Safety Metrics & AC91-57C
11-05-2022, 01:31 PM
#1
Thread Starter
Safety Metrics & AC91-57C
As far back as 2014, I recommended AMA start tracking legitimate safety data:
Then again in 2016, I recommended AMA start tracking leading metrics:
And lo and behold, look at what FAA is telling them in AC91-57C, Section 3.3.2.8:
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.
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)
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:
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
11-07-2022, 06:11 PM
#2
Senior Member
Hanson went around the FAA and lobbied Congress to force hobby drone owners to join AMA. Hanson asked for "tweaks" to the law to clear up who was covered. Congress cleared it up by kicking AMA out of management forever. So now AMA does what they're told by their supervisors at FAA. AMA safety reporting system coming soon.
11-07-2022, 08:32 PM
#4
Senior Member
11-07-2022, 09:12 PM
#5
Senior Member
I'm only going back as far as Hanson's op-ed in The Hill. I'd have to look up Hanson's and Chad Budreau's previous comments on drone owners being subject to AMA membership, but it common knowledge and I'm guessing Franklin has it readily available. Hanson's AMA frauds are so well document I stopped wasting space. In any case, this is from Hanson's op-ed in The Hill, titled
After declaring that, Hanson admits he is actually lying:
"we acknowledge that some tweaks to Section 336 may be necessary to clarify who the provision does and does not cover."
There is no need to further dissect the article. It is a total fraud, as is Rich Hanson. Look it up yourself.
The proof is in the pudding (like Rich Hanson's brain now, apparently). Hanson flushed the sweet deal of no regulation and Section 366 down the toilet over drones and FPV. Congress booted the AMA and the FAA took over. It's too bad this is a tempest in a tea pot in the big scheme of things. The epic meltdown of a once great institution like AMA could be compared to the Boy Scouts of America. But in AMA case it is all due to one megalomaniac and a couple of his lakeys.
Punish rogue recreational drone pilots — not the rule followers
"Let me be clear — if you are flying drones for recreational purposes today, you must be operating within an established safety program," "recreational drone pilots are only eligible to fly under Section 336" "about 200,000 people fly under Section 336 [AMA members] and the remaining 700,000 [drone owners] are required to operate under Part 107" (and should be "punished" by the FAA if they don't join AMA)After declaring that, Hanson admits he is actually lying:
"we acknowledge that some tweaks to Section 336 may be necessary to clarify who the provision does and does not cover."
There is no need to further dissect the article. It is a total fraud, as is Rich Hanson. Look it up yourself.
The proof is in the pudding (like Rich Hanson's brain now, apparently). Hanson flushed the sweet deal of no regulation and Section 366 down the toilet over drones and FPV. Congress booted the AMA and the FAA took over. It's too bad this is a tempest in a tea pot in the big scheme of things. The epic meltdown of a once great institution like AMA could be compared to the Boy Scouts of America. But in AMA case it is all due to one megalomaniac and a couple of his lakeys.
11-08-2022, 04:54 AM
#6
Thread Starter
From experience with OSHA 1910 and 30 CFR 250 as well as various other FAA regs, when the Feds recommend, in the form of "may" statements, ignore at your own peril. If you don't have something in place and there's an event that gets FAA's attention, they're going to hammer that you didn't have such a system. Lawyers, as in injury/property damage types, also seize on that and pounce when an organization ignores the regulators recommendations. Just add a couple zeros to the settlement. And given AMA's finances, one serious claim and they could lose it all.
If AMA chooses to hang their future on the fact that it's not compulsory, they're handing feds and lawyers the stick to beat them with. Combine that with an unwillingness to hold folks (turbine community in particular) accountable in a meaningful way, and they're just one roll of the dice away from ruin. But what do I know. Not like I can predict the shape of regulatory environment 8 years in the future.
If AMA chooses to hang their future on the fact that it's not compulsory, they're handing feds and lawyers the stick to beat them with. Combine that with an unwillingness to hold folks (turbine community in particular) accountable in a meaningful way, and they're just one roll of the dice away from ruin. But what do I know. Not like I can predict the shape of regulatory environment 8 years in the future.
11-08-2022, 06:59 AM
#8
For those not familiar with how AMA clubs function, most put out a monthly newsletter typically online for a couple decades now. Within this newsletter is usually reports for various club officers including the safety officer. If there had been an injury or close call within the previous month it would have been reported in the news letter. I will use the SCCMAS club as an example. There was an incident where a club member had his hand mangled by a prop. The incident was brought to light in the next news letter with tips for preventing such an occurrence. I myself had a lockout which resulted in a 40% Extra gliding over interstate 101 and impacting on a hill beyond the freeway. That too was mentioned in the newsletter. If one were to scour clubs archives of news letters you would find other examples. Then of course there are those incidents that result in a claim filed with the AMA’s insurance carrier such as the fire that was started in an adjacent field to the Sacramento Area Modelers. So in reality there have been incident reports being made. Maybe not to the level that some think they should. That could very well be the “‘ we’re pretty smart “ comment, as to a certain degree what Franklin was suggesting was already being done.
11-08-2022, 08:26 AM
#9
Senior Member
For those not familiar with how AMA clubs function, most put out a monthly newsletter typically online for a couple decades now. Within this newsletter is usually reports for various club officers including the safety officer. If there had been an injury or close call within the previous month it would have been reported in the news letter. I will use the SCCMAS club as an example. There was an incident where a club member had his hand mangled by a prop. The incident was brought to light in the next news letter with tips for preventing such an occurrence. I myself had a lockout which resulted in a 40% Extra gliding over interstate 101 and impacting on a hill beyond the freeway. That too was mentioned in the newsletter. If one were to scour clubs archives of news letters you would find other examples. Then of course there are those incidents that result in a claim filed with the AMA’s insurance carrier such as the fire that was started in an adjacent field to the Sacramento Area Modelers. So in reality there have been incident reports being made. Maybe not to the level that some think they should. That could very well be the “‘ we’re pretty smart “ comment, as to a certain degree what Franklin was suggesting was already being done.
11-08-2022, 08:49 AM
#11
Senior Member
11-08-2022, 09:27 AM
#13
Senior Member
11-08-2022, 09:42 AM
#14
He had also claimed that the FAA would NEVER (emphasis added) allow the AMA to administer the UAS knowledge test and that one of the test requirements was to read sectional charts. If memory serves, I believe claimed this information came from one of his “ FAA contacts “. So unless Franklin is an authorized agent of the FAA I’ll not be taking anything at face value without further verification.
Last edited by speedracerntrixie; 11-08-2022 at 09:56 AM.
11-08-2022, 10:30 AM
#15
Hi guys, interesting thread ya got goin on here.....
Anyway, I figured I'd pop in just to say this;
If ya'll wanna know what the FAA intends WRT this compilation of safety data business, why not just Email them and ask? As you may remember from a different thread, I Emailed them to ask about C/L flying during a TFR and they responded in less than 24 hours with a return Email stating that C/L model airplanes are indeed subject to TFRs (to mine and everyone else's surprise/dismay).
One quick Email could end DAYS of endless speculation, , , , , yes ? .....
Anyway, I figured I'd pop in just to say this;
If ya'll wanna know what the FAA intends WRT this compilation of safety data business, why not just Email them and ask? As you may remember from a different thread, I Emailed them to ask about C/L flying during a TFR and they responded in less than 24 hours with a return Email stating that C/L model airplanes are indeed subject to TFRs (to mine and everyone else's surprise/dismay).
One quick Email could end DAYS of endless speculation, , , , , yes ? .....
11-08-2022, 11:04 AM
#17
Senior Member
He had also claimed that the FAA would NEVER (emphasis added) be allowed to administer the UAS knowledge test and that one of the test requirements was to read sectional charts. If memory serves, I believe claimed this information came from one of his “ FAA contacts “. So unless Franklin is an authorized agent of the FAA I’ll not be taking anything at face value without further verification.
Government safety metrics were inevitable as soon as AMA claimed drones were model aircraft under Section 336. Franklin gets credit for that foresight. What did AMA think would happen? Right on top of Section 336 is this (2012):
Notwithstanding any other provision of law relating
to the incorporation of unmanned aircraft systems into Federal Aviation
Administration plans and policies
And before that this, with several paragraphs and subsections (a) through (d):
SEC. 332. INTEGRATION OF CIVIL
UNMANNED AIRCRAFT SYSTEMS INTO NATIONAL
AIRSPACE SYSTEM.
In the face of that legal mandate Hanson et al though they could take control of drones away from the FAA? Looks even more stupid as time goes by.
11-08-2022, 11:33 AM
#19
Senior Member
11-08-2022, 11:55 AM
#21
Senior Member
Here's some speculation for you. In that video of the three AMA stooges, Tyler Dobbs directly references Flight Test when he mentions the FAA doesn't want a backyard FRIA with one person. Backyard FRIAs was a proposal from Flight Test when Josh Bixler visited the FAA UAS Integration Office. It sounded like a fantasy at the time. But two backyards combined? Flight test is going to cut into AMA's market and they know it. That's why that trio got into the weeds with Remote ID and and talking about testing testing modules at AMA headquarters.
For some reason this bunch can't figure out that fixed fields are AMA's key asset and core mission, or at least should be. Just like drones and FPV, every module sold is one more person who has no need for AMA. Their loss and Flight Test's gain. Flight Test is going to sponsor flying sites but they are a virtual RC community, i.e., RC outside of fixed fields.
11-08-2022, 02:55 PM
#23
I thought you were capable of pushing the quote button.
Here's some speculation for you. In that video of the three AMA stooges, Tyler Dobbs directly references Flight Test when he mentions the FAA doesn't want a backyard FRIA with one person. Backyard FRIAs was a proposal from Flight Test when Josh Bixler visited the FAA UAS Integration Office. It sounded like a fantasy at the time. But two backyards combined? Flight test is going to cut into AMA's market and they know it. That's why that trio got into the weeds with Remote ID and and talking about testing testing modules at AMA headquarters.
For some reason this bunch can't figure out that fixed fields are AMA's key asset and core mission, or at least should be. Just like drones and FPV, every module sold is one more person who has no need for AMA. Their loss and Flight Test's gain. Flight Test is going to sponsor flying sites but they are a virtual RC community, i.e., RC outside of fixed fields.
Here's some speculation for you. In that video of the three AMA stooges, Tyler Dobbs directly references Flight Test when he mentions the FAA doesn't want a backyard FRIA with one person. Backyard FRIAs was a proposal from Flight Test when Josh Bixler visited the FAA UAS Integration Office. It sounded like a fantasy at the time. But two backyards combined? Flight test is going to cut into AMA's market and they know it. That's why that trio got into the weeds with Remote ID and and talking about testing testing modules at AMA headquarters.
For some reason this bunch can't figure out that fixed fields are AMA's key asset and core mission, or at least should be. Just like drones and FPV, every module sold is one more person who has no need for AMA. Their loss and Flight Test's gain. Flight Test is going to sponsor flying sites but they are a virtual RC community, i.e., RC outside of fixed fields.
Astro
11-10-2022, 05:39 AM
#24
Thread Starter
First, I'll address Speedy's criticim of some things he said that I said. I was in contact with folks I know in FAA when the whole testing thing was in draft. My friends were pushing hard for the sectional reading etc., but it did not make it into the final version. That happens. But that can always change in the future. And yes, I was wrong about AMA being able to administer TRUST.
But I was right about increasing regulation, right about the AMA financial trajectory, right about move away from requiring CBO membership and - as we see above - right about eventual need to have metrics in support of legitimate Safety Management System (SMS). All of which I'd argue are just a touch more important.
Echo you're correct. AMA has said they have an SMS, but I submit what they have exists in name only. A true SMS would have some level of standardized data collection, lessons learned collection, and regular sharing of those events and KPIs across the entire organization. You don't see AMA talk about common factors in recent near misses, injuries, etc. like those described above. Even issues with compliance among certain communities isn't shared widely, limiting CD's ability to watch for similar behaviors in other communities. That's how true SMS function, info sharing, common factors, responding to KPIs, and continuous improvement. When regulators come look at a system like AMA's, this is what you see in their audit report: "fragmented SMS" or one that "lacks integration" or one that "ineffectively uses KPIs and audits to evaluate and improve SMS effectiveness."
But I was right about increasing regulation, right about the AMA financial trajectory, right about move away from requiring CBO membership and - as we see above - right about eventual need to have metrics in support of legitimate Safety Management System (SMS). All of which I'd argue are just a touch more important.
For those not familiar with how AMA clubs function, most put out a monthly newsletter typically online for a couple decades now. Within this newsletter is usually reports for various club officers including the safety officer. If there had been an injury or close call within the previous month it would have been reported in the news letter. I will use the SCCMAS club as an example. There was an incident where a club member had his hand mangled by a prop. The incident was brought to light in the next news letter with tips for preventing such an occurrence. I myself had a lockout which resulted in a 40% Extra gliding over interstate 101 and impacting on a hill beyond the freeway. That too was mentioned in the newsletter. If one were to scour clubs archives of news letters you would find other examples. Then of course there are those incidents that result in a claim filed with the AMA’s insurance carrier such as the fire that was started in an adjacent field to the Sacramento Area Modelers. So in reality there have been incident reports being made. Maybe not to the level that some think they should. That could very well be the “‘ we’re pretty smart “ comment, as to a certain degree what Franklin was suggesting was already being done.
11-10-2022, 05:41 AM
#25
Thread Starter
For some reason this bunch can't figure out that fixed fields are AMA's key asset and core mission, or at least should be. Just like drones and FPV, every module sold is one more person who has no need for AMA. Their loss and Flight Test's gain. Flight Test is going to sponsor flying sites but they are a virtual RC community, i.e., RC outside of fixed fields.