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.
Appendix A TABLE 1. FOQA TIMELINE Month Task
58. Review FOQA data gathered prior to program’s official launch and determine how the data will be used based on the [Airline Name’s] data retention policy.
59. Continue pilot education process.
9. EDUCATION AND TRAINING
Pilot education about the [Airline Name] FOQA Program will be accomplished through quarterly Flight Operations publications, the Pilot Association publications, and a secure bulletin board at each crew base. These bulletin boards will highlight FOQA issues, including featured events or issues.
Each of the FOQA stakeholders will be provided with information about the FOQA program through reports generated from periodic FOQA meetings, bulletin boards, and an initial FOQA overview report that will be developed and distributed during the initial implementation of the FOQA program.
All FOQA personnel will receive training on the GDRAS software. Additionally, FOQA stakeholders will visit other operators with established FOQA programs. Other training will be provided as new hardware and/or software is added to the program.
10. DATA ANALYSIS PROCEDURES
Data Usage and Management
All processed FOQA data will be maintained by the GDRAS subject to periodic deletion as determined by the FOQA Steering Committee and in accordance with the [Airline Name] record retention policies.
The FMT will be responsible for developing reports summarizing the information obtained through the FOQA Program. The reports will include summaries of the most recent information obtained through the FOQA Program as well as trend information to demonstrate the effectiveness of prior corrective actions. These reports will be distributed to Flight Operations, Flight Training, Flight Safety, Maintenance Engineering, and other involved stakeholders on a regular basis. The FMT will solicit recommendations from the recipients of the reports in order to improve their usefulness as the program proceeds.
Flight Data Collection and Analysis
The manner in which FOQA data is processed is illustrated in Figure 3. Maintenance Engineering retrieves data from the aircraft and forwards it to the FOQA office. The ground Page 12
Appendix A analysis station will process the recorded flight data. Provisions for security and tracking of the media will be established through coordination between the FOQA Program Manager and the Maintenance Engineering.
Flight data will be processed by the FOQA Analyst to determine what occurred and whether the recorded information was legitimate. A preliminary analysis will use the GDRAS to interpret identified events or trends and determine whether the information was valid or invalid because of bad data, a faulty sensor, or some other invalidating factor. In the event that the data reveal a situation of immediate concern to Maintenance Engineering, the FOQA Program Manager will notify that department.
NOTE: Preliminary review of the data to assess validity must be completed within 7 business days from the time the data is received at the FOQA office. After 7 days, the data is permanently de-identified per FMT procedures and the Pilot Association agreement preventing the ability to contact flight crewmembers, if needed. Further analysis of the data received is accomplished in relation to existing aggregate information within the FOQA Program. Program trend reports of the aggregate data are developed by the FMT on a regular basis for presentation to stakeholders for use in developing corrective actions or for monitoring of operational issues.
Appendix A
FIGURE 3. FOQA DATA PROCESSING
Airborne Data Valid Data?
FOQA Monitoring Team Action/Feedback Crew Contact?
Gatekeeper/ Designated FOQA Team Member Stop Flight Crew Maintenance and Engineering FOQA Manager Safety, Operations, and Training Remove from FOQA Database No Yes NoYes De-identified Flight Data FOQA Database Secured Raw Data GDRAS