Sweeping Changes to Service Difficulty Report System Nixed

Air Safety Week, Sept 26, 2005

The effort to modernize the service difficulty report (SDR) system began with a bang and ended with a whimper. Almost five years ago to the day, the Federal Aviation Administration (FAA) proposed sweeping changes to the SDR system. But the FAA announced in the Sept. 14 Federal Register that it is withdrawing that rule, opting for minor technical fixes but not the sweeping agenda it had originally proposed.

"The topic that received the most comments was the FAA's analysis for the final rule," the FAA said. That's an understatement. The proposed rule would have required operators to report more information, to report ground as well as airborne problems, to adopt a new coding mechanism for SDRs, and all this would have been accomplished at only "minimal" added cost to the industry.

The marginal cost was roundly rebuffed by industry. The Air Transport Association (ATA), representing most scheduled carriers, offered the most trenchant, if not stinging rebuke:

"The FAA has estimated ... a 45% increase in the total reports; yet they also state that the economic cost is 'minimal,' costing each air carrier on average $67 a year ... while $67 or two man-hours per year is truly minimal to an air carrier, a 45% increase in the number of reports is not.

"Depending upon one's interpretation of the wording used in this final rule, ATA members are now estimating a 1000% to 5000% increase in the total number of SDR reports (e.g., one member's review shows 463 SDR's submitted under the existing rules, but 23,822 SDRs would have had to have been submitted under the new final rule, primarily due to having to report all autothrottle discrepancies, all autoflight discrepancies, all flight control discrepancies, all navigation discrepancies, and all corrosion, cracks, disbonding and repairs of metallic structure) ...

"The FAA is estimating a significant cost savings ($1.4 million) for the reduced workload on the FAA's Principal Maintenance Inspectors (PMI's) to offset their estimate of a cost increase to the air carriers and the increased repair station costs of sending SDR copies to the Certificate Holders. This is 'apples and oranges' mathematics; the reduced PMI workload is not a savings to the air carriers or repair stations!"

The ATA commentary goes on for eight pages in this vein. Virtually all other comments from the industry were similarly critical of the FAA's flawed cost-benefit justification. The FAA questions the industry estimate of the number of reports generated under the new system but nonetheless decided "it is prudent to withdraw the final rule." To be sure, the economic climate in which the airlines are now operating is completely different than when the proposed rule was first issued. Airlines are no longer prospering and are in a survival mode. In this climate, a new reporting requirement would be resisted. Having said that, some of the industry's negative reaction may be off the mark. For example, Delta Air Lines [DAL] complained that the SDR system has never been observed and properly utilized. This is true, but doesn't make much sense prospectively. The objective was to make the SDR system work and be useful.

An alternative approach might be to offload much of the requirement from the airlines, and only have the overhaul shops disclose how often an avionics line replaceable unit (LRU), for example, was returned for overhaul, calibration, bench-checking or replacement (that is, non-consumables), with the airlines providing bulk data on usage rates of consumables. This would take the form of turnover rates for retreaded tires, windscreen replacements, light bulb burnouts, blown fuzes, etc.). Aircraft undergoing major overhaul could be vetted for condition, such as cracking and corrosion. Enough aircraft are continually in major overhaul status to provide indicative data.

Among the more contentious issues is the safety benefit of the SDR system. The FAA argued that the SDR was a vital tool for trend analysis and, in this respect, was an important instrument to analyze safety. To be sure, the National Transportation Safety Board (NTSB) occasionally uses SDR reports to identify precursors to an accident it is investigating, but in the numerous comments the FAA received, the safety benefit of proactive SDR reporting was challenged. The NTSB did not submit a comment on the utility of retaining the existing SDR, modifying it along the lines proposed by the FAA, or opting for more modest changes that nevertheless would enhance its utility.

The FAA argument that SDRs can be used to analyze and identify safety trends is undercut by the fact that lack of reporting discipline has plagued the SDR system for years. The latest check of the SDR database shows great inequities in reporting among six legacy carriers. For example, US Airways [UAIRQ] and United Airlines [UALAQ] submit proportionately more reports than Northwest Airlines [NWAC]. The situation is little changed from Sept. 2000, when an FAA official said, "There is a tremendous amount missing" from the SDR database (see ASW, Sept. 11, 2000). At that time, United Airlines was among the most derelict in submitting SDR reports, and it is one of the strongest participants today. Thus, the SDR database is only partly useful for analyzing safety threats over time and, as the latest review of reporting discipline indicates, it is not useful for analysis at a particular point in time.