FOQA is almost impossible. The training department benefits from more effective training that is focused on documented problem areas, rather than using a standard syllabus that may not address areas where pilots are having problems. The maintenance department benefits from FOQA because of improved monitoring and documentation of maintenance problems, as well as having more data available for timely troubleshooting. This may result in fewer unscheduled component changes, better preventive maintenance procedures, and reduced requirements for spare part inventories.
(8) Evaluate Emerging Technologies. As the air carrier’s FOQA program expands to cover greater numbers of aircraft and fleets, the ability of current systems to accommodate growth and change should be carefully considered. Emerging technologies have the potential to increase the efficiency and effectiveness of all facets of a FOQA program. For example, newer data capture devices may be able to record more parameters more frequently, the handling of recorded data may require less human intervention, analysis programs may become more automated, and new visualization capabilities may enhance the ability to understand flights and events. Technological advances can also provide solutions for many of the day-to-day data handling problems that FOQA generates. During the next few years, the market for FOQA equipment may grow rapidly and vendors may offer new products and technology. Keeping apprised of new technologies can help to optimize the overall investment in a FOQA program.
(9) Expand Data Usage. Expansion of data analysis is controlled by the limitations of the data generated by the GDRAS and the degree to which the data are stored in proprietary formats. COTS products can be used for statistical analysis and data mining, particularly when GDRAS supports industry standards for data access and exchange. The integration of FOQA data with other internal safety-related programs (such as the Aviation Safety Action Program (ASAP)) should be considered to further enhance the safety value of the information.
(10) FOQA Meetings. Conduct periodic FOQA meetings (preferably every 30 days) to provide company stakeholders with updated trends, information, and evaluation of previously implemented corrective actions.
8. INFORMATION-SHARING WITH THE FAA AND INDUSTRY. Section 13.401 requires operators of approved FOQA programs to provide the FAA with aggregate FOQA data in a form and manner acceptable to the Administrator. There are various ways and levels on which to accomplish this sharing, which are described below. The operator’s director of safety or designated representative should be responsible for approving the release of de-identified aggregate FOQA data to any third party after obtaining the prior input and approval of all appropriate parties within the carrier, including the pilot association (if applicable).
a. Regular Briefings with the FAA Certificate Management Office (CMO). The first level of sharing is between the carrier and its local CMO/Flight Standards district office (FSDO).
To accomplish this, a regular meeting should be established with local FAA personnel, as identified in the operator’s FAA-approved I&O plan, to review FOQA program status and data trend analysis. Scheduling of these meetings should at least be quarterly, but can be held more often depending on the scope of the operator’s FOQA program. Normally, this meeting is held on the operator’s property and does not include the physical exchange of data, but a review of Par 7 Page 19
trend analysis and corrective action plans. Aggregate data has been further clarified by the FOQA Aviation Rulemaking Committee (ARC) as the de-identified summary, statistical FOQA information that is normally acquired within a carrier’s FAA-approved FOQA program. The degree of data de-identification will be determined by the respective air carrier, as described in its approved FOQA I&O Plan. For these briefings, the carrier may provide the aggregate data in oral, written, graphical, or digital format.
b. Intra-Carrier Information-Sharing. The sharing of FOQA information from an operator’s program with other operators can provide benefits to an operator’s overall safety program. This sharing can be accomplished through industry associations or directly between operators depending on the scope of the issue. Issues such as ATC or issues specific to a particular aircraft type are examples of subjects that can be shared between operators.
Maintaining confidentiality of the information between operators is important in providing a cooperative environment.
c. Industry Sharing with the FAA. Issues may be identified from FOQA data that can’t be solved through modifications or enhancements to an operator’s existing operational procedures or approved training programs or through aircraft modifications under the control of the carrier.
Also, issues may not be evident when individual carrier information is viewed independently.
Therefore, industry sharing with the FAA may be helpful in identifying and resolving broad, industry issues. The FAA, working with carriers, has adopted an incremental approach to this requirement. The specific provisions of this approach will be developed over time in collaboration with the FOQA ARC and operators of approved programs. As an interim means of establishing initial compliance with section 13.401, operators of approved FOQA programs should provide the FAA with at least quarterly briefings on observed trends. These operators should also provide any other applicable information of potential safety significance. The FAA will specify the location of the briefing. For the purpose of these briefings, carriers may provide the aggregate data in oral, written, graphical or digital format. As the FOQA ARC works collaboratively with the FAA to develop a more systematic approach to the future sharing of aggregate FOQA information, guidance to industry on acceptable means of compliance with section 13.401 will be updated as appropriate.
d. Need for Appropriate Background and Expertise. While it is recognized that the sharing of FOQA information between operators and the FAA has significant potential for identifying system safety issues, FOQA data (even in aggregate form) has important limitations.
A detailed understanding of the operator’s route structure, equipment types, operating procedures, measurement criteria, and data collection procedures is required so that conclusions drawn from FOQA data will result in effective or productive safety interventions. Analysis of FOQA data should be accomplished by the operator and/or trained representatives from the operator’s pilot association (if applicable) and by individuals thoroughly familiar with its characteristics. FOQA data analysis is a tool for managing safe operations, not an independent objective. FOQA is but one element of a comprehensive operator safety program.
9. FOQA IMPLEMENTATION AND OPERATIONS PLAN.
a. Overview and Plan Development.
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(1) Under section 13.401, an operator seeking protection from the use of FOQA data for enforcement by the FAA must obtain FAA approval of its FOQA I&O Plan. The document that describes an air carrier’s FOQA program for FAA approval purposes is the FOQA I&O Plan. A FOQA I&O Plan is submitted to the FAA for review and approval, as described in paragraph 9a(2) of this AC. The FAA will determine whether an air carrier’s FOQA program is approved and notify the air carrier by letter of any concerns and/or formal approval.
(2) The I&O Plan specifies the organization, technology, policies, procedures, and operational processes used by a certificate holder for its FOQA program. The FAA approval process for an I&O Plan is designed so the air carrier has identified adequate procedures, organizational resources, and material resources to collect, analyze, and act upon information provided by the FOQA data. The I&O Plan should describe the following elements:
(a) Program goals.
(b) Fleet(s) to be equipped for FOQA.
(c) Airborne hardware, analysis software, and other equipment to be used in the program.
(d) Organizational structure for the FOQA program.
(e) FOQA program personnel and associated roles and responsibilities.
(f) Procedures for data acquisition and handling.
(g) Procedures for data analysis and reporting.
(h) Procedures to implement corrective action(s) when adverse safety trends are discovered.
(i) Policies on data retention, data security, and crew contact.
(j) Policies on providing FAA with de-identified aggregate data on the operator’s premises and information on corrective actions undertaken.
(k) Policies and procedures for maintaining and revising the I&O Plan.
(l) A glossary of terms used in the I&O Plan.
(m) Appendices, which should include:
• A copy of the Letter of Agreement on FOQA with the pilots’ collective bargaining unit (if applicable) Par 8 Page 21
• List of events, parameters, and threshold values to be used in the program for each FOQA-equipped aircraft fleet
• A list of the documents referenced or cited
(3) An air carrier should identify its planned FOQA airborne and ground-based equipment in its initial I&O Plan. Subsequent revisions of the I&O Plan should identify any changes to the planned or implemented equipment. The purpose of this information is to ascertain proposed system capabilities, rather than to approve an air carrier’s selection of a particular brand or vendor. Decisions with respect to the selection of software and equipment vendors are left entirely to the air carrier. However, the FAA may assess, for the initial plan and any subsequent revisions, whether the proposed products’ functionality appears to be adequate to accomplish the program’s goals.
(4) The FAA prefers to interact closely with applicants during the development of the I&O Plan, rather than to wait for the formal submittal of the finished plan before establishing substantive dialogue. A discussion and review of rough drafts of document sections early in the development process will facilitate approval. The submittal of the final documents then becomes a formality, with minimal changes required.
(5) To assist air carriers in developing their I&O Plans, a checklist of items to be included in the plan is provided in paragraph 9a(3). Paragraph 9a(4) contains a sample I&O Plan template. Although specific areas should be addressed in the plan, the I&O Plan template is flexible enough to allow the air carrier to tailor the plan to its individual needs.
b. FAA Approval.
(1) Operators seeking approval of a FOQA I&O Plan should submit the plan and a completed I&O Plan checklist to the FAA. The checklist should be used as an aid to see that all required material is included in the plan. The submittal should include a cover letter addressed to the air carrier’s assigned Principal Operations Inspector (POI) that requests approval of the plan.
A copy of the cover letter, plan, and checklist should be sent simultaneously to HQ FAA, Attn:
AFS-230. Electronic transmission of this documentation to AFS-230, Volunteer Safety Program Branch, is encouraged (for which purpose signatures are not required).
(2) The FAA will evaluate the I&O Plan based on the adequacy of the proposed means and methods identified for the collection and analysis of data, as well as procedures for taking corrective actions. The joint evaluation by AFS-230 and the POI will allow the FAA to maintain standardization and continuity throughout the industry while accommodating carrier-specific organization and resource differences best understood by the POI.
(3) The POI and AFS-230 will review the proposed I&O Plan and establish a consensus as to whether the plan should be approved. The FAA procedures for I&O Plan approval are contained in FAA Order 8400.10, Air Transportation Operations Inspector’s Handbook.
AFS-230 and the POI will communicate any plan inadequacies to the air carrier in writing.
Similarly, once AFS-230 and the POI concur that the plan should be approved, the air carrier will receive an approval letter with the signatures of the POI and the manager of AFS-230. Once Page 22 Par 9
an I&O Plan is approved by the FAA, the air carrier’s FOQA program may continue for an indefinite period, unless the carrier elects to terminate the FOQA program or the FAA withdraws its approval.
(4) The I&O Plan is a “living document” and should be updated as necessary. Changes will occur in the FOQA program as an air carrier assimilates new technologies, adds new fleets, modifies event definitions, and changes structures to meet its program’s growing needs. Changes are likely to be particularly frequent during the early stages of an operator’s FOQA program.
When changes occur to previously approved I&O Plan content, the I&O Plan should be revised to incorporate those changes.
(5) A revision control methodology should be established for the I&O Plan (and any subsequent revisions) and included in the I&O Plan. A list of affected pages, or a revision control page that identifies the pages to be added/removed/replaced, should be submitted with any revised pages. Each revised page should contain the page number, revision number, and revision date. Revisions to the I&O Plan are required whenever changes occur to the nature of the FOQA program (e.g., changes to fleet composition, system configuration, flight operating procedures, organizational structure, schedule, and key milestones).
(6) Revisions to approved I&O Plans do not require FAA letters of approval. Because such changes can be potentially frequent and voluminous, revisions to approved plans will be considered to be accepted by the FAA, unless the FAA notifies the carrier in writing within 45 days of revision submittal that the revision is not accepted, except as follows: notwithstanding this 45 day period, if at any time the FAA discovers that the content of a FOQA I&O Plan is not consistent with section 13.401, or is otherwise unacceptable to the FAA, the FAA may notify the operator that revisions are required in order to maintain program approval. In addition to the POI, AFS-230 should be provided with an information copy of all revisions. The POI may permit an air carrier to consolidate and submit revisions on a quarterly basis throughout the calendar year, rather than submit each revision as it occurs. The air carrier should request this authority from the POI. This procedure is intended to reduce workload for the air carrier and FAA.
(7) FOQA is a voluntary program, and the air carrier may elect at any time to terminate its program. The FAA may also elect at any time to withdraw approval of an air carrier’s I&O Plan for failure to comply with the requirements of section 13.410. The protections from civil enforcement actions are predicated upon the expectation that the operator will act upon FOQA information indicative of an adverse safety trend or a continuing violation. If the FAA determines that insufficient effort to develop or implement a plan of corrective action is taking place, and the air carrier is not responsive to FAA efforts to elicit compliance with this requirement, withdrawal of program approval may be appropriate. Withdrawal of FAA approval of the I&O Plan will be transmitted, in writing, to the air carrier.
c. I&O Plan—Topics. The following topics should be included in an I&O Plan:
(1) Background. This section summarizes the foundation and relevant FAA references for FOQA programs.
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(2) Introduction. The introduction section should state the goals and objectives of the airline’s FOQA program.
(3) FOQA Program Stakeholders. This section should identify the key stakeholders in the FOQA program. There may also be stakeholders outside the company that should be identified here.
(4) Protective Provisions, Pilot Association Agreement (if Applicable), and Corporate Policy Statement. Summarize the salient points of the protective provisions that the airline and its pilots are afforded from FAA certificate action or civil penalties from information and data collected and analyzed by the FOQA program. In addition, the protective provisions from the pilots association agreement should be summarized. Provide a copy of the agreement in Appendix 1 of the I&O Plan. If a pilot association agreement is not applicable to the airline, a corporate policy statement should be included in the I&O Plan that establishes protective provisions to its pilots against disciplinary or other pejorative action from the airline from data or information produced by the FOQA program.
(5) Data Protective Provisions and Security.
(a) In this section, include a summary of the protective provisions to be incorporated into the FOQA program that will gain acceptance by all participants, including the pilot association (if applicable).
(b) Describe the pilot association agreement (if applicable) as it pertains to individual protection and data usage. At a minimum, discuss the following security considerations:
• The team member(s) responsible for data protection and security
• Data protection methods (including those provided by the GDRAS, physical security of FOQA media and facilities and information dissemination safeguards, etc.)
• De-identification requirements and procedures
• Methods for ensuring confidentiality
• Data retention policies and procedures
• Data storage policies and procedures
• Procedures for auditing and refining the security policy, methods, and procedures
(6) FOQA Program Components. Describe the specific technology components proposed for use in the FOQA program. The I&O Plan will need to be amended when changes or additions to the fleet types or changes to other technology components are made in the airline’s FOQA program. Program components described should include the following:
(a) Aircraft Fleet. Describe the following:
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• How the initial aircraft fleet(s) were selected for participation in the FOQA program
• Number of parameters to be collected from each fleet
• Future plans for program expansion to additional fleets and aircraft within the current fleet
(b) Airborne Data Acquisition System. Describe the selection criteria and product selection process.
• What technical criteria were evaluated (recording capacity, media handling, and download capabilities)?
• How were service and support considered (warranty, repair station locations )?
• What compatibility issues with existing systems were raised (power considerations, size, weight)?
(c) Describe the airborne system configuration and provide information concerning the following:
• Strategy for acquiring airborne data
• Equipment to be installed in the aircraft (including vendor, part number, and other pertinent information) and the technology to be used
• Availability of the STC for each component installed on the aircraft or the plan for obtaining an STC
• Method used for loading and maintaining the LFL
• Fleet installation plan, including equipment installation requirements and schedule
• Support to be provided by the vendor (including a description of repair facilities and warranty policies)
(7) Airborne System Maintenance and Support. Describe whose responsibility it is within the operator to maintain the airborne acquisition and recording system, including parameter maps and configuration. This should also include interface between the FOQA FMT and the responsible party.
(8) GDRAS. Describe the GDRAS selection criteria and product selection process.
Describe the GDRAS to be used for the FOQA program, including:
• Specify the vendor, product name, hardware, software, operating system configuration, and communication network
• Summarize the proposed GDRAS’s functionality
• Describe vendor support and training
• Specify how LFLs, events, and parameters are defined, configured, and maintained
• Describe user configuration capabilities Par 9 Page 25
• Describe how the system complies with de-identification and security requirements defined by the air carrier and pilot association
(9) Other Equipment. Describe any other FOQA components, such as:
• Software for trend analysis, statistical analysis, and flight animation
• Remote data collection systems and communication infrastructure, as applicable
• The vendor, product name, and associated hardware, software, communication, and operating system requirements
• The selection criteria and product selection process
(10) Equipment Upgrade, Modification, or Replacement. Describe the procedures, including criteria, which will be used for upgrading, modifying, or replacing the FOQA program components once those components have been approved for use.
(11) FOQA Organization. This section explains the context of the FOQA program within the air carrier’s departmental settings and the individuals who will serve on the FOQA program team. The following subsections contain topics that should be incorporated into the I&O Plan:
(a) Organization Structure. Describe the following:
• The organization and management of the FOQA program, including the organizational entity responsible for the FOQA program
• Any oversight body (such as a steering committee or FOQA committee), including information on membership, charter, duties, meeting schedule.
• Provide an organizational chart that illustrates the organization and management structure of the FOQA program
(b) Personnel. Describe the skills, knowledge, duties, and responsibilities of the following anticipated key personnel associated with the FOQA program:
• Person providing corporate oversight
• FOQA manager
• Gatekeepers
• FOQA analyst
• FOQA intern, if applicable
• Members of the FMT, along with any other committees in the organizational structure
(12) FOQA Program Implementation.
(a) Describe the air carrier’s concept of the FOQA program. Include operational procedures for:
• Data processing and analysis Page 26 Par 9
• Investigating results
• Determining corrective actions to be taken for significant events
• Communicating findings to all effected stakeholders
• Obtaining feedback and follow-up for corrective actions
• Data trending
• Generating periodic reports
• Providing local FAA with aggregate FOQA information on the operator’s premises
(b) The FOQA Implementation Process. Describe the following:
1 Schedule and timeline for FOQA implementation, including required resources.
2 Training that will be provided to team members and key stakeholders.
3 Location of FOQA facilities, including central processing and any remote sites.
4 Program startup criteria, including milestones (e.g. on system training, education, infrastructure, data validation) that should be met before collected data are used for analysis of line operations. If a user needs assessment has been conducted, summarize the methods used, users interviewed, and results.
NOTE: When developing a schedul ed timeline for starting a FOQA program, many of these tasks may require considerable time for completion
(i.e., beyond the month in w hich they are listed as occurring) and that preliminary w ork will have commenced on these tasks prior to w here they appear on the checklist. Obtaining financial approvals and commitments for equipment expenditures and perso nnel, contracting for equipment purchases, and delivery of equipment may all have very long lead times.
(13) Education and training. Describe the following:
• How officers, senior management, team members, and stakeholders will be educated about the FOQA program
• How pilots will be educated about the program
• How team members will be trained
(14) Data Analysis Procedures.
(a) Data Usage and Management. Describe the anticipated usage of FOQA data for safety, operations, training, and maintenance/engineering. Also describe the framework/technology architecture that will be used for managing the data.
(b) Flight Data Collection and Analysis. Describe the following:
• Procedures for the physical retrieval of data from aircraft Par 9 Page 27
• Procedures for transferring data from airborne systems to the GDRAS, including media logistics and schedule for data retrieval
• Manual and automated methods to verify the quality and integrity of collected data, including any data quality standards
• Methods for logging and tracking airborne-collected data
• Procedures for handling invalid data and diagnosing airborne equipment problems
• Include a process flow diagram that shows the transit and direction of FOQA data through the system, including key systems, entities, and decision points
(c) Data Classifications and Definitions. Describe the following:
• Team member(s) involved in developing the event set
• Methods used to develop the event set
• Source documents
• Event categories, classifications, and severity levels
NOTE: Provide initial event set cla ssifications by operational mode in Appendix B.
(d) Data Definition Maintenance.
1 Describe how event definitions will be validated, reviewed, and defined by the FMT. The following boilerplate can be used as a baseline, but should be modified, as appropriate, to the air carrier’s specific situation:
NOTE: Documentation of event definiti on, validation, and modification w ill be maintained in the FOQA office and will be made available on request.
2 Also, describe the following:
• Procedures for validating, reviewing, and refining event definitions
• Procedures for creating and verifying new events
• Procedures for tracking modifications to event definitions
(e) Data Review and Evaluation. Describe the following:
• Procedures for periodic review of FOQA event data and trends, including personnel responsible and proposed schedule for review of data and trends
• Procedures for joint FAA/air carrier periodic review of aggregate trend data
• Procedures for notifying appropriate personnel (e.g., flightcrews, engineering/maintenance, and training) about events requiring immediate action
• Processes for maintaining event information for trend analysis, including databases and methods to have invalid events and associated data removed Page 28 Par 9
• Procedures for generating periodic reports to convey FOQA trends and findings
• Methods for detecting and analyzing data trends
• Procedures for crew contact and follow-up
• Procedures for determining corrective actions to be taken for identified events and/or trends
• Methods for obtaining feedback/follow-up for resolution
(f) Data Trending and Record Retention. Describe the following:
• The data retention policy for FOQA data and trend analyses, which should include requirements by maintenance to satisfy manufacturer warranty claims
• Archiving procedures and process for archiving and retrieval of archived data
(15) Program and Data Documentation. Describe how this I&O Plan will be maintained, who the review process will involve, how changes will be tracked, and how revisions will be submitted to the FAA. With the approval of the POI, the air carrier may submit quarterly updates of the I&O Plan to reflect changes that were made during the preceding quarter.
(a) Operational Development. Describe the overall development of FOQA program documentation in support of the program in cases of personnel transitions or program changes.
(b) Information and Data Control. Describe how changes to the FOQA Program will be documented. This should include the following:
• A description of the identified use
• Analysis that was accomplished
• Specific corrective actions or recommendations taken or made
• Personnel who were notified
• Resolution of actions or recommendations
(c) I&O Plan Revision Control. A revision control methodology should be incorporated into the I&O plan. This revision control methodology should include controls for page revisions, deletions, or replacements. The I&O Plan should also stipulate that the operator will submit all revisions to the POI and AFS-230.
(16) FAA Access.
(a) Procedures for joint FAA/air carrier periodic reviews of FOQA program effectiveness.
(b) Procedures for the operator's handling and marking of company proprietary and confidential information submitted to the FAA.
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(17) I&O Appendices.
(a) Appendix I (Pilot Association Agreement, if Applicable). If the implementation of the FOQA program depends on obtaining a signed pilot association agreement, insert the agreement or side letter in this section. The agreement should describe how the pilot association will be involved in the operation of the FOQA program.
(b) Appendix II (Event Parameters and Definitions). This appendix should contain list of events and minimum parameters to be monitored and analyzed in a basic FOQA program. When establishing a new FOQA program, the events and parameters in this appendix should provide a good starting point. Note that there are many more parameters available for recording on modern aircraft than are listed in the appendix. Although many such parameters are not used in FOQA event creation, they can be useful to develop a more complete understanding of the causes of events and for aircraft maintenance troubleshooting purposes. Following initial establishment and validation of its program, operators are encouraged to consider expanding upon the basic parameter list provided in this appendix. Ideally, the aircraft fleet initially involved in starting a FOQA program should have a data bus capable of supplying the parameters listed in this appendix and a means of capturing and recording those parameters. It is important to understand, however, that the list of available parameters on any given aircraft will be a result of those provided by the airframe manufacturer, ordered by the air carrier, or a combination of both.
1 Event Selection. Depending on the GDRAS used, selecting events to be included and analyzed can be simple or complex. Developing a list of events from scratch can be extremely time-consuming, particularly during event validation. GDRAS vendors can also create and deliver event sets, but this may entail considerable expense. If an event list is available from another carrier or the list contained in this appendix is adequate, then the event selection process will be relatively simple and much less expensive.
NOTE: The event list should be ta ilored to the specific air carrier and aircraft type. The parameters used to me asure the event need to be recorded on that aircraft type. Next, the tolerances that trigger the events should be set to account for applicable federal regulations, aircraft limitations, and company policies and procedures. The FMT and FOQA analyst should w ork together to evaluate and adjust event triggers. Since maintenance w ill also be an important stakeholder, creating events that maintenance w ould be interested in analyzing would be advantageous.
2 Event Standardization.
(aa) If an operator has multiple aircraft type or model variance within its fleet, attempting to standardize events within the GDRAS analysis function may be advantageous. Numerous events will be common to all types and models of aircraft in an air carrier’s fleet (e.g., VMO, MMO, and VLE exceedences). These “common” events can be monitored and analyzed across fleets. However, there will be differences in the triggering limits, which will Page 30 Par 9