidence, 4, 7, 8, 9, 10, 12, 13, 5, 6 evidence, independent, 9, 10 evidence, new, 8 evidence, sufficient, 4, 7, 12 examples, 2, 9, 10 excluded reports, 6, 7, 8, 9, 12, 13 F FAA Order 2150.3A, 2, 7, 9, 13, 2, 4, 5 FAA representative, 3, 5 failure to reach or complete, 7, 8, 12 falsification, 1, 3, 6, 8, 13, 2, 5 feedback, 12, 3 fixes, 12, 3, 4, 5 Flight Standards District Office, 2, 9, 10 G guidelines, 6 H Handbook Bulletin, 13 I information, 1, 2, 3, 5, 6, 10, 11, 12, 14, 1, 2, 3, 4, 7 intentional disregard for safety, 6, 8, 2 M Manager, 13, 14, 2, 7 medical qualification/certification, 3, 5, 7, 8, 11, 13, 5, 7 modifications, program, 5, 12 modifications, programs, 12, 2, 4 MOU, 3, 5, 11, 12, 13, 14, 1 N no action, 7, 8, 10, 13, 6 O objective, ASAP, 1, 4, 11, 14, 1 P person, 2, 3 purpose, 1 Q qualification, 3, 5, 7, 8, 11, 13, 4, 5, 6, 7 R record keeping, 14 Regional Flight Surgeon, 5, 13, 5 renewal, 5, 11, 13, 14 reopening closed cases, 7, 8, 11, 13, 6
Index repair station, 1, 3, 4, 9, 11, 13 repeated violations, 6, 12 reporting ASAP events, 1, 2, 4, 11, 12, 14, 1, 4, 7 reporting, timely, 6, 11 reporting, voluntary, 1 reports, 1, 3, 5, 6, 7, 8, 9, 10, 11, 12, 13, 1, 2, 3, 4, 6, 7 resources, 5 review, 3, 4, 5, 6, 11, 12, 13, 14, 1, 3, 4, 5 reviews, frequency of, 12 S safety-related report or event, 1, 2, 3, 4, 6, 7, 8, 9, 10, 11, 12, 13, 3, 4, 6 sample, 11, 1 sole-source report, 4, 7, 8, 9, 10, 12, 6 statements, required in MOU, 11, 12, 13 substance abuse, 1, 6, 8, 13, 2, 5 T termination, 5, 11, 12, 2, 4, 6 tracking, 12, 3 training, 12, 4, 7 U US Air, 2 V Voluntary Disclosure, 2, 4, 9, 2