The passage of time might not have dimmed the painful memory of the crash of Colgan Air Flight 3407, but it has at least given delegates to this year’s RAA Convention some perspective on the legacy the disaster seems sure to leave on the industry’s regulatory environment. The accident has led to FAA Administrator Randy Babbitt’s “Call to Action,” under which U.S. airlines endured some of the most intense scrutiny ever placed on them by regulators. Since then, each branch of Congress has introduced legislation calling for an increase in the minimum hours required for Part 121 first officers and tougher rules related to training, inspections and recordkeeping.
Of course, the rationale behind the measures stems from a professed desire to ensure “one level of safety” between regional and major airlines. Still, RAA vice president Scott Foose takes issue with the premise that a single safety standard doesn’t exist.
“For us, being painted with a broad brush, that’s something that happens,” said Foose. “We know it will happen from time to time, but it’s in our culture that, while we need to respond to those concerns, every day we’re out there looking for a better way to do things, to make things safer.”
To the RAA, that commitment has taken the form of what it calls its strategic safety initiative, under which the association has undertaken a review of safety procedures, commissioned a study on fatigue, developed a so-called fatigue awareness management program and issued six recommendations for regulators. The recommendations include:
• create a single FAA database of pilot records;
• conduct random fatigue tests;
• examine the practice of pilot commuting;
• extend the time frame for pilot background checks;
• audit cockpit voice recordings; and
• improve tracking and analysis of check rides.
But quite apart from participating in any voluntary programs advocated by the RAA, the airlines had no choice but to submit to the FAA blitz of inspections and meetings under the Call to Action, a report on which Babbitt submitted in January. The report noted that inspectors observed 2,419 training and/or checking “events” at 85 airlines. Of those, they found that 14 training events at five carriers, or 0.6 percent of the events observed, did not meet regulatory requirements. Although four of the five carriers identified– SkyWest, Lynx Aviation, Cape Air and Colgan Air–belong to the RAA, Foose expressed satisfaction with the regionals’ performance as a group.
“In fact, we were quite pleased [with Babbitt’s report],” said Foose. “You do expect with a thorough inspection that there will be recommendations [that] come out, but overall the report was good and we were pleased.”
Although the report also noted that several carriers either didn’t fully comply or failed to implement any component of a remedial training system described in Safo 06015, all have since addressed their deficiencies, according to the FAA. Five RAA member airlines–namely Era Aviation, GoJet, Trans States Airlines, Mesaba Airlines and Lynx Aviation–appeared on a list of nine that had not established a program.
Another element of the Call to Action–an aviation rulemaking committee (ARC) on flight duty and rest commissioned by Babbitt last June–had yet to result in an NPRM by the time Foose spoke with AIN in March, but the RAA vice president wouldn’t fault the FAA for the length of time it had taken to devise rulemaking since the ARC last met in early September.
“The FAA is putting its heart and soul into putting this out,” said Foose. “They made it clear that they want to do it as soon as possible, but they want it to be right. I don’t see this as a delay; I see it really as they’re doing their due diligence to make sure that the proposal is clear and understandable when it’s published.”
Foose, who served as an alternate member of the ARC, attended its meetings and characterized its work as thorough and scientifically sound.
“I will tell you that I was impressed with how well the various parties on the ARC really worked to try to find ways to take advantage of the science and I’m confident that the proposal will reflect what the science suggests we should do to change and update those rules,” he said.
Foose acknowledged that the science remains incomplete, however, and that the study that the RAA has commissioned–now under way at Washington State University–will help fill gaps in the understanding of how multi-segment schedules common among regional airlines affect pilot physiology.
“Regional airlines obviously generally fly shorter flights and multi-segment pilot schedules and so there’s a great interest on the part of our members in understanding to what extent their schedules could be more or less fatiguing than [those at] the major airlines,” said Foose.
While some have argued that the nature of regional operations necessarily leads to more fatigue, science hasn’t substantiated that assertion, said Foose. Similarly, the association does not necessarily accept the premise that pilot commuting leads to fatigue, or that regionals should carry the entire burden of answering critics of the practice.
“There was testimony last year at one of the NTSB hearings that more than 50 percent of United’s pilots commute, so it’s not a regional issue,” said Foose. “It’s really something that the pilots find is beneficial to their schedules and their lifestyle. And I’ve heard so many pilots [say] that they think they’ve been professional and mature about managing their time, so that they are safe and rested when they take their trips. But clearly there have been exceptions to that.”
Unfortunately, one of those exceptions “likely” contributed to the crash of Colgan Flight 3407, although the NTSB would not venture a judgment on the extent fatigue contributed to the pilots’ mental impairment or the operational deficiencies they exhibited during the flight.
Still, the RAA considers fatigue enough of a concern not only to commission a study, but also to collaborate with the Flight Safety Foundation on developing what the association calls a fatigue mitigation tool kit. Foose described the tool kit as an “industry-leading program” designed to incorporate all the science available to develop a training regime aimed directly at alleviating the dangers of fatigue. “We’re not interested in waiting around until we find out that there was something that we could have done better,” said Foose. “So we’re being proactive in identifying ways to fill the safety gaps and most important, whatever we learn, whatever we know now and whatever we learn in the future will be incorporated into our training programs that we’ll be giving to our pilots and other safety professionals in the industry.”
Foose said the RAA would like to finish its work on the tool kit by next March and “have it in the hands of anybody who wants it” by July 2011.
Superficially, it appeared that before the Call to Action not all of the RAA’s airlines behaved in quite the proactive fashion Foose described, at least when it came to implementing flight operations quality assurance (FOQA)–the voluntary program under which airlines use quick access recorders and ground analysis software to monitor and analyze various flight and systems data to help craft a training curriculum, for example, or, more controversially, to apply corrective action. Although most member airlines had adopted the Aviation Safety Action Program (ASAP), which encourages employees to report safety concerns voluntarily by guaranteeing limited immunity from disciplinary action, only two had instituted FOQA by the time of the Colgan disaster.
“As a result of the meetings with the FAA, [the regionals] have agreed to accelerate FOQA,” said Foose, who nevertheless refused to characterize the regionals’ behavior before the Colgan accident as less than conscientious. “Where the regional aircraft did not come with the hardware needed to implement a FOQA, there were other safety programs that they adopted that worked well together,” he said.
“So airlines looked at what they were able to do in the short term and moved out. In the case of the regional airlines, because they have such a great working relationship with their pilots, they found that the ASAP program was an effective means of identifying the cause of events. So it was a natural response for them to implement those first, and they did…The major carriers, on the other hand…their aircraft came with the hardware. So they predominantly went with the FOQA program.”
Foose explained that while FOQA shows “how the airplanes are being operated,” ASAP explains why events happen. “So were the regionals behind? I would say no,” said Foose. “They made the right choice to implement ASAP, but they realized that they needed also to accelerate FOQA so they’ve gone ahead and made that commitment to do it.”
Today, “the majority” of the RAA’s airline members have committed to adopting FOQA. Those that haven’t, said Foose, simply do not operate large enough fleets to glean any benefit from the program. “If you’ve got a small operation, so your management staff is flying regularly with your pilots, you’re not going to get any new information out of FOQA,” he said.