Appendix A APPENDIX A. EXAMPLE OF A FOQA IMPLEMENTATION AND
OPERATIONS PLAN
This section contains an example of an Implementation and Operations (I&O) Plan. Section numbering and section names in this example are suggestions only. They represent the topics that should be included in the I&O Plan. The text of this example is boilerplate content only.
It should be used as a baseline and modified accordingly. Instances of [Airline Name] should be replaced with the name of the actual air carrier or operator. Name references to particular equipment should also be modified appropriately.
1. BACKGROUND
Flight Operational Quality Assurance (FOQA) is defined as a program to improve flight safety by providing more information about, and greater insight into, the total flight operations environment through selective automated recording and analysis of data generated during flight operations. Analysis of FOQA data can reveal situations that require improved operating, training, and maintenance procedures, practices, equipment, and infrastructure.
In support of the public safety objective, the FAA has publicly endorsed the development and implementation of voluntary FOQA programs as a tool for continuously monitoring and evaluating operational practices and procedures. In Advisory Circular (AC) 120-59 (as amended), Air Carrier Internal Evaluation Programs, the FAA states, “public safety is enhanced if deficiencies are identified and immediately corrected when they are discovered by the certificate holder rather than when they are discovered by the FAA.” FOQA programs can provide the quantitative and objective information needed to identify deficiencies during the certificate holder’s internal audit and evaluation process.
FOQA programs are based on the premise that air carriers have primary responsibility for continuously monitoring and ensuring that their operations are safe and in compliance with their operating standards and the regulations. A FOQA program will assist [Airline Name] in identifying and addressing operational deficiencies and trends that are not generally detectable with other procedures. Additionally, analysis of some FOQA program data may contribute to improved safety and efficiency in the design and operations of air traffic control (ATC) systems, aircraft, and airports. Many potential applications of FOQA data have been identified to date.
These applications aim to improve safety, evaluate and enhance training practices, revise operating procedures, assist aircraft engineering programs, improve maintenance efficiency, and assist manufacturers in aircraft design and modification.
Several foreign air carriers have successfully implemented FOQA-type programs that use flightrecorded data to improve operational safety and performance. Lengthy track records in effective usage of this information (over 20 years in the cases of British Airways and Scandinavian Airlines System) have provided foreign carriers with clear evidence that FOQA program data represent a source of valuable information that, when used appropriately, can contribute greatly Page 1
Appendix A to aviation safety. Airlines that currently have FOQA-type programs agree that the insights derived from these programs have prevented serious incidents and accidents and have led to improved operating efficiencies.
FOQA information can be included in the voluntary audits and evaluations described in AC 120-59 to determine the causes of deficiencies and to suggest enhancements to operating practices. Title 14 of the Code of Federal Regulations (14 CFR) part 13 states the conditions under which information obtained from an approved voluntary FOQA program will not be used in legal enforcement actions against an operator or its employees. In addition, 14 CFR part 193 contains provisions for certain protection from public disclosure of voluntarily submitted safety related information, when such information has been designated by an FAA order as protected from disclosure under that part.
2. INTRODUCTION
The I&O Plan presented in this document specifies the organization, technology, policies, procedures, and operational processes used in the [Airline Name] FOQA program.
The core objective and intent of the [Airline Name] FOQA program is to facilitate the free flow of safety information. The FOQA program will:
1. Collect operational flight data.
2. Develop methods to analyze the collected flight data, such as triggered events and routine operational measurements.
3. Establish procedures for comparing the collected data with established procedures and standards and the use of analyzed data in formal awareness and feedback programs to enhance safety in the following areas:
a. Flight procedures
b. Flight training procedures and qualification standards
c. Crew performance in all phases of flight
d. Air traffic control procedures
e. Aircraft maintenance and engineering programs
f. Aircraft and airport design and maintenance
4. Perform trend analyses of FOQA data to identify potential problem areas, evaluate corrective actions, and measure performance over time.
3. FOQA PROGRAM STAKEHOLDERS
The FOQA program will provide large amounts of previously unavailable data to significantly improve the problem definition process and allow assessment and resolution of systemic safety and efficiency issues. Beneficiaries or stakeholders within [Airline Name] include, but are not limited to, the following:
Appendix A
1. Flight Safety
2. Flight Training and Standards
3. Flight Operations
4. Maintenance and Engineering
5. Operations Control and Dispatch
6. Pilot Association
Cooperation with stakeholders outside of [Airline Name] will also benefit the [Airline Name] FOQA Program. These stakeholders may include, but are not limited to, the following:
1. FAA
2. NASA
3. ATC
4. Aircraft manufacturers
5. Other industry safety groups.
4. PROTECTIVE PROVISIONS, PILOT ASSOCIATION AGREEMENT (IF
APPLICABLE), AND CORPORATE POLICY STATEMENT
Key to the success of the [Airline Name] are specific protective provisions that will protect both [Airline Name] and its employees from FAA certificate action or civil penalties as a result of information and data that are collected and analyzed by the FOQA program. In establishing these protective provisions, [Airline Name] has pursued the following distinct courses of action.
[Airline Name] has established a corporate policy endorsed by senior management providing that no pilot shall ever be subject to disciplinary or other pejorative action by [Airline Name] from data or information that is produced by the FOQA program, and [Airline Name] has formalized that policy in a FOQA agreement that has been negotiated and accepted by the [Airline Name] Pilot Association [If applicable]. [Airline Name] will establish procedures for sharing of FOQA trend analysis and other pertinent de-identified data with the FAA, as specified in this I&O Plan.
These actions are intended to create a framework of cooperation between the Pilot Association [if applicable], the FAA, and [Airline Name] that will permit the most effective use and analysis of FOQA data.
5. DATA PROTECTIVE PROVISIONS AND SECURITY
General Key areas that were considered in developing the protective provisions for the FOQA program include:
Appendix A
1. Confidentiality⎯Provides that the identity of individual crewmembers cannot be associated with any FOQA data, except for the purposes of crew-contact as provided for in this I&O Plan.
1. Anonymity⎯Provides that any identification of airline flight and/or flightcrews with specific FOQA flight data necessary during an analysis is eliminated permanently at the earliest possible time and in accordance with the pilot association agreement.
2. Data access and control⎯Identifies data that require protection and assigns overall responsibility for data protection. In addition, data access and control provides guidelines and procedures to protect data; provides authorized access to data, data processing and storage locations; provides authorized access to reports and other data outputs, and requires the destruction of data after the retention period has expired.
3. FOQA facilities⎯Provides secure, controlled access facilities for all systems, offices, equipment, workstations, computers, and peripherals associated with the FOQA program.
Additionally, secure systems will also be provided for storage of all FOQA-related materials, including paper, media, and backup devices.
FAA FOQA Enforcement Policy
The [Airline Name] FOQA Program incorporates the protections codified in the FOQA Rule, part 13, section 13.401, which states that except for deliberate or criminal acts, the Administrator will not use [Airline Name]'s FOQA data or aggregate FOQA data in an enforcement action against [Airline Name] or its employees when such FOQA data or aggregate FOQA data is obtained from a FOQA program that is approved by the Administrator.
Legislation In the Federal Aviation Reauthorization Act of 1996, Congress included specific provisions pertinent to the public release of safety-related information that was voluntarily submitted to the FAA. Specifically, the Reauthorization Act added a new section—49 U.S.C. § 40123—to the FAA’s governing statute to protect voluntarily submitted information from disclosure if the Administrator finds that (1) the disclosure of the information would inhibit the voluntary provision of that type of information and that the receipt of that type of information aids in fulfilling the Administrator's safety and security responsibilities; and (2) withholding such information from disclosure would be consistent with the Administrator's safety and security responsibilities.
The Administrator has issued a rule, 14 CFR part 193, which accomplishes the purposes set forth in this legislation. This rule describes the provisions for designating information that would be protected. Information collected under an FAA-approved voluntary FOQA program has been designated by FAA Order 8000.81 as coming under the provisions of this rule.
Appendix A
6. FOQA PROGRAM COMPONENTS
The principal components that will compose the FOQA program at [Airline Name] are described below and are illustrated in Figure 1.
Aircraft Fleet
The [Aircraft Model/Type] aircraft will be the launch aircraft for the [Airline Name] FOQA program. Twenty of these aircraft will be used to initiate the FOQA program. These aircraft will be equipped with the [Product Name] Flight Data Acquisition Management System on a schedule established by [Airline Name] Maintenance and Engineering. Additional aircraft will be added to the FOQA program pending approval from the FOQA Monitoring Team (FMT) as sufficient experience is gained on data acquisition and analysis.
Airborne Data Acquisition System
[Airline Name] will be utilizing the [Product Name] Quick Access Recorder. This recorder collects continuous flight data parameters and stores this information on the [Specify Storage Media, e.g., PCMCIA card].
Data Download and Airborne System Maintenance and Support
The Flight Data Acquisition Management System and Quick Access Recorder will be maintained per the FAA-approved [Airline Name] aircraft maintenance program. Avionics Engineering will be responsible for managing this process. The [Storage Media] will be downloaded [specify frequency] by means of [Specify Downloading Methodology, e.g., removal and replacement of PCMCIA cards]. The FOQA Manager will be responsible for coordinating maintenance issues with [Airline Name] Avionics Engineering regarding data download and any Flight Data Acquisition Management System problems discovered during data analysis.
Ground Data Replay and Analysis System (GDRAS)
The GDRAS is designed to process and analyze data from all FOQA-equipped aircraft in the [Airline Name] fleet. It will apply protective mechanisms, including removal of identifying information in accordance with the provisions described in the previous sections. The GDRAS will also include trend analysis capabilities to explore historical data and analyze similar event data from past flights to determine if any patterns exist or if further study is warranted.
Appendix A Other Equipment
[Airline Name] will be investigating several other components to incorporate into the FOQA program as the technology becomes available and requirements are identified and refined. The addition of these components is subject to approval by the FMT.
FIGURE 1. FOQA SYSTEM ARCHITECTURE
F D R ( F lig h t Da ta Re c o r d e r) H a n d - h e ld Do wl o a d U n it RDS ( R e m o te Da ta S y s te m ) (L oc at io n) EM S W o rk s ta tio nE M S W o r kst a tio n EM S W o rk s ta tio n F D W (F ligh t D a ta W a r e ho us e A irc ra ft F O Q A D a ta M O Q A D a tafile f o r m a t: .p c r , .u c rS e r ia l C o n n e c t io n Da ta C e n te r FD A P O ff ic e Ma in te n a n c e P C fo r S W I S o ftw a re F D A P (F lig h t D a ta A n a ly s is P r o g r a m ) - A r ch itec tu r e
PC M C IA D F D A U ( D ig it a l F lig h t D a ta A c q u is itio n U n it) F A A D a t a w ith in c r e a s e d u p d a te r a t e F A A S p e c ific D a ta C D S ( C o m m u ni c a tion S e rv e r ) A C M S (A ir c raf t C o ndi tion in g M o n ito r in g S y s tem ) A P M ( A ut om at ed P a r a m e te r M e as ur e m ent ) T e rm in al S e rv er E M S E v en t M e as ur e m en t S y s te m ) S e rv e r s Replicated Data
Appendix A Equipment Upgrade, Modification, or Replacement
The equipment used initially in the FOQA program, including airborne and ground systems, may be upgraded, modified, or replaced with equipment from the same or a different vendor that will provide comparable or superior functionality to the equipment described in this section.
Documentation of such changes in airborne or ground systems will be maintained in the FOQA office and will be made available to the FAA on request. This I&O plan will be revised and submitted to the FAA whenever changes to airborne or ground-based systems are made.
7. FOQA ORGANIZATION
Organizational Structure
The [Airline Name] FOQA organization structure is illustrated in Figure 2:
Personnel The FOQA Program will consist of the following personnel:
1. FOQA Steering Committee The FOQA Steering Committee is chaired by the Director of Flight Safety and serves as the advisory group for the FOQA program. Members of this committee include the Vice President of Flight Operations, the Pilot Association Air Safety Chairman, Director of Maintenance, and the Director of Flight Training.
2. FOQA Program Manager The FOQA Program Manager is responsible for the overall management, administration, security, and maintenance of the FOQA program. These duties include interfacing with the FAA, vendors, and other entities. The program manager’s primary duties include addressing the FOQA data needs and reporting requirements of Flight Operations, Training, and Safety departments (and any other stakeholders).
3. FMT The FMT is chaired by the FOQA Program Manager. The FMT meets once per month to conduct reviews of aggregate trend data to identify recommendations to stakeholders.
4. FOQA Gatekeeper (s) [or Pilot Association Gatekeeper(s), if applicable] The FOQA Gatekeeper(s) [or Pilot Association Gatekeeper(s), if applicable] will have access to identifying data, [in accordance with the Pilot Association agreement, if applicable]. The gatekeeper will manage password selection and maintenance, control access to identifying data, and perform any necessary crew contacts.
Appendix A
FIGURE 2. FOQA ORGANIZATIONAL STRUCTURE
FOQA Steering Committee FOQA Program Manager Pilot Association Gatekeeper FOQA Monitoring Team FOQA Analyst Flight Training Flight Standards Flight Safety Maintenance Engineering Flight Operations
Appendix A
5. FOQA Analyst The FOQA analyst will assist the FOQA Manager and is responsible for the day-to-day operations of the FOQA GDRAS, generating GDRAS-related reports, and assisting the FMT in reviewing and analyzing data.
8. FOQA PROGRAM IMPLEMENTATION
Program Startup Criteria
The startup criteria for the program will be defined by the FMT and will include, but not be limited to:
• Completion of installation and testing of airborne equipment and GDRAS
• Successful testing of the complete data analysis system
• Validation of flight parameters
• Validation of data collection system from the recording media to the GDRAS
• Implementation of all data de-identification, protection, security, and retention procedures
• Education of pilots and stakeholders
• Training for FOQA team members
• Specification and validation of event and definitions and operational measurements
• Implementation of procedures to detect and analyze triggered events and operational measurements
• Implementation of procedures to identify and track corrective actions
The FMT will make the decision regarding when the established criteria are met. Once the FMT determines a formal start date, any data collected before the formal start date must be reanalyzed prior to retention in the FOQA database in order to assure that all reported events are valid.
FOQA Implementation Schedule
Table 1 below identifies the FOQA implementation schedule, timelines, and milestones.
TABLE 1. FOQA TIMELINE Month Task Month 1 1. Coordinate airborne technology requirements, particularly data maps and LFLs, with maintenance/engineering.
2. Acquire airborne data acquisition/recording equipment for aircraft.
3. Coordinate with maintenance/engineering for installation of equipment in aircraft.
4. Evaluate GDRAS products, including on-site system trials.
5. Coordinate with corporate information technology personnel for integration Page 9
Appendix A TABLE 1. FOQA TIMELINE Month Task with or installation of any communication networks, compliance with computer-related standards, review of vendor maintenance contracts, and any other assistance required.
6. Begin education program for company officers and management personnel regarding FOQA benefits.
7. Begin periodic FMT meetings to assist in GDRAS evaluation.
8. Meet with stakeholders to review current requirements and to define any additional requirements.
9. Generate pilot education materials in conjunction with the pilot association.
10. Refine program start-up criteria.
Month 2 11. Convene FMT to review and refine event definitions.
12. Continue development of pilot educational materials.
13. Develop equipment acceptance criteria with FMT, FOQA Analyst, and associated vendor(s).
14. Select and acquire GDRAS hardware, software, and peripherals and coordinate product support and any integration with corporate communications infrastructure.
15. Coordinate with vendors and maintenance/engineering to determine procedures and resources required for retrieving airborne data and transferring to FOQA facility.
16. Establish interface with maintenance/engineering for addressing FOQA issues.
17. Coordinate with GDRAS vendor to define periodic reporting capabilities and formats.
18. Refine methods for retrieving data collected on aircraft.
19. Refine I&O Plan and submit to AFS-230 and POI for approval.
20. Develop and issue maintenance work cards/bulletins for data retrieval procedures.
21. Develop methods for tracking receipt and auditing quality of aircraftrecorded data.
22. Define data backup, retention, and archiving policies.
23. Develop guidelines for crew contact.
Month 3 24. Acquire/install computer, communications infrastructure, and operating system for GDRAS and other ground and communication equipment.
25. Integrate GDRAS with corporate communications infrastructure as appropriate.
26. Obtain and attend GDRAS vendor training for FOQA team members.
27. Develop and implement security policy and procedures.
28. Continue pilot education process.
Appendix A TABLE 1. FOQA TIMELINE Month Task
29. Evaluate GDRAS reporting capabilities using initial data and coordinate with GDRAS vendor to obtain modifications, if required.
30. Implement maintenance procedures for routine retrieval of data from aircraft.
31. Analyze and validate initial data to confirm proper operation of airborne equipment and GDRAS.
32. Establish vendor problem reporting and tracking system for FOQA equipment and software.
Month 4 33. Formalize and document procedures for event review, evaluation, and follow-up.
34. Generate stakeholder education materials.
35. Educate POI regarding the specifics of the FOQA program.
36. Continue pilot education process.
37. Refine and test parameter conversions.
38. Refine and test event definitions.
39. Review equipment acceptance criteria and resolve outstanding issues with vendors.
40. Verify GDRAS and system components compliance with data security and de-identification procedures.
Month 5 41. Continue development of parameter specifications.
42. Continue development of event definitions.
43. Define and document procedures for transferring to maintenance/engineering any maintenance-related events captured by FOQA data.
44. Continue pilot education process.
45. Modify the I&O Plan as appropriate and submit revisions to the FAA.
46. Determine and review format for trend and summary reports.
47. Establish procedures to validate data and events and in the review and evaluation of trend and summary reports.
48. Establish procedures for defining and implementing corrective actions, and tracking their efficacy.
Month 6 49. Test all aspects of the data collection, transmittal, and analysis system.
50. Continue data validation.
51. Implement data retention policies.
52. Review start-up criteria.
53. Implement procedures for system and data back-up and archiving.
54. Finalize trend analysis procedures.
55. Define schedule and milestones for formal start-up and entry into continuing operations.
56. Develop procedures for maintaining I&O plan revisions.
57. Implement stakeholder feedback mechanisms.