These are the times for all good pilots to come to the aid of ASRS
The Federal Register is the official place for all US government bodies to give notice to the public about proposed changes to regulations, among other actions. NASA has posted a Renewal of information collection required by the Paperwork Reduction Act of 1995 (PRA). This NASA filing establishes a process- the 1st of which is establishing a docket for interested persons[1] to comment on the proposal. It is noted that ASRS is used to
(1) Identify deficiencies and discrepancies so that these can be remedied by appropriate authorities,
(2) Support policy formulation and planning for improvements and,
(3) Strengthen the foundation of human factors safety research.
Those are encouraging words which suggest that ASRS will be renewed; however, the FR text asks for:
(1) Whether the proposed collection of information is necessary for the proper performance of the functions of NASA[2], including whether the information collected has practical utility; the development, construction, testing, and operation for research purposes of aeronautical and space vehicles;
(2) the accuracy of NASA’s estimate of the burden (including hours and cost) of the proposed collection of information;
(3) ways to ENHANCE THE QUALITY, UTILITY, AND CLARITY OF THE INFORMATION TO BE COLLECTED; and
(4) ways to minimize the burden of the collection of information on respondents, including automated collection techniques or the use of other forms of information technology.
Comments are due by July 7, 2025. You can and should participate in trying to convince NASA to retain ASRS by submitting comments at https://www.regulations.gov/document/NASA_FRDOC_0001-0962 and clicking on “Comment” button.
Here are some hints about what the readers of public comments are
“These are the times for all good pilots to come to the aid of ASRS” (see cover image) is an apt, adapted pangram here. Yes, NASA has gone through this review for almost 50 years BUT recognize that the DOGE initiative has sought to eliminate many federal programs, apparently using some AI algorithm that is not programmed to find the worth of the paperwork or policy that it denominates for being cut.
ASRS IS TOO VALUABLE AND PRESERVATION OF THIS TOOL DEMANDS THAT ALL IN AVIATION TAKETHE TIME TO PROVIDE COMMENTS.
Here are some hints about what the readers of public comments[3] are most likely to read and include in their report:
- Solid, factual examples of using ASRS, particularly if a rule or practice change resulted ;
- Personal opinions, unsupported by a recognized objective source, rarely make to highlight summary;
- The most powerful impact comes from your citing analysis, research, academic papers, think tanks, other well-regarded safety institutions..
If you find any of these references personally compelling, you might want to include one or more in your submission:
- International Civil Aviation Organization (ICAO) can be found in Annex 19 to the Convention on International Civil Aviation – Safety Management, which states:
“States shall establish a voluntary reporting system to collect safety information that may not be captured by a mandatory incident reporting system. The voluntary reporting system shall be non-punitive and afford protection to the sources of the information.”
- Flight Safety Foundation (FSF):
In multiple publications, FSF has emphasized that ASRS is a model for “just culture” reporting systems, noting its role in “enhancing safety through open, non-punitive communication.” - Sidney Dekker, safety scientist and author of The Field Guide to Understanding Human Error, has cited ASRS as a pioneering example of how to build trust in safety systems:
“You don’t get safety by blaming people. You get safety by learning from them. ASRS embodies that principle.” - University of Southern California’s Aviation Safety and Security Program has used ASRS case studies in its curriculum, highlighting its role in proactive risk management.
- A presentation at the International Civil Aviation Safety Summit emphasized how ASRS data has been used to identify systemic issues, such as automation confusion and runway incursions, before they became widespread.
- European Union Aviation Safety Agency (EASA) has referenced ASRS as a benchmark in developing its own confidential reporting systems under the EU Regulation 376/2014.
- Captain Chesley “Sully” Sullenberger, retired airline captain and safety advocate:
“ASRS has been a vital tool in helping us understand and mitigate risks before they lead to accidents. It’s one of the most important safety nets in aviation.”
(Quoted in various aviation safety forums and interviews following the “Miracle on the Hudson.”) - NASA ASRS Research Library: While NASA hosts the data, many of the 60+ studies in its research archive are authored by independent academics and contractors. These studies analyze how ASRS data has led to procedural changes, training improvements, and design modifications that directly reduced incident rates.
- “ASRS: The Case for Confidential Incident Reporting Systems” (FAASafety.gov): This white paper, though hosted on a government site, includes third-party analysis showing how ASRS reports have led to specific safety interventions, such as changes in cockpit procedures and air traffic communication protocols, which were followed by measurable reductions in related incidents.
- “Causal Factors and Adverse Conditions of Aviation Accidents” (NASA Technical Memorandum 2010-216261): This report explores how ASRS data has been used to identify root causes of incidents and implement resilient control strategies. While authored under NASA, it includes contributions from external researchers and contractors, offering a more independent lens.
- Academic Use in Aviation Safety Programs: Institutions like Embry-Riddle and USC’s Aviation Safety and Security Program use ASRS data in coursework and research to demonstrate how data-driven interventions—inspired by ASRS reports—have led to fewer runway incursions, better crew resource management, and improved automation handling.
ASRS, by all objective measures, has resulted in preventative actions that likely saved lives. Recent experience suggests that the failure to analyze and react to this information is the fault of those responsible for taking those steps[4]
Aviation Safety and Reporting System (ASRS) in Jeopardy
By J Scott Dyer
An ENLIGHTENED SAFETY PROGRAM has been in use by the FAA in partnership with NASA for nearly 50 years. The voluntary and confidential Aviation Safety and Reporting System (ASRS) has been a boon to air safety. It was born out of the 1974 crash of a TWA jet on approach to Dulles in bad weather, where the jet met up with the terrain of Mt. Weather as a result of at-best ambiguous ATC language and definitely imprecise instrument flight procedures. The program provides for pilots, controllers, mechanics and others to make confidential reports to the ASRS within NASA, insulating the reports from the sometimes draconian regulation enforcement arms of the FAA, and THEREBY PROVIDING A STEADY STREAM OF REPORTS THAT HIGHLIGHT AVIATION SAFETY ISSUES IN NEARLY REAL-TIME.
The “CARROT” enticing those in the industry to submit voluntary reports is that in many if not most cases, the reporting person can’t be subject to an FAA enforcement sanction (e.g., suspension or revocation of a certificate) even if a regulation has been broken. If the report is made within 10 days of the event, the action is inadvertent and not deliberate, and the action is not criminal, there can be a finding of a violation but no penalty can be assessed. This immunity can only be used once every five years.
ASRS So Far
More than 2 million reports have been received by NASA and there has never been a breach of confidentiality. Roughly 400 or more reports come in every day, the great majority of these from airline crews. FAA is forbidden from using ASRS information against those who report under ASRS. The result is that this is a ROBUST SYSTEM WITH ASRS ANALYSIS REGULARLY BEING SHARED WITH FAA, NTSB, AIRLINES, AIRPORTS AND OTHER USERS THROUGH SAFETY ALERTS ON SPECIFIC ITEMS AND IN A MONTHLY NEWSLETTER. We as aviators shouldn’t lose this valuable resource of both safety data and immunity from penalty. We can’t take it for granted.
In May 2025, NASA published a notice in the Federal Register asking for comments within 60 days about the continuation of ASRS. Suspicious minds were worried that this might be a not-very-subtle effort by the Administration to close down ASRS. That probably isn’t the case because periodic notices of this sort have been published for many years under the Paperwork Reduction Act of 1995, and ASRS has continued.
But still, we live in “interesting” times when the past is no guarantee of what will happen tomorrow. We aviators shouldn’t sit on our hands and do nothing. Lawyers have a phrase for working to box in administrative agencies from making undesirable changes: it’s called, “making a record”. Put on the record facts and positions that the commenter finds helpful to her or his position. Make it tough for an agency to chart a different course.
Where Does ASRS Fit?
What can we do? NASA is ostensibly looking for comments on whether ASRS fits NASA’s role, whether the estimate of about 30 minutes’ time to fill our an ASRS report is about right, ways to enhance the quality and usefulness of the information collected and how automation can be used to minimize the burdens on us, the users. I’d suggest sending in those comments. Tell them that the middle name of “NASA” is “Aeronautics” and a major part of aeronautics is aviation safety. The 30 minutes to complete the form (paper or online) is about right and ASRS has honed the form for collecting and collating this data from reporters quite well over the years. Also note that ASRS already allows for online completion and submission of the reporting form and this is about as easy as can be (maybe there can be an app for that?). And include a statement that the ASRS is a program that works beautifully and is an integral part of how individual aviators can make a direct contribution of aviation safety. We can each make the system better.
Comments are due by July 7, 2025. Provide yours by going to https://www.regulations.gov/document/NASA_FRDOC_0001-0962 and clicking on “Comment” button. You can also read what others have submitted under the Comment tab. The full Federal Register listing is here: https://www.govinfo.gov/content/pkg/FR-2025-05-05/html/2025-07779.htm
J Scott Dyer is an Aviation Consumer and AVweb contributor, an active flight instructor and aircraft owner in the New York City area.
[1] The notice lists the following as potential commenters—“…any participant involved in safety-critical domains such as aviation or railway operations including commercial and general aviation pilots, drone operators, air traffic controllers, flight attendants, ground crews, maintenance technicians, dispatchers, train engineers, conductors, and other members of the public.”
[2] National Aeronautics and Space Act of 1958, which established the agency. According to U.S. Code Title 51, Section 20111, NASA is tasked with:
“The expansion of human knowledge of phenomena in the atmosphere and space,”
“The improvement of the usefulness, performance, speed, safety, and efficiency of aeronautical and space vehicles,”
[3] All comments submitted in the docket are reviewed by staff and they summarize what they believe to be the most salient points to their bosses. Their selection of what’s important sets up two important steps; (1) the draft response published in the Federal Register includes these selected comments (may have impact on an appeal) and (ii) will be part of the package that will be sent to the savants at OMB who approve or reject the draft decision.
[4] the NTSB’s preliminary report on the tragic January 29, 2025 midair collision near Ronald Reagan Washington National Airport (DCA) revealed a deeply troubling pattern: over 15,000 close-proximity events between helicopters and commercial aircraft occurred at DCA between 2011 and 2024, yet no systemic corrective action had been taken.
