Proposals for Improved Accident Reporting Trigger Negative Reactions

Air Safety Week, April 4, 2005

The most significant changes to accident reporting in years have generated mostly a negative reaction from the industry.

The challenge to the proposer, the National Transportation Safety Board (NTSB), will be to see if industry concerns can be accommodated while still achieving the spirit of the announced changes.

On Dec. 27, 2004, the NTSB suggested a number of alterations to the existing rules, specifically to broaden the definition of substantial damage (see ASW, Jan. 3, 2005). While this may yield more reports of breakage and breakdowns, it also may mean the NTSB would have to grow beyond its present budget to be able to cope with the added commitment associated with analyzing or investigating the incidents.

Among other things, the NTSB was proposing an expanded reporting of traffic collision and reporting system alerts known as resolution advisories (recommended escape maneuvers to either increase or maintain the existing vertical separation between aircraft). In addition, the NTSB proposed reporting of loss of information from a majority of an aircraft's electronic primary flight displays, failure of an internal turbine engine component that results in the escape of debris other than out of the exhaust path, and to include damage to helicopter tail and main rotors that occurs on the ground (on the rationale that rotors provide the equivalent lift of wings, and therefore even ground damage to them should be reported).

The nay-sayers certainly make their point. For smaller helicopter operators, and most notably where aero medical evacuation is involved, bureaucratic airframe downtime may put lives in jeopardy. Crop-sprayers could lose irreplaceable time and contracts at the peak of their season. Both individual pilots and company accident records could be affected, and in many cases their new accident "history" would reflect a higher incidence. The dire economic consequences of reporting might well start breeding a genus of lawlessness within the industry. The cynicism generated by that attitude can severely erode attitudes toward safety and its bureaucratically generated economic consequences (loss of airframe utilization, added paperwork, hiked insurance premiums, contracts unable to be tendered due to "accident history," identifiable data-base entry, etc.).

Reclassifying incidents as accidents would skew insurance and safety board statistics worldwide, leading to the sort of confusion that is always generated by officialdom "moving the goal posts."

While the industry generally holds the NTSB in high regard, the National Air Transportation Association (NATA) questions whether any effective industry impact analyses have been carried out. The Helicopter Association International (HAI) refutes the analogy of rotor blades equating to aircraft wings, pointing out that rotor damage that extends to the drive train (mast or tail-rotor drive- shaft) is already an accident. However, rotor blades are changed frequently because of minor damage and erosion, unlike aircraft wings.

The views expressed on resolution advisories (RA) are especially relevant because of:

* Reduced vertical separation minima, as of Jan. 20, 2005, and the ease with which RAs can now be generated (see ASW, Nov. 3, 2003). Dr. Andrew Zeitlin (principal engineer at the Center for Advanced Aviation System Development) and United Airlines [UALAQ], below, suggest a solution whereby the Federal Aviation Administration (FAA) would, at its air traffic control centers, record the Mode- S returns. This would be a way out, but would require the FAA to implement a system whereby any RA report would trigger a data collection process.

* NetJets, Inc. makes the valid point that its RA reporting alone would produce 24,000 pilot reports a year. NetJets guess is that the U.S. aviation industry altogether would generate 250,000 RA reports per year. That number would inundate the industry and the NTSB with a huge mass of reports where safety may not be compromised.

* The Regional Airline Association (RAA) claims that unless there were the type of disclosure protection afforded in the Aviation Safety Action Program (ASAP) or flight operations quality assurance (FOQA) schemes, pilots would simply fail to comply.

* Perhaps RAs should be regarded as just another back-stopping safety tool (like wind-shear alerting, radar altimeter warning systems, weather radars, undercarriage alerts, overspeed clackers and enhanced ground proximity warning system alerts).

Clearly, the NTSB has much to consider as it wrestles with RAs, in addition to its other proposals.

Of the roughly 50 comments it received, we present below selected comments on RAs and on the loss of information from flight displays. Significantly, the NTSB has received no comments from the FAA.

Report all airborne collision and avoidance system (ACAS) resolution advisories when an aircraft is operating on an instrument flight rules (IFR) flight plan: