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Old 11-05-2022, 01:31 PM
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franklin_m
 
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Default Safety Metrics & AC91-57C

As far back as 2014, I recommended AMA start tracking legitimate safety data:
Originally Posted by franklin_m
I've advocated to AMA that they create a standardized mishap reporting system. The goal being that not only does it allow them to go to FAA with hard numbers in support of a safety record, but it also provides members a window into just how frequently we're crashing and how bad these are. What's missing is the framework for this reporting and the mechanism to ensure it happens. I think it would be a very powerful argument to take to the FAA if AMA was able to say for example: "At all of our chartered clubs last year, there were XXX crashes of aircraft greater than XX pounds, YYYY crashes of aircraft weighing between YY and XX pounds, and ZZZZ crashes of less than YY pounds. Of these crashes, RR were not on club property, and X resulted in any claimed property damage. At our clubs, there were a total of SSSS injuries, KKK of which were First Aid (as defined by OSHA), and M were more serious. Lastly, per reporting from our club leadership, there were a total of TTT substantive violations of our safety policy. NNN were handled through education and administrative measures, P resulted in termination of flying privileges.

I think the ability to go to FAA with that kind of hard data would create a powerful argument that our operations are safe, that we can prove that with hard data, and that we're holding members accountable to the code. It would also allow us to know what is and is not our major area of demonstrated risk and then design management system controls to mitigate that risk.

This is how a professional safety program is managed (I did this professionally), and thus it's not a "tin hat" type of recommendation. Interesting note, as of yet AMA has not responded. (emphasis added)

Then again in 2016, I recommended AMA start tracking leading metrics:
Originally Posted by franklin_m
I firmly believe they need to be doing more than they are now. They're looking at lagging indicators only, and even then a very narrow subset of them. That may have been fashionable in safety programs of thirty or more years ago, but it's not a best practice these days. Everything today is about looking at trends in leading indicators ... near misses, non-injury incidents, etc. (emphasis added)

And lo and behold, look at what FAA is telling them in AC91-57C, Section 3.3.2.8:
Safety Incident Reporting Program. To support and promote a safety culture among all CBOs and recreational flyers, the FAA recommends that comprehensive safety guidelines address safety incidents. For the purpose of this AC, a 'safety incident' is defined as an occurrence associated with the operation of the aircraft that affects or could affect the safety of operations. CBOs may consider including a safety incident reporting program for recreational flyers. Gathering such data may provide substantial benefits to CBOs, as the data would enable better understanding of the trends and risks that may be posed by UA operations. CBOs could then use the data to identify appropriate mitigations. (emphasis added)

Just think, if they'd listened to me back in 2014, they'd have the policy in place, worked out the data collection issues, developed reports and actioned improvements based on data, and had EIGHT years of data already. But as the EVP said, "we're pretty smart too."

How's that working out so far? Point being, to BC and others at "Taj-Muncie," the world is looking a lot more like what I've been describing than it looks like the "as we always have" crowd (them) have described. Once again, AMA leadership reacting rather than leading.

Last edited by franklin_m; 11-06-2022 at 07:04 AM. Reason: Fix line spacing; added 2014 recommendation