Appendix A
A-6
A.6 STAGE 4: Written Report Review by the FAA. The FAA will review the information submitted in Stage 3 and work with the operator to ensure that they have identified any root causes and systemic issues which led to the apparent violation. In this stage, the PHI is also tasked with completing a:
A.6.1 Risk Assessment Matrix to aid in evaluating the significance of the event, and the proposed comprehensive fix. This collaboration helps to ensure that the corrective actions contained in the comprehensive fix are acceptable to the FAA.
Note: If investigation of the apparent violation results in the determination that no violation has occurred, the voluntary disclosure may be closed by rescinding the file and providing an explanation in the provided comment box. When the user selects rescind, a warning is provided that rescinding the file will close the case and terminate the investigation. If the PHI confirms the rescission, the case is closed in VDRP on that date.
A.7 STAGE 5: Implementation of a Comprehensive Fix and FAA Surveillance.
A.7.1 Implementation Period. The implementation period begins when the FAA concurs with the operator’s comprehensive fix. The operator will make changes to the proposed comprehensive fix when the operator or the FAA identifies a need for change. During the implementation period, the FAA and the operator will continue to collaborate, communicate, and cooperate in order to ensure the completion of each of the corrective actions as well as the self-audit. The FAA may advise and assist the operator in correcting any identified systemic problems. Changes will be made to the proposed comprehensive fix when the need is identified. Upon determining that the initial implementation of the proposed comprehensive fix is satisfactory, the PHI may advance the voluntary disclosure to Stage 6.
A.7.2 Corrective Actions. The FAA monitors the implementation of the corrective actions.
The FAA assesses the operator’s corrective efforts through the implementation period.
If, during this period, the FAA determines that the actions taken by the operator are not those documented in the comprehensive fix, or that the operator failed to take corrective action satisfactory to the FAA, the voluntary disclosure report may be rejected, and appropriate FAA action initiated.
A.7.3 Self-Audit Completed by the Operator. The operator must complete at least one satisfactory self-audit after implementation of the corrective action in accordance with their corrective action plan submitted in their written report. This report must be uploaded into the web-based VDRP system.
A.8 STAGE 6: FAA Review of Completed Actions of the Corrective Action Plan. At the conclusion of the implementation period, the PHI will make the final assessment.
Consultation with regional specialists, enforcement counsel, or other FAA personnel may be deemed appropriate by the PHI or AXH.
Appendix A
A-7
A.8.1 Stage 6 Completion. If all elements of the comprehensive fix have been satisfactorily accomplished, including the operator’s self-audit and FAA verification that all requirements have been completed, then the PHI will submit the required entries in the web-based application for Stage 6 completion.
A.8.2 Stage 6 Submission. Upon Stage 6 submission by the PHI, the VDRP system will notify AXH via email that the file is awaiting management review. AXH will review the VDRP file, and assess the adequacy of the comprehensive fix and its implementation. AXH must decide whether to concur with the PHI’s determination that the comprehensive fix was satisfactorily accomplished.
A.8.3 A XH Concurrence. AXH concurrence with the PHI’s determination is recorded when the “Submit” button is selected. This closes the submission and concludes Stage 6.
Upon closure, an email is sent to the appropriate parties advising them that the submission is closed.
A.8.4 A XH Non-Concurrence. If AXH does not concur with the PHI’s determination, AXH will select the “Return” button to refer the case back to the PHI, along with comments, for reconsideration. The case will not advance out of Stage 6 until it is re-submitted by the PHI, and AXH submits their concurrence.