During HELI-EXPO ’22, HAI’s Director of Safety Chris Hill sat down with leaders from the Air Charter Safety Foundation to discuss the ACSF’s Aviation Safety Action Program (ASAP) for rotor wing operators.
In this video, you’ll hear from Bryan Burns, Frank Raymond and Bob Rufli as they explain the features and benefits of the non-punitive aviation safety reporting program. Plus, learn how to access a safety management system (SMS) at a low cost of entry.
Below is a modified transcript of the video:
Chris Hill:
We are here at HELI-EXPO ’22 to talk about the HAI’s Aviation Safety Action Program (ASAP). Joining me here are representatives from the Air Charter Safety Foundation (ACSF). Bryan, would you like to introduce your team?
Bryan Burns: Well, thank you, Chris, for inviting us to have this session. I’m Bryan Burns, the president of the Air Charter Safety Foundation and this is Frank Raymond, our Director of Safety and Bob Rufli, the chairman of the Air Charter Safety Foundation.
We just wanted to take a few minutes and explain what the Aviation Safety Action Program is all about. If you guys are familiar with that term, the acronym being ASAP.
ASAP is a voluntary safety reporting platform with immunity from the FAA. At the ACSF, we have worked very hard in the last 10 years or so with the fixed wing folks—both in Part 135 and Part 91—to get them on board. Today we have over 200 companies that we, at the Air Charter Safety Foundation, are third-party program managers of. This is a totally turnkey process where we set up the memorandum of understanding, and we work with you guys with your Event Review Committee.
When we first started this program, with fixed wing operators, there was a lot of hesitation. Because this is a true partnership with the FAA. And a lot of folks, as you may know, don’t have a lot of trust that this is full disclosure and transparent.
The relationship with the FAA that we have already worked with about 55 FSDOs in the nation. I think there’s like 75 or so. We’ve got those relationships already established with these 200 companies that we work with.
The point is that what we’re trying to introduce here today is trust us. And trust the FAA. They support it. They get it. They understand it. And it’s all about enhancement and improvement of your operation.
And one of the things we emphasize the most is that a lot of the reports we receive would have never ever been disclosed or discovered unless you were enrolled in the ASAP program. Because that immunity is important obviously. And that protection is why people are reporting safety issues that would go undiscovered or undisclosed.
With that said, I’ll turn it over to Frank, our director of safety. He is the ASAP program manager and he’s seen over a thousand reports come in this past year since he’s been with us. He can give you a little bit of background on the process and what it takes to enroll in the ASAP program.
Frank Raymond: Thank you for having us. At the ACSF, we’ve gotten over 1,400 reports last year from over 200 member companies, so we’re getting quite a few reports. Over 95 percent of those reports are what we call “sole source” events. Meaning that we wouldn’t have known about the event if it wasn’t for the ASAP reporting program. It’s a very powerful tool to give you a window into your operation.
I’m big proponent of the Program. I started ASAP programs for a Part 121 operation many, many years ago. Now I’ve come home to ACSF in the last year, and it’s been really great to see. And to Bryan’s point, I think that trust is the big piece. And that’s trust within the ERC. It’s trust with myself. An operator can call me up with a question and they know that they have that freedom to speak freely. We can have a very open discussion about the event. What we want to do with it. What issues may come out of it. And then that way when we go into the Event Review Committee meeting, we already kind of have a game plan of what we’re trying to accomplish. It’s very important to build that trust early because without it becomes a very difficult process to manage.
Chris: That’s a good start. So, Bob, you’re with an operator and you are on the board for the ACSF. As an operator, what’s some something you could share with the fellow operators that that can demonstrate the value of a program like this?
Bob Rufli: As Chris mentioned, I’m chairman of the board right now, but that’s a voluntary position so I’m only here for a while. I’m the vice president and director of operations for Pentastar Aviation out of Pontiac, Michigan.
The ASAP program is about getting information that you probably wouldn’t have known. Because your flight crews are a little cautious, unsure whether to report it or whether or not to. This really just opens up the opportunity to get that information on the table and do something about it.
It’s about getting it into your SMS program, about evaluating it, and fixing the problems.
I like to tell my pilots that you never make a mistake. You make a decision based on the information you’re given, the training you have, the experience you have, and the amount of time you have to make that decision. All we want to do is understand.
As we all know, hindsight is 20/20. If we can look back at that decision that you made, and find a way to give you more information, or train you better so that you’re better prepared, or give you more time—whatever those aspects are—that’s what ASAP is about. Tell us the challenges that you encounter.
The other important part is the ERC—the Event Review Committee. It’s made up of three individuals: the FAA, a management person (who has the responsibility to spend money for the company) and an employee rep.
ASAP works for pilots, mechanics, ground personnel and flight attendants. Now the FAA’s gotten broader with their ASAP program, and they have a category called “other.” It you have an interesting group of lift operators, you can add them into the program and begin to collect that information.
But no action is ever taken until there’s unanimous decision between those three individuals. And that’s a key to it. Everybody has to agree. The FAA, the management, and the employee rep have to agree as to what the corrective action is.
It’s just really a good program in that it really brings out a lot of information that, as a company, you really aren’t aware sometimes of what’s going on out there.
Chris: Thanks, Bob. People could be a little bit intimidated by this ASAP thing and working with the FAA right out the gate. Some companies just haven’t even established a reporting program at all. It reminds me of when I would visit units and do some assessments.
I would talk to say a maintenance supervisor and they would talk about an issue that they had fixed. And they were very proud of that issue. But it was on one location and they had many different units across the country. And I said, “hey did you share that with the rest of the organization?” And this is just one organization. And they said, “No, we found the problem and we fixed it in house. Problem solved.”
Then I said, “Do you think there’s one other organization that just might be in the same set of circumstances, with the same hazard that, when left undetected, could cause a problem?” And then they scratch their head thinking, “that’s a good point.”
Now this is just talking about one organization. So, if you’re not reporting already and sharing within your organization, that certainly is the first step.
But then tell us a little bit about that process where somebody decides, “okay, I’m reporting it internally.” And then they discover this needs to be submitted externally to say help others like in the ASIAS program and the other programs that are out there. So any thoughts on that?
Bob: So, yeah. You mentioned the ASIAS database. The way ASAP works is that the data is yours. You keep it within your company. You do have to report the statistics of it to the FAA on a quarterly basis, but it’s just how many events, kind of what categories and some basic stuff.
If you desire to share that information outside your organization, the FAA has what’s called the ASIAS program (Aviation Safety Information Analysis and Sharing). If you do that, then you get access to that national database.
For example, if you’re going into some heliport that that maybe you haven’t been to in a long time, you can go into the ASIAS database and they will show you the events that have happened at that heliport. Or maybe it’s a tail strike or whatever it might have been. So that you can become more aware of what’s going on at that airport. It’s back to sharing that data with other operators.
Frank: We had an operator who had a problem with their FMS system on a fixed-wing operation. They went to the OEM that produced the avionics, and they found out there was a problem with the avionics itself. The flight crew ran into this, had an altitude deviation as a result of an FMS problem, and they went back to the OEM. The OEM fixed that problem so now everybody who’s operating those same avionics got that update and that fixed that problem for everybody.
While it didn’t run through the ASIAS program, which I’m a huge proponent of, that one event made a nationwide fix for all the operators using that FMS. And that just happened two weeks ago when I was on the phone call with that group. So pretty amazing that the fix happened.
Bryan: I’ll just add one thing that Frank touched on, which is that the Air Charter Safety Foundation has their own SMS platform as well. We always say that ASAP complements SMS. If the folks that are talking about reporting, and don’t know where to start and how to even enroll in the not only SMS, but ASAP, we have that turnkey already set up for you. We can get you enrolled in SMS, get you tied into the ASAP program—all under one platform right.
Our partnership with HAI has a very low cost to get involved in the program. Our proposal gets you in based on the number of participants and depending on the size of the flight department, you can get into this under $1000 year for your operation. For a small operation, you can start as little as $600 or so a year and you’re fully enrolled in SMS and the ASAP program.
That’s for the small operations right and then it’s scaled up. I’ll be happy to talk to anybody about it if you’re interested in participating.
Chris: Thanks, Bryan. Just so everybody knows the Air Charter Safety Foundation—along with many other safety-focused entities are here in the Rotor Safety Zone. Feel free to go talk to them and tell them your specific story and what you’re looking for. No commitments obviously just get better understanding of the program.
Can you share a very compelling story about a recent example where something was reported, and something got corrected and a lot of people benefited from it?
Bob: We work a lot with fixed wing and had an operator who was transitioning up the east coast with a fixed-wing airplane. Transitioned from one air traffic control center to the other and when he got to the new center, the center said, “What are you doing at that altitude? Why are you there?” And the pilot’s like, “I’m pretty sure this is where I was told to be and everything’s right.” The controller got a little upset with him. Sent him to the right altitude the pilot just said what it just didn’t feel right, so he filed an ASAP report. He wasn’t even sure if he did anything wrong. He just filed the ASAP report.
Well, a few days later, the ATC filed a violation on him. That’s what then becomes what we call a “non-sole source.” Now there’s two entities that reported the event, so now look at it. And we when the ERC meets, the FAA guy contacted the air traffic control center and they found out that the air traffic control center was actually using an outdated chart. So it was all the air traffic control center’s fault. The first guy was using a wrong chart. The two centers had not gotten communicated.
And most of you know, publications are challenging to get out into your organization. Well ATC has that problem too. So it was an opportunity to fix that problem so that now a potential not even just another violation of a pilot, but an actual air-to-air mid-air or something potentially happen. That’s another great example.
The reason the ACSF is part of these programs is we sit in on the ERC meetings. We don’t have a voting right, but we’re there to mentor to guide and bring our experience.
Frank sits in on over 40 Event Review Committee meetings a month. So that experience alone—sitting in your ERC meeting—to be able to say, “Hey, wait a minute, guys. We’ve seen this event before. Here’s how we handle it.”
Frank: It’s not the FAA that I usually have to corral, it’s the operator. A lot of times the FAA rep—that we’re all afraid of—is actually the best “party” in that discussion. Because they’ve got the philosophy a little bit better. Sometimes I have to kind of pull the operator back a little bit and say, “Hold on, wait a minute. Remember why we’re here.”
Chris: There’s lots of folks out here consummate professionals and they hear something about immunity or you get away with murder or whatever all you got to do is land and submit an ASAP and you’re golden. So the system is not designed to protect “bad actors.” So talk a little bit about that for those people to make sure the quality is not compromised.
Frank: We call it is the “big five.” I always joke, “if you fly underneath the golden gate bridge inverted and then you file an ASAP report, we’re going to violate the heck out of you.” You knew what the rule was, you intentionally violated safety of flight, you’re not covered under the ASAP program.”
ASAP is really designed for unintentional violations, unintentional acts. There is a checklist that we go through at each event that we review that we decide whether we’re
including or excluding a report. Now having said that, I’ve looked at a thousand different ASAP reports in the past year, and think we’ve excluded maybe five in that year out of over 200 operators for one of the big five.
It’s very rare that we exclude a report. Because, again, our purpose is to get the data. If we exclude the data, that doesn’t help us improve the system. It’s not an immunity program. There are immunity protections built in. But if you go out and do something intentionally, we’re not going to give you a pass on that.
Chris: It really is actually just not in the program, it’s excluded. There’s also sometimes a report will come in and there’s something that they decide it’s kind of a “nothing burger.” It doesn’t even need to get elevated to a committee level. Because we want to encourage people that every single report, is not just going to be a drain on everybody’s time so there’s a process to determine does it rise to the level of a committee consideration.
Bryan: Our top ASAP reports for fixed wing operators is all about altitude deviation, root deviation and TCAS deviation. Those are typically what I would refer to are “benign.”
Frank will tell you that you know we’ve got fleets of aircraft with over 7,500 aircraft in the fleet and he’s doing ASAP ERC meetings once every month with those.
For small operators, it’s typically once every quarter. For an hour, whatever you accumulate of ASAP reports, you’ll review them. And a lot of those are just things to watch the trend and see if there’s any pattern in the corrective action may not be anything at that point and it’ll be just kind of rolled into the next the next ERC meeting.
Bob: Part of why the FAA is doing this is they want that data. So to Chris’s point it may be benign for your organization but if it’s an altitude bust, simple thing, it was a mistake you’d be surprised again how that data flows to the ASIAS system and they will begin to see things. They’ll see the large trends in our in our operations and organizations.
Frank: One thing I’d add to that is that we actually review every report so whether it’s a TCAS whether it’s an altitude deviation that is “benign” as Bryan calls it we look at every single report because one we have to agree as an ERC to accept the report into the program and we have to agree on any corrective action and a lot of cases like Bryan says there is no corrective action but occasionally you’ll get one of those that looks benign and everybody looks and says, “wait a minute, what about this?”
There’s one little piece. Having three of us in the room: a company a representative, a pilot representative and an FAA representative. We’re all looking at it from a slightly different perspective. And so that one person may see one thing in that narrative that has makes them ask the question. Maybe we would have missed if we didn’t if I looked at it and said, “Oh, it’s just a TCAS we don’t need to review it,” there may have been a nugget in there that I missed and so having that group think to look at every report and decide, “yes, we agree it’s benign. We can close it or maybe there is something that we need to dig a little further on it.”
Chris: We’re coming up on towards the end of the period. One reminder. It’s a small investment. Lots of folks who are smaller operators simply don’t have the resources the time to dedicate active management to something like this, that is where you step in.
You are their third-party active manager. You don’t do everything for them, but you do the lion’s share of the prep work. The coordination with FAA. There’s a requirement to get an MOU together. Sometimes that can be a little tricky. They’ve got a relationship with all the FSDOs in the country. And they can find the right resources to get something done a lot faster than perhaps you would be able to because you’re focused on other things that are just as important for your operation.
Bryan: Earlier, I used the term “turnkey.” So as a third-party program manager, we do all the administrative work on your behalf. And it’s primarily about 95% of it we do. We’re representing you in getting this process started. We set the memorandum of understanding up which is really the agreement between you us and the FAA that’s we facilitate that whole process. Frank’s sets up all the ERC meetings with all parties involved. There’s a lot of time-consuming man-hours that go in to this behind-the-scenes. You guys primarily participate in the ERC meetings when those are established.
Chris: That’s why there is a cost, but if you take a look at that cost to compare it to even having a half-time employee that might be between $30K to $70,000 a year for somebody just to be a simple management (to keep the lights on) that’s what you bring to the table.
Bryan: If there’s one thing that folks should remember about the ASAP program no I my thought process has been so successful with the fixed wing folks and by the way Part 91 has outgrown the Part 135 as far as the participants of those 200+ customers that that we have.
Just a little side note the airlines have been using ASAP for 25 years with huge success. And I say that because this is very measurable, it’s very quantifiable, and you’ll discover information that would have never ever been potentially disclosed without those protections and an immunity from the FAA. It’s an incredible, valuable tool that you guys should take some serious consideration to explore.
Chris: All right. Thanks a lot, Bryan, and your team. Appreciate it and so glad to be working with you. Again, if you need to talk ASAP over in the Rotor Safety Zone look for the Air Charter Safety Foundation.
Bryan: Thank you, Chris