ATOS and the Nature of the FAA/Operator Relationship

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There has been a great deal of public scrutiny of the Air Transportation Oversight System (ATOS) system.  After a 30-year career in safety both at the Federal Aviation Administration (FAA) and as a safety consultant, I am concerned about the tone and direction of the publicity.  There seems to be a general assumption that the operators are unable to take on the responsibility of their safety systems and that collaboration and cooperation between the regulator (FAA) and the operator is a bad thing.  I disagree.

The only feasible method for the FAA to ensure that a comprehensive safety system exists for the operator is to conduct audits of the system on a periodic basis.  These audits are essential as they check the processes and procedures of the safety system to ensure they meet their intended design.  On the other hand, when the FAA audits stand alone, they do not provide the data needed to truly improve a safety system.  Any suggested changes made to a safety system that are based solely on the data from a single audit, may be invalid.  System changes that move a safety system towards the ideal are developed from data gathered, analyzed and trended over time.  From this data, controls and corrective actions can then be put into place based on reality rather than an anomaly.  Once enacted, more analysis of the corrective actions needs to occur to determine if these actions meet their intended design.  This process of analyzing, trending, and making changes is ongoing and needs to utilize data collected by both the operator and the FAA. 

To enable the analysis of data collected by both the FAA and operator, the data needs to be shared in a positive working environment that is open and based on trust.  When an operator voluntarily shares data with the FAA, the data needs to be protected and used by the FAA to help the operator ensure best practices in the Safety Management System (SMS).

Though the FAA is integral to helping an operator develop a comprehensive SMS, in the end, the responsibility of the SMS rests squarely on the shoulders of the operator. If there is an ineffective SMS, the operator’s customers are at risk, and thus the operator itself is at risk.  Operators understand their responsibility, and the FAA provides them with another viewpoint and a second set of eyes to analyze their safety data.  When operators are able to take the FAA’s viewpoint and combine it with their own ongoing collection of data and analysis, they have what is needed to create an evolving SMS where changes improve the entire system rather than provide short-term fixes to errors that could well have been anomalies.

So let the scrutiny of ATOS continue.  But, as in the development of an SMS, we need to make decisions about any changes to ATOS after a thorough analysis of a complete set of data points.  I am encouraged when I see a positive FAA/operator relationship and the sharing of critical safety information.  Sharing enhances the operator in part and the aviation industry as a whole.

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1 Comment on "ATOS and the Nature of the FAA/Operator Relationship"

  1. The whole ATOS mess isn’t working at all. I am a FAA Inspector with a small 121 air carrier. All I do is spend my time doing SAI & EPI’s stuck at a computer all day looking at a flat screen computer. Oversight of the carrier is much less than before they went ATOS, which is great for larger 121 air carriers. Not one with 7 planes and no assistants!!!

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