RASG‐PA ESC/29 — WP/04 14/11/17 Twenty ‐ Ninth Regional Aviation Safety Group — Pan America Executive Steering Committee Meeting (RASG‐PA ESC/29) ICAO NACC Regional Office, Mexico City, Mexico, 29‐30 November 2017 Agenda Item 3: Items/Briefings of interest to the RASG‐PA ESC PROPOSAL TO AMEND ICAO FLIGHT DATA ANALYSIS PROGRAMME (FDAP) RECOMMENDATION AND STANDARD TO EXPAND AEROPLANES´ WEIGHT THRESHOLD (Presented by Flight Safety Foundation and supported by Airbus, ATR, Embraer, IATA, Brazil ANAC, ICAO SAM Office, and SRVSOP) EXECUTIVE SUMMARY The Flight Data Analysis Program (FDAP) working group comprised by representatives of Airbus, ATR, Embraer, IATA, Brazil ANAC, ICAO SAM Office, and SRVSOP, is in the process of preparing a proposal to expand the number of functional flight data analysis programs. It is anticipated that a greater number of Flight Data Analysis Programs will lead to significantly greater safety levels through analysis of critical event sets and incidents. Action: The FDAP working group is requesting support for greater implementation of FDAP/FDMP throughout the Pan American Regions and consideration of new ICAO standards through the actions outlined in Section 4 of this working paper. Strategic Safety Objectives: References: Annex 6 ‐ Operation of Aircraft, Part 1 sections as mentioned in this working paper RASG‐PA ESC/28 ‐ WP/09 presented at the ICAO SAM Regional Office, 4 to 5 May 2017. 1. Introduction 1.1 Flight Data Recorders have long been used as one of the most important tools for accident investigations such that the term “black box” and its recovery is well known beyond the aviation industry. The safety advances in the industry from flight data recorders have been invaluable. RASG‐PA ESC/29 — WP/04 — 2 — 1.2 As Flight Data Recorder technology has advanced, the aircraft operators around the world have sought to make use of this data in their safety management systems under Flight Data Analysis/Monitoring FDAP/FDAM programs. 1.3 As a result of both the learning from accident investigations and the desire to learn more from current operational data, the ICAO council adopted a proposal on FDAP/FDMP programs that first became applicable in November 1, 2001. Subsequently this was revised through Amendment 30 in 2006. The latest language of Annex 6, Part 1 (Edition 10, Amendment 41) Chapter 3 states: 3.3 SAFETY MANAGEMENT 3.3.1 Recommendation.— The operator of an aeroplane of a certificated take‐off mass in excess of 20 000 kg should establish and maintain a flight data analysis programme as part of its safety management system. 3.3.2 The operator of an aeroplane of a maximum certificated take‐off mass in excess of 27 000 kg shall establish and maintain a flight data analysis programme as part of its safety management system. Note.‐ The operator may contract the operation of a flight data analysis programme to another party while retaining overall responsibility for the maintenance of such a programme. 3.3.3 A flight data analysis programme shall be non‐punitive and contain adequate safeguards to protect the source(s) of the data. Note 1.‐ Guidance on the establishment of flight data analysis programmes is included in the Manual on Flight Data Analysis Programmes (FDAP) (Doc 10000). Note 2.‐ Legal guidance for the protection of information from safety data collection and processing systems is contained in Attachment B to the first edition of Annex 19. 3.3.4 The operator shall establish a flight safety documents system, for the use and guidance of operational personnel, as part of its safety management system. Note.‐ Guidance on the development and organization of a flight safety documents system is provided in Attachment F. 1.4 Now after two decades of flight data analysis programs, much has changed in the costs and potential benefits of these programs. Early programs were often burdened by the costs of specific aircraft configurations to support FDAP/FDMP with Quick Access Recorders (QARs), computer storage devices for extracted data, software analysis packages, staff headcount to manage the programs and more. The analysis capability has expanded and now benefits many aspects of safety and operational efficiency. RASG‐PA ESC/29 — WP/04 — 3 — 1.5 The RASG‐PA FDAP working group was assembled to examine current costs and benefits with the objective of promoting greater participation in FDAP/FDMP programs on all aeroplanes equipped with Flight Data Recorders. This would target aeroplanes over 5 700 kg up to 27 000 kg. There is no current requirement for FDAP/FDMP programs between 5 700 kg and 20 000 kg AND it is only recommended for aeroplanes from 20 000 kg up to 27 000 kg. 1.6 As a result of the review, a new alternative recommendation and standard proposal to expand weight threshold are as follows: 3.3.1 Recommendation.‐ All aeroplanes of a maximum certificated take‐off mass over 5 700 kg should be equipped with a Quick Access Recorder (QAR). This QAR should record at a minimum the parameters recorded by the Flight Data Recorder and the operator should establish and maintain a flight data analysis programme as part of its safety management system. 3.3.2 All aeroplanes of a maximum certificated take‐off mass over 5 700kg for which the individual certificate of airworthiness has been first issued on or after 1 January 2005 shall be equipped with a Quick Access Recorder (QAR). This QAR shall record at a minimum the parameters recorded by the Flight Data Recorder and the operator shall establish and maintain a flight data analysis programme as part of its safety management system. 2. Cost Benefit Analysis for Flight Data Analysis/Monitoring Programs 2.1 The RASG‐PA FDAP working group has completed a cost benefit report as of September 2017. The document describes the most likely areas of costs for implementing a FDAP/FDMP program with current operations with a special focus on organizations operating aeroplanes in the 5 700 kg to 20 000 kg MTOW range. The report is included as Appendix A to this working paper. 2.2 The report references many of the original implementation considerations and how those have changed. It provides operators and other stakeholders with greater tools to determine their current implementation costs, including optional costs on aircraft configuration. 2.3 Benefits are described in terms of the potential improvements that could be achieved in existing accident rates. The document recognizes that original FDAP/FDMP programs did not forecast a specific rate reduction before programs were adopted. Yet over the past twenty years improvements continue and accident rates are lower than ever before. Implementation may make much more practical sense today as costs have become much more affordable. 2.4 A review of the current accidents in the 5 700 to 27 000 Kg MTOW range is provided for the Pan American region in the cost benefit analysis (CBA) Appendix A1. RASG‐PA ESC/29 — WP/04 — 4 — 2.5 A review of all worldwide aeroplanes with MTOW between 5 700 kg to 27 000 kg and organizations operating aeroplanes with that range is also provided in CBA Appendix A2 and A3. It should be noted that a sizeable portion of the existing aircraft are likely to already be operating with on‐ going FDAP/FDMP programs. Both of these can be used for determination of the level of operations impacted by a proposal to implement FDAP/FDMP programs. In Appendix B, a costs and benefits spreadsheet is attached. 3. The need for a Business Case 3.1 In order to accomplish the expansion in implementation, a business case is essential to describe both the costs and benefits. This CBA recognizes the much more affordable options to FDAP/FDMP implementation and helps to provide a compelling story for action. This CBA also provides the necessary tools for organizations and States to assemble this business case as best suites their requirements. 3.2 Ultimately, this can lead to a specific proposal to the ICAO Air Navigation Commission (ANC) for adoption as new ICAO standard. 3.3 In the meantime, the RASG‐PA FDAP working group recommends formulating an immediate safety enhancement to be considered by Industry in Pan American RASG‐PA States. The FDAP standard proposal would be brought to RASG‐PA Plenary using the fast track mechanism, considering that the next RASG‐PA Plenary will take place in approximately two years, and to the Pan American RSOOs and RAIOs for coordination and promotion. 4. Suggested actions 4.1 The RASG‐PA ESC/29 is invited to take note of this working paper, make comments and circulate a proposal of conclusion to be adopted by RASG‐PA members as follows: a) States take note of the results of the cost‐benefit analysis (CBA) developed by RASGPA FDAP working group for the implementation of FDAP on aeroplanes over 5 700 kg; b) States and RSOO to consider the incorporation of a requirement in their national/regional regulations; and c) Request to the ICAO ANC to take note on the results of the CBA and consider an amendment to Annex 6 Part I FDAP Recommendation 3.3.1 and Standard 3.3.2 of Section 3.3, as worded in 1.6 of this working paper. — — — — — — — — — — — COST-BENEFIT ANALYSIS FOR EXTENDING ICAO’S ANNEX 6, PART I, STANDARD 3.3.2 1 Table of Contents CHAPTER 1. BACKGROUND............................................................................................................................2 CHAPTER 2. JUSTIFICATION FOR THE NEW STANDARD...........................................................................5 CHAPTER 3. COST-BENEFIT ANALYSIS .........................................................................................................7 3.1. ASSUMPTIONS OF THE MODEL.........................................................................................................7 3.1.1. QAR vs. FDR........................................................................................................................8 3.1.2. In-house vs. Outsourced Flight Data Analysis.....................................................................9 3.1.3.