The SDR Phantasm

phan·tasm

[fan-taz-uhm] Show IPA
–noun
 
1. an apparition or specter.
 
2. a creation of the imagination or fancy; fantasy.
 
3. a mental image or representation of a real object.
 
4. an illusory likeness of something.
Examples of, and the impact of, past safety investigations utilizing NTSB Safety Recommendation Letters with partial references to SDRs in Final Reports which , in short , demonstrate a NTSB disconnect in their companion program Rule 830.5 Immediate Reporting.  The NTSB has said "they have no (Rule 830.5) database" and it showed terribly as FOIA requests for specific data such as uncommanded rudders and uncontained engine explosions produced but about 20 % of the already compromised SDR database.
 
At stake are past NTSB Final Reports on Valujet 592 and American flight 587, and that they were not data-driven , but rather the subject of narrowed focus to O2 cans and American Airlines flight training.  Of course SDR, AAIB and Tech Center data greatly undermined those 'probable causes'.
 
Another fall-out of the dysfunctional SDR program is that the highly touted ATOS program has suffered terribly.  A number of GAO critical reports were produced, but all had the same underlying theme - poor SDR data hampers any attempt to evaluate the effectiveness of the ATOS - or any other such voluntary disclosure program.  Moreover, it's most difficult to say with certainty whether any FAA program is allocating its inspection resources effectively.
 
Simply, the flaws in the SDR program have negatively impacted every other program that followed.
 
See attachments to the documents sent to the OIG so far .

1.  NTSB Survey VS SDRs:  link one     2.  Survey - Frivolous SDRs:  link two

 
See below for some of these past GAO reports referred to above >
 
 

Needed Improvements in FAA’s Airline Inspection Program Are Underway (GAO/RCED-87-62, May 19, 1987). Link > http://archive.gao.gov/d28t5/133088.pdf

Ref pg 2-3 ;  “Further, GAO'S review-as well as FAA and DOT studies found that the inspection program often did not identify major safety problems or assure their correction through appropriate follow-up.”

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Changes Needed In FAA’s Service Difficulty Reporting System.  GAO/RCED-91-94; March 1991.  Link > http://archive.gao.gov/d21t9/143542.pdf 

Ref pg 4; “The chief reason that FAA engineers and airline personnel are dissatisfied with the SDR program is that its data are of low quality.  We believe that this is due to management’s inattention to the program over the last decade."

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Data Problems Threaten FAA Strides on Safety Analysis GAO/AIMD-95-27.  02/08/95. Link > http://www.gao.gov/archive/1995/ai9527.pdf 

Ref pg 3;  “To identify aviation safety risk precursors, SPAS relies on data from numerous databases, including those comprising FAA’s Aviation Safety Analysis System (ASAS). As previously reported by GAO, FAA, and others, these ASAS databases contain incomplete, inconsistent, and inaccurate data. If the quality of the data that SPAS relies on remains poor, its inputs to safety-related decisions will not be reliable, and it will not effectively support FAA’s inspection and certification mission.”

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FAA’s New Aviation Inspection System Offers Promise but Problems Need to Be Addressed.  GAO/RCED-99-183  Link > http://www.gao.gov/archive/1999/rc99183.pdf  

Pgs 10-11;  "Because the ATOS guidance does not include all (legally enforceable pg 11) applicable regulatory requirements, inspections may not be thorough enough to ensure compliance."

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Weaknesses in Inspection and Enforcement Limit FAA in Identifying and Responding to Risks

(GAO/RCED-98-6, Feb. 27, 1998).  Link > http://www.gao.gov/archive/1998/rc98006.pdf 

Ref pg 6; “GAO reported 10 years ago that FAA needed to develop criteria for targeting safety inspections to airlines whose characteristics may indicate safety problems, and in February 1995 and April 1996, GAO identified serious problems with the quality of the data systems on which FAA’s targeting depends.  Although Flight Standards has developed a system for targeting its inspections, this system relies on the database whose accuracy is compromised by incomplete information.”

-------------------

 

Better Management Controls are Needed to Improve FAA’s Safety Enforcement and Compliance

Efforts. (GAO-04-646, July 2004).  Link > http://www.gao.gov/new.items/d04646.pdf

Ref pg 1; “FAA is limited in its ability to evaluate enforcement efforts because the agency lacks comprehensive nationwide data”.

Related GAO Products       Items in highlight ; PDFs not found

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1987  Needed Improvements in FAA’s Airline Inspection Program Are Underway (GAO/RCED-87-62, May 19, 1987).

Link > http://archive.gao.gov/d28t5/133088.pdf

Ref pg 2-3 ;  “Further, GAO'S review-as well as FAA and DOT studies found that the inspection program often did not identify major safety problems or assure their correction through appropriate followup.”

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1989  FAA Aviation Safety Inspectors Are Not Receiving Needed Training (GAO/RCED-89-168, Sept. 14, 1989).

Link > http://archive.gao.gov/d26t7/139803.pdf

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1989  FAA’s Safety Inspection Management System Lacks Adequate Oversight (GAO/RCED-90-36, Nov. 13, 1989).   

Link > http://archive.gao.gov/d26t7/140117.pdf

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 1991  Problems Persist in FAA’s Inspection Program 

(GAO/RCED-92-14, Nov. 20, 1991).

Link> http://www.gao.gov/cgi-bin/getrpt?RCED-92-14

 -------------------

1991  Changes Needed In FAA’s Service Difficulty Reporting System.  (GAO/RCED-91-94;  March 1991.) 

Link > http://archive.gao.gov/d21t9/143542.pdf     Ref pg 4; “The chief reason that FAA engineers and airline personnel are dissatisfied with the SDR program is that its data are of low quality.  We believe that this is due to management’s inattention to the program over the last decade.”

 -------------------

1992  Progress on FAA Safety Indicators Program Slow and Challenges Remain (GAO/IMTEC-92-57, 8/31/92).

Link> http://www.gao.gov/cgi-bin/getrpt?IMTEC-92-57

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1992  FAA Needs to More Aggressively Manage Its Inspection Program (GAO/T-RCED-92-25, Feb. 6,1992.)

Link> http://archive.gao.gov/t2pbat6/146176.pdf

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1995  Data Problems Threaten FAA Strides on Safety Analysis   (GAO/AIMD-95-27.  02/08/95).

Link > http://www.gao.gov/archive/1995/ai9527.pdf   

Ref pg 3;  “To identify aviation safety risk precursors, SPAS relies on data from numerous databases, including those comprising FAA’s Aviation Safety Analysis System (ASAS). As previously reported by GAO, FAA, and others, these ASAS databases contain incomplete, inconsistent, and inaccurate data. If the quality of the data that SPAS relies on remains poor, its inputs to safety-related decisions will not be reliable, and it will not effectively support FAA’s inspection and certification mission.”

 -------------------

1996 Targeting and Training of FAA’s Safety Inspector Workforce.  (GAO/T-RCED-96-26, Apr 30, 1996)   

Link . http://www.gao.gov/archive/1996/rc96026t.pdf

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1996 FAA Generally Agrees with but Is Slow in Implementing Safety Recommendations (GAO/RCED-96-193.) 09/23/96.)  

Link > http://www.gao.gov/archive/1996/rc96193.pdf  

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1997  Challenges to Implementing the Recommendations of the White House Commission on Aviation Safety and

Security (GAO/T-RCED-97-90 , Mar. 5, 1997). 

Link > http://www.gao.gov/archive/1997/rc97090t.pdf and http://www.tpub.com/content/cg1997/rc97090t/rc97090t0005.htm  > Page 3;  “Similarly, we have reported since 1987 that the availability of complete, accurate, and reliable FAA data is critical to expanding the margin of safety”.   (Statement by GAO Gerald L. Dillingham)

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1998  Weaknesses in Inspection and Enforcement Limit FAA in Identifying and Responding to Risks (GAO/RCED-98-6, Feb. 27, 1998). 

Link > http://www.gao.gov/archive/1998/rc98006.pdf

Ref pg 6; “GAO reported 10 years ago that FAA needed to develop criteria for targeting safety inspections to airlines whose characteristics may indicate safety problems, and in February 1995 and April 1996, GAO identified serious problems with the quality of the data systems on which FAA’s targeting depends.  Although Flight Standards has developed a system for targeting its inspections, this system relies on the database whose accuracy is compromised by incomplete information.”

 -------------------

1999  FAA’s New Aviation Inspection System Offers Promise but Problems Need to Be Addressed. 

 (GAO/RCED-99-183.)  

Link > http://www.gao.gov/archive/1999/rc99183.pdf    

Pgs 10-11; Because the ATOS guidance does not include all (legally enforceable/pg 11) applicable regulatory requirements, inspections may not be thorough enough to ensure compliance

 -------------------

2003 Major Management Challenges and Program Risks.  (GAO-03-108; Jan 1, 2003.) 

Link > http://www.gao.gov/pas/2003/d03108.pdf

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2004  Better Management Controls are Needed to Improve FAA’s Safety Enforcement and Compliance

Efforts.   (GAO-04-646, July 2004). 

Link > http://www.gao.gov/new.items/d04646.pdf

Ref pg 1; “FAA is limited in its ability to evaluate enforcement efforts because the agency lacks comprehensive nationwide data”.

see also follow-up blog article at http://asj.nolan-law.com/