AMC1 ORO.AOC.130 Flight data monitoring – aeroplanes    

CAA ORS9 Decision No. 15

FLIGHT DATA MONITORING (FDM) PROGRAMME

(a) The Safety Manager, as defined under AMC1 ORO.GEN.200(a)(1), should be responsible for the identification and assessment of issues and their transmission to the manager(s) responsible for the process(es) concerned. The latter should be responsible for taking appropriate and practicable safety action within a reasonable period of time that reflects the severity of the issue.

(b) An FDM programme should allow an operator to:

(1) identify areas of operational risk and quantify current safety margins;

(2) identify and quantify operational risks by highlighting occurrences of non-standard, unusual or unsafe circumstances;

(3) use the FDM information on the frequency of such occurrences, combined with an estimation of the level of severity, to assess the safety risks and to determine which may become unacceptable if the discovered trend continues;

(4) put in place appropriate procedures for remedial action once an unacceptable risk, either actually present or predicted by trending, has been identified; and

(5) confirm the effectiveness of any remedial action by continued monitoring.

(c) FDM analysis techniques should comprise the following:

(1) Exceedance detection: searching for deviations from aircraft flight manual limits and standard operating procedures. A set of core events should be selected to cover the main areas of interest to the operator and as much as possible, the most significant risks identified by the operator. The event definitions should be continuously reviewed to reflect the operator’s current operating procedures.

(2) All flights measurement: a system defining what is normal practice. This may be accomplished by retaining various snapshots of information from each flight.

(3) Statistics — a series of data collected to support the analysis process: this technique should include the number of flights flown per aircraft and sector details sufficient to generate rate and trend information.

(d) FDM analysis, assessment and process control tools: the effective assessment of information obtained from digital flight data should be dependent on the provision of appropriate information technology tool sets.

(e) Education and publication: sharing safety information should be a fundamental principle of aviation safety in helping to reduce accident rates. The operator should pass on the lessons learnt to all relevant personnel and, where appropriate, industry.

(f) Accident and incident data requirements specified in CAT.GEN.MPA.195 take precedence over the requirements of an FDM programme. In these cases the FDR data should be retained as part of the investigation data and may fall outside the de-identification agreements.

(g) Every crew member should be responsible for reporting events. Significant risk-bearing incidents detected by FDM should therefore normally be the subject of mandatory occurrence reporting by the crew. If this is not the case, then they should submit a retrospective report that should be included under the normal process for reporting and analysing hazards, incidents and accidents.

(h) The data recovery strategy should ensure a sufficiently representative capture of flight information to maintain an overview of operations. Data analysis should be performed sufficiently frequently to enable action to be taken on significant safety issues.

(i) The data retention strategy should aim at providing the greatest safety benefits practicable from the available data. A full dataset should be retained until the action and review processes are complete; thereafter, a reduced dataset relating to closed issues should be maintained for longer-term trend analysis. Programme managers may wish to retain samples of de-identified full-flight data for various safety purposes (detailed analysis, training, benchmarking, etc.).

(j) The data access and security policy should restrict information access to authorised persons. When data access is required for airworthiness and maintenance purposes, a procedure should be in place to prevent disclosure of crew identity.

(k) The procedure to prevent disclosure of crew identity should be written in a document, which should be signed by all parties (airline management, flight crew member representatives nominated either by the union or the flight crew themselves). This procedure should, as a minimum, define:

(1) the aim of the FDM programme;

(2) a data access and security policy that should restrict access to information to specifically authorised persons identified by their position;

(3) the method to obtain de-identified crew feedback on those occasions that require specific flight follow-up for contextual information; where such crew contact is required the authorised person(s) need not necessarily be the programme manager or safety manager, but could be a third party (broker) mutually acceptable to unions or staff and management;

(4) the data retention policy and accountability, including the measures taken to ensure the security of the data;

(5) the conditions under which advisory briefing or remedial training should take place; this should always be carried out in a constructive and non-punitive manner;

(6) the conditions under which the confidentiality may be withdrawn for reasons of gross negligence or significant continuing safety concern;

(7) the participation of flight crew member representative(s) in the assessment of the data, the action and review process and the consideration of recommendations; and

(8) the policy for publishing the findings resulting from FDM.

(l) Airborne systems and equipment used to obtain FDM data should range from a quick access recorder (QAR), in an aircraft with digital systems, to a crash-protected recorder in an older or less sophisticated aircraft. The analysis potential of the reduced data set available in the latter case may reduce the safety benefits obtainable. The operator should ensure that FDM use does not adversely affect the serviceability of equipment required for accident investigation.