Distribution: Electronic Initiated By: AIR-150 

 10/1/2012 

 

SUBJ: Monitor Safety/Analyze Data 

 

This order contains the Monitor Safety/Analyze Data (MSAD) process, designed to promote an 

improved continued operational safety (COS) methodology by incorporating a data-driven, riskbased approach for safety assurance and safety risk management. MSAD supports aviation 

products throughout their life cycle. 

This order describes how the Aviation Safety organization (AVS) staff uses MSAD within the 

Aircraft Certification Service’s (AIR) Safety Management System (SMS) to identify and manage 

risk in aviation products. 

MSAD uses product defined hazard criteria to surface potential hazards from aviation safety 

data. MSAD uses a standard taxonomy for organizing COS data and promotes quick 

identification of emerging safety trends. 

In addition, MSAD establishes a causal analysis approach. This approach may identify 

underlying contributing factors, such as process breakdowns, which we then communicate to the 

appropriate AVS oversight business process owner. 

The MSAD process is heavily based on existing industry best practices. MSAD builds a safety 

risk management model that sets the example for how we expect industry to evolve, in taking 

responsibility for the safety of their aviation products. 

Susan J. M. Cabler 

Acting Manager, Aircraft Engineering Division 

 Aircraft Certification Service 

ORDER 

8110.107A National Policy 
10/01/2012 8110.107A 

 ii 

REVISION HISTORY 

Rev Description of Change Effective Date

0 Original 3/12/2010 

1 Major Changes: 

 Page 1, Para 1-2: Clarified that references to “ACO” may 

apply to other offices in AIR when those offices have 

responsibility for continued operational safety oversight 

 Page 1, Para 1-3: Changed all references of AIR-140 to AIR150, the new business process owner 

 Page 4, Fig. 2: Revised MSAD process flow to enhance 

readability and reflect changes to process 

 Page 6, Para 2-6: More guidance for marking events as “false 

positives” 

 Page 7, Para 2-7: Added guidance for minimizing single 

point safety decisions during the preliminary risk assessment 

 Page 8, Para 2-9: Clarified responsibilities for TSO articles 

and standard parts installed on multiple product types that 

span purview of more than one directorate 

 Page 9, Para 2-9a: Added information encouraging 

involvement of AEG 

 Page 10, Para 2-9c: Added a third risk value, “Time until 

control program risk guideline is reached,” which must be 

calculated as part of the risk analysis 

 Page 12, Fig. 4: Added a diagram outlining the corrective 

action timeline 

 Page 13, Para 2-10: Moved CARB section (previously para 

2-15) for improved readability and added responsibility for 

CARB when dealing with MCAIs 

 Page 15, Para 2-11: Clarified when a “structured” root causal 

analysis must be performed 

 Page 17, Para 2-15b: Added guidance for determining the 

appropriate corrective action 

 Page 26, Chapter 4: Added chapter on applying the MSAD 

process to foreign products 

 Page 33, Chapter 7: Added chapter detailing situations where 

exceptions may be made to the MSAD process 

10/1/2012 
10/01/2012 8110.107A 

 iii 

Table of Contents 

Paragraph Page 

Chapter 1. General Information................................................................................... 1

1-1. Purpose of this Order. ...........................................................................................................1 

1-2. Audience................................................................................................................................1 

1-3. Certificate Holder Engagement. ...........................................................................................1 

1-4. Where to Find This Order.....................................................................................................1 

Chapter 2. MSAD Process Overview .......................................................................... 2

2-1. Purpose of the MSAD Process. ...........................................................................................2 

2-2. Range of the MSAD Process...............................................................................................2 

2-3. MSAD Overview. ................................................................................................................2 

2-4. The MSAD Process Flow.....................................................................................................3 

2-5. Acquire Data (Step 1.0). .......................................................................................................6 

2-6. Hazard Criteria Analysis (Step 2.0)......................................................................................6 

2-7. Perform Preliminary Risk Assessment (Step 3.0). ..............................................................7 

2-8. Initiate Immediate Corrective Action (Step 4.0)..................................................................8 

2-9. Record Risk Analysis Results (Step 5.0). ............................................................................8 

2-10. CARB. ...............................................................................................................................13 

2-11. Safety Issue Cause(s) (Step 6.0).......................................................................................15 

2-12. Perform Causal Analysis (Step 7.0). ................................................................................16 

2-13. Document the Cause(s) (Step 8.0)....................................................................................16 

2-14. Identifying Causes and Contributing Factors. .................................................................16 

2-15. Evaluate and Select Corrective Action for a Fleet Issue (Step 9.0)................................17 

2-16. Submit to Process Owner for Further Analysis (Step 10.0)............................................21 

2-17. Submit Cause to Certificate Oversight Process (Step 11.0)............................................22 

2-18. Document and Submit Issue to External Organization (Step 12.0)................................22 

2-19. Initiate AD, SAIB or other Corrective Action Process (Step 13.0)................................22 

2-20. Prepare Internal Feedback to MSAD Process Owner (Optional) (Step 14.0). ..............22 

2-21. Prepare Lessons Learned (Step 15.0)...............................................................................22 

Chapter 3. Follow On and Trending.......................................................................... 23

3-1. Monitor and Validate. ........................................................................................................23 

3-2. Trending..............................................................................................................................23 

Chapter 4. Applying MSAD to Foreign Products..................................................... 26

4-1. Introduction. .......................................................................................................................26 

4-2. Addressing MCAI..............................................................................................................26 

4-3. Addressing Events..............................................................................................................27 

Chapter 5. Roles and Responsibilities ..................................................................... 29

5-1. Process Owner Responsibilities.........................................................................................29 

5-2. AIR-110 Responsibilities...................................................................................................29
10/01/2012 8110.107A 

 iv 

Table of Contents (Continued) 

5-3. AIR-120 and AIR-130 Responsibilities............................................................................29 

5-4. Directorate Responsibilities...............................................................................................29 

5-5. Responsibilities of offices responsible for COS oversight...............................................30 

Chapter 6. Background.............................................................................................. 31

6-1. AIR SMS. ...........................................................................................................................31 

6-2. Industry Interface and Applicability..................................................................................31 

6-3. Benefits of the MSAD Process..........................................................................................32 

6-4. MSAD Tool Support..........................................................................................................32 

Chapter 7. Exceptions................................................................................................ 33

7-1. Exceptions to Some Requirements of this Order..............................................................33 

Appendix A. Definitions and Acronyms................................................................. A-1

Appendix B. Administrative Information............................................................... B-1

Appendix C. Directive Feedback Information ........................................................ C-1
10/01/2012 8110.107A 

1 

Chapter 1. General Information 

1-1. Purpose of this Order. This order explains how you will use the MSAD process to 

analyze COS data and monitor safety in aircraft fleets. In this order, we describe the steps of the 

process, the tasks within those steps, and the responsibilities incumbent on all process users for 

all product types. 

1-2. Audience. We, the FAA, wrote this order for aviation safety engineers (ASE), aviation 

safety inspectors (ASI), aircraft certification offices (ACO*) staffs, directorate standards staffs, 

and all Aircraft Certification Service (AIR) and Flight Standards Service (AFS) personnel 

responsible for monitoring and addressing product safety risks. 

*Note: For the purposes of this order, the term “ACO” is used as 

defined in FAA Order 8100.5, Aircraft Certification Service, 

paragraph 1-8(c). The term “ACO” also applies to an FAA 

office responsible for COS oversight. 

1-3. Certificate Holder Engagement. Compatible certificate holder processes that are 

acceptable to the FAA ACO can be used in lieu of functions identified for FAA personnel 

throughout this order. The ACO, Safety Management Design and Analysis Branch (AIR-150) 

and the appropriate directorates should coordinate to ensure these processes provide an adequate 

oversight role for the ACO in ensuring that the objectives of this order are met. 

1-4. Where to Find This Order. You can find this order on the MyFAA Employee website at 

https://employees.faa.gov/tools_resources/orders_notices/ or the FAA’s Regulatory and 

Guidance Library (RGL) website at http://rgl.faa.gov. 
10/01/2012 8110.107A 

2 

Chapter 2. MSAD Process Overview 

2-1. Purpose of the MSAD Process. We designed the MSAD process to filter, review, 

analyze and trend aviation safety data. The MSAD process helps us identify safety issues in the 

in-service aircraft fleets, and identify corrective actions to mitigate safety risks across the fleet. 

The process also identifies other causes of safety issues that cannot be addressed by fleet 

(product/part) corrective actions. MSAD users should submit these causes to the appropriate 

organization and/or process owner (whether inside or outside AIR) for further analysis and 

action. 

2-2. Range of the MSAD Process. 

a. We intend the MSAD process to analyze in-service data to determine corrective 

action for COS issues. The MSAD process covers everything from receiving data to determining 

fleet corrective action. Issuing the corrective action, including the notice of proposed 

rulemaking (NPRM) process, is outside MSAD. It is part of the airworthiness directive (AD), 

special airworthiness information bulletin (SAIB), and/or other FAA actions or 

recommendations processes. 

b. Certain certificate holders have their own processes to filter, review, analyze and 

trend aviation safety data on their products. We expect the ACOs will continue to foster 

cooperative COS agreements which integrate the certificate holders’ processes with the MSAD 

process in a manner that is compatible with this order. In those instances, the certificate holder 

will accomplish many of the steps defined in this order to address the safety of their products 

with the ACO ASE performing an oversight role. 

c. MSAD may also interface with other AIR processes, non-AIR FAA processes, and 

industry, to help identify non-fleet-based problems. For example, ASEs and ASIs who oversee 

the certificate holder may analyze product design, production, operations, and maintenance 

process data to identify certificate holder risks and corrective actions that should reduce aircraft 

fleet risks. 

2-3. MSAD Overview. As an ASE following the MSAD process, you perform both a risk 

analysis of the potential safety issue and a causal analysis. Following the MSAD process, you 

initiate the AD or SAIB (or other corrective actions or recommendations) as required. When you 

complete the process, you store event data, safety issues, risk analysis, causal analysis and 

corrective action data for future use. Figure 1 is a high-level view of the entire process. 

Although we display and describe the components sequentially, you may encounter situations 

where portions of the process are worked concurrently or out of sequence. 
10/01/2012 8110.107A 

3 

Figure 1. High-Level View of MSAD 

2-4. The MSAD Process Flow. In figure 2, the entire MSAD process is given in fifteen steps. 

Subsequent paragraphs explain every step. We will expand some steps, like risk analysis, into 

more detail as we discuss them. 

Aviation data, 

in a standard 

taxonomy, is 

collected by 

automation, 

provided by 

certificate 

holders or 

captured by 

other 

methods.

Aviation data 

is filtered, 

using 

automation 

and/or 

manually, to 

identify 

event data 

likely to 

identify 

safety 

issues.

Senior COS ASE(s) 

conducts 

qualitative 

assessment to filter 

the data or issues 

quick disposition 

(Emergency ADs, 

Final rule; request 

for comments and 

obvious nonissues).

ASE evaluates 

certificate holder 

risk analysis or 

performs 

quantitative risk 

analysis to 

identify safety 

issues for 

corrective action.

Risk 

is reduced

Acquire 

data

Conduct 

hazard 

criteria 

analysis

Perform 

preliminary 

risk 

assessment

Aviation 

data 

triggers 

MSAD

Perform 

risk 

analysis

ASE identifies 

causes that 

contributed to the 

event. ASE 

identifies candidate 

product/part 

solutions and 

submits nonproduct/part cause 

information to 

applicable parties.

Identify 

causes

ASE works with 

other AIR and 

AVS experts to 

identify and 

evaluate 

candidate 

corrective actions 

to reduce risk. 

May lead to the 

initiation of an 

AD or nonmandatory 

corrective action.

Select 

corrective 

action

Monitor and validate corrective actions
10/01/2012 8110.107A 

4 

Figure 2. MSAD Process Flow Page 1 

Note: See Chapter 3 for details on link C. See figure 3 for details on step 5.0.
10/01/2012 8110.107A 

5 

Figure 2. MSAD Process Flow - Page 2 

External 

(non-AIR) 

issues 

documentation

AD, SAIB 

or other 

optional 

corrective 

action 

information

ASE

Initiate AD, 

SAIB* or other 

corrective action

process

7.0 8.0

ASE

Perform causal 

analysis

ASE

Evaluate & select 

corrective action 

for a fleet issue 

(CARB Decision) ASE

Submit cause 

to certificate 

oversight 

process

Cause/effect 

chart

AD, SAIB 

or other 

optional 

corrective 

action 

decision

6.0

12.0

14.0

13.0

15.0

ASE

Prepare internal 

feedback to 

MSAD process 

owner 

(optional)

Feedback 

ASE

Prepare COS 

lesson learned, 

as necessary

Lessons 

learned END

ASE

Submit to 

process owner 

for further 

analysis

9.0

Is the safety 

issue cause(s) 

unclear?

People/

process issue 

documentation

Process issue 

documentation

10.0 11.0

Product/part 

cause? Internal AIR 

process or people 

Yes cause?

Yes

Design or 

Production 

Certificate holder

cause?

Yes

Maintenance 

or operations 

cause?

Yes

Cause(s)

ASE

Document the 

cause(s)

Link A 

MSAD

(figure 2, 

page 1)

Link B

Monitor & 

validate

(paragraph 

3-1)

ASE

Document & 

submit issue 

to external 

(non-AIR) 

organization

 Was previous 

corrective action 

ineffective?

Does CARB 

recommend

RCA?

No No

Yes Yes Yes

No
10/01/2012 8110.107A 

6 

2-5. Acquire Data (Step 1.0). Data is acquired from FAA databases using an automated batch 

process. Acquired data can also be manually input, such as a report satisfying the requirement 

found in Title 14 of the Code of Federal Regulations (14 CFR) 21.3 and 183.63. In both cases, 

the data goes to an electronic form called the MSAD record. Not all event data will be analyzed 

through the MSAD process. Hazard criteria (described in paragraph 2-6) are used to filter out 

the events that do not present potential safety issues. However, the events that are filtered out 

can still be used for trending purposes. 

a. Responsible Office. MSAD software sends event data to the responsible office for 

the applicable product-type. When event data applies to more than one product-type, MSAD 

software sends it to all responsible offices based on the make and model. If all offices indicate 

they are not responsible for the event data, the software will send the event data to AIR-150 for 

resolution. When the event data does not contain any product-type data that is directly traceable 

to an aircraft, engine, or propeller, such as an appliance, the software sends it to all offices to 

determine whether the part/appliance is installed on any of the aircraft for which the office has 

type certificate (TC)/supplemental type certificate (STC) oversight. An MSAD record will not 

show that it is fully “closed” until all offices involved have completed their review and taken 

appropriate action to close the record. Sometimes more than one office may need to remedy 

safety issues related to a single event. 

b. Taxonomy. MSAD taxonomy is aligned with the FAA’s Commercial Aviation 

Safety Team (CAST) and International Civil Aviation Organization (ICAO) common taxonomy 

team (CICTT). MSAD taxonomy is more in-depth and detailed than CICTT because CICTT 

terms are currently top-level event descriptors only. MSAD supplements CICTT taxonomy with 

lower-level event descriptions, part name, and other details. CICTT taxonomy is still evolving. 

New terms and changes in hierarchy may or may not fit the MSAD application. However, we 

intend to keep MSAD aligned with CICTT taxonomy as it matures. 

c. Event Data Sources. Sources of safety data include FAA databases focusing on 

event information. We expect industry sources to increase as cooperative data sharing increases. 

ASEs can manually create an event record from any data source. The ACO COS focal can 

import event data from external sources via the data portal. Automation will pull data from 

certain databases and submit those as event records to the cognizant ACOs and directorates 

based on the make and model. ACO and directorate personnel can manually enter event records 

from any data source. Manufacturing inspection district office (MIDO) personnel can manually 

enter event records associated with quality escapes. We anticipate that automation will be 

modified to add additional data sources. 

2-6. Hazard Criteria Analysis (Step 2.0). Hazard criteria are used to automatically or 

manually filter event data. Filtering reduces the number of events that the senior COS ASE(s) 

must review for potential safety issues during the preliminary risk assessment. Automatic 

filtering is based on keyword, key-phrase matches, or other data mining techniques of the event 

data for the product type. For example, a filter might be one that sends forward any event 

description that includes the word “fire.” Event data that does not meet the hazard criteria is 

retained and can be used for trending. If senior COS ASE(s) determine that the event should not 
10/01/2012 8110.107A 

7 

have passed the hazard filtering criteria, then the event should be marked as a “false positive” to 

assist directorates in refining the hazard criteria. 

Note: Automation will not filter § 21.3 reports or other 

safety data submitted under negotiated agreements since 

the agreement will typically include the hazard criteria. 

a. Product Type Hazard Criteria. Each directorate standards staff must develop and 

maintain their own hazard criteria to filter event data about their product type. 

b. Manual Sampling. Automated hazard criteria should continue to mature over time. 

The criteria list will be a living document. Directorate-assigned COS representatives must 

review, at least annually, samplings of events filtered by the hazard criteria to ensure that the 

criteria stay valid. The rate and frequency of events they sample may vary, based on process 

maturity and directorate/ACO needs.

2-7. Perform Preliminary Risk Assessment (Step 3.0). The purpose of the preliminary risk 

assessment is to quickly identify any safety issues needing an emergency AD or immediately 

adopted rule (IAR) (issued as a “final rule; request for comment”). It also determines whether an 

event indicates a potential safety issue requiring more investigation through the MSAD process. 

The assessment should take advantage of whatever data is immediately available. It is preferred 

to minimize single point safety decisions by doing multi-discipline assessments when manpower 

permits. This assessment can be performed by a group of senior COS ASEs, however any actual 

data analysis is usually performed by a single person. If a group assessment is performed, a 

cognizant senior ASE for the engineering discipline most affected by the event must participate. 

a. Review by Other Offices. Here, or at any other point in the MSAD process, the 

senior COS ASE(s) or assigned ASE may decide that there is a cross-product issue, and that 

other offices need to review the information. The senior COS ASE(s) or assigned ASE must 

enter the rationale in the MSAD record and submit it to the appropriate office(s). 

b. Questions for the Senior COS ASE(s). As the senior COS ASE(s), you must review 

the event to answer two key questions: 

(1) Is this a potential safety issue? 

(2) Does an urgent unsafe condition exist that requires immediate corrective action? 

c. Preliminary Risk Assessment Answers. The answers to those two questions 

determine the remaining steps in the process. 

(1) If you, the senior COS ASE(s), determine that there is a potential safety issue, 

you must define it and submit the resultant action to the assigned ASE to proceed with the risk 

analysis step (investigation may determine that there is negligible risk and that calculation of the 

risk is not required). If you are the cognizant engineer for this product, you can assign this 

potential safety issue to yourself. 
10/01/2012 8110.107A 

8 

(2) If you, the senior COS ASE(s), identify an urgent unsafe condition that requires 

immediate corrective action, you must define the safety issue and assign it to an ASE to initiate 

either an emergency AD or IAR (per step 4.0). The assigned ASE can delay the comprehensive 

risk analysis and causal analysis until after starting the emergency AD or IAR. Once the 

emergency AD or IAR starts, the assigned ASE must continue analyzing the safety issue in the 

risk analysis step. You or the assigned ASE may determine that an emergency AD or IAR is 

necessary later in the MSAD process as new data becomes available. 

Note: An emergency AD or IAR can be started based on 

an FAA estimate that the time in which the action is 

required is too short to allow the time necessary for public 

comment. (Reference FAA Manual FAA-IR-M 8040.1, 

Airworthiness Directives Manual.) 

(3) If you, the senior COS ASE(s), determine that no further action is necessary, 

you must document that determination. The event does not move any further in the event 

evaluation portion of the MSAD process, but is retained for trending. Prior to closing the MSAD 

event, you should ensure that MSAD events discovered to be false positives are marked, and that 

the MSAD record is routed to appropriate offices, as necessary. 

2-8. Initiate Immediate Corrective Action (Step 4.0). If a safety issue is urgent, you, the 

assigned ASE, must start either an emergency AD or IAR per FAA Order 8040.1, Airworthiness 

Directives; FAA Manual FAA-IR-M 8040.1; and any directorate-specific procedures. This 

ensures that the risk is mitigated in a timely fashion, without waiting for the remaining MSAD 

process steps. 

2-9. Record Risk Analysis Results (Step 5.0). MSAD risk analysis objectively characterizes 

hazards for probability and severity, and determines the risk posed by each hazard associated 

with a given safety issue. Each directorate may have particular risk measures based on their 

product type. If you are an assigned ASE, you are responsible for the risk analysis, and you must 

record the total uncorrected fleet risk and the uncorrected individual risk (per flight or per flighthour) and compare them to directorate-defined risk guidelines, as applicable, for issuing ADs or 

other mandatory corrective actions for the product type. If the safety issue is associated with an 

appliance, technical standard order (TSO) article or standard part, the safety issue could be 

associated with multiple product types and the assigned ASE should obtain any available 

information from the manufacturer to determine product applicability to support the risk 

assessment. In certain cases where the safety effect is different depending on the installation or 

when the appliance, TSO article or standard part is installed on multiple product types that use 

different directorate-defined risk guidelines, the ASE should assign the MSAD records to the 

cognizant TC or STC oversight office to perform the risk analysis and subsequent follow-on 

actions. The risk guidelines for AD or other mandatory corrective action assist the CARB in 

determining if mandatory corrective action is warranted. The risk analysis process (step 5.0) is 

defined in the next paragraphs, and is illustrated in figure 3. 
10/01/2012 8110.107A 

9 

Figure 3. Record Risk Analysis Results Flow Diagram 

a. Identify ASI Support. If you, the assigned ASE, need manufacturing, maintenance 

or operations ASI support, you should contact an ASI responsible for the product and ask for 

information to support the risk analysis. Those ASIs may come from an aircraft evaluation 

group (AEG), flight standards district office (FSDO), certificate management office (CMO), 

MIDO and/or manufacturing inspection office (MIO). 

Note: When ASEs solicit information from flight 

standards ASIs in the field (i.e., FSDO or CMO), ASEs 

should either obtain the information through the cognizant 

AEG or notify the AEG that information is requested 

directly from the field. 

 

b. Identify Potential Outcomes. You, the assigned ASE, must identify and document 

all important potential outcomes for the potential safety issue you are studying for further risk 

analysis. If you determine that the risk of an outcome is obviously negligible, there is no need to 

calculate or document it. 
10/01/2012 8110.107A 

10 

c. Calculate the Risk Value of Each Outcome. You, the assigned ASE, must use the 

directorate-specified product-specific risk analysis method (resulting in units convertible to fatal 

accidents) to calculate the quantitative probability, severity, and risk value for each important 

outcome. Calculate and record these risk values: 

(1) Total uncorrected fleet risk; 

(2) Uncorrected individual risk (per flight or per flight hour); and 

(3) Time until control program risk guideline is reached (Not required if (1) and (2) 

are both below directorate risk guidelines). 

 

d. See table 1 for detailed descriptions of risk values. You, the assigned ASE, must 

attach the documents produced that support probabilities, severities and risk values for total 

uncorrected fleet risk and uncorrected individual risk (per flight or per flight hour) to the MSAD 

record containing the event information. 

Table 1 – Risk Value Definition, Purpose, and Mathematical Basis 

Risk Value Definition Purpose Mathematical Basis 

Total 

uncorrected 

fleet risk 

Predicted risk 

expected, over 

remaining life of 

affected fleet, if no 

corrective action is 

taken. 

Provides future risk if no 

corrective action is taken. 

Helps determine if an unsafe 

condition may exist in future. 

Used to guide decisions for 

corrective action. 

Computed as the product of the 

average severity and average 

per-flight (or flight-hour) 

probability of occurrence, 

multiplied by the exposure 

(flights or flight-hours) 

remaining in affected fleet life. 

If known voluntary compliance 

to an existing service document 

is supported by data, then you 

can account for the existing 

control actions by adjusting the 

affected fleet numbers. 
10/01/2012 8110.107A 

11 

Risk Value Definition Purpose Mathematical Basis 

Uncorrected 

individual 

risk 

Predicted risk per 

flight or per flighthour. 

Needed for cases of low fleet 

exposure that result in the 

total uncorrected fleet risk, as 

defined above, to be 

acceptable while the risk to 

an individual aircraft or 

person is unacceptable. 

Helps determine if an unsafe 

condition may exist in future. 

Used to guide the decision for 

corrective action. 

If only a subset of the fleet is 

subject to the risk, include 

only that portion in the 

analysis. Evaluate significant 

variations between 

identifiable subsets of the 

fleet (different models, 

different usages, etc.) as 

separate populations for the 

individual risk. 

Typically based on averages 

that apply to the fleet. 

However, there may be 

circumstances where you can 

calculate individual risk 

including risk values for special 

conditions and combinations of 

conditions, or for subsets of the 

fleet, for example by model or 

usage. 

Time until 

control 

program risk 

guideline is 

reached 

Amount of time from 

when the need for 

corrective action is 

determined by the 

CARB to the time 

when the fleet would 

exceed the control 

program risk 

guideline if no action 

was taken. With the 

agreement of the 

corrective action 

review board 

(CARB), this 

guideline may be 

exceeded in cases of 

severe resource 

availability or service 

disruption and there 

is no practical interim 

measures to reduce 

risk. 

Provides information to assist 

in risk management planning, 

i.e., how much time is 

available to determine root 

cause, develop service 

information, coordinate and 

process corrective action, and 

incorporate the corrective 

action in the fleet while 

staying within the risk 

guideline. See Figure 4 

On occasion the plan to issue 

corrective action material by a 

date that meets this guideline 

may fail to be achieved (e.g., 

the planned modification was 

discovered late in the process 

to not work). In those cases 

do not shorten compliance 

times to completely make up 

for the lost time; it is 

acceptable to recalculate the 

time until the program risk 

guideline is reached and start 

anew. However, give the 

issue extra supervision and 

emphasis to avoid a repeat 

and work to issue the 

corrective action material 

before the new date by as 

much as can be reasonably 

accomplished. 

The time period when risk 

accumulates in the fleet to a 

value that equals the control 

program risk guideline (Note: 

Control program risk guideline 

is discussed further in section 

2-15.c.). 
10/01/2012 8110.107A 

12 

Figure 4. Corrective Action Timeline 

Time Until Control Program Risk Guideline 

is Reached

Safety 

Determination 

Date

Fleet 

Corrected 

Date

Safety 

determination and 

Control program 

incorporation time 

accepted at CARB

Root causes 

determined, all 

service 

information 

developed and AD 

worksheet 

submitted

AD Published Control Program 

Risk Guideline is 

reached

Corrective action 

buffer time

e. Risk Analysis Requirements. You, the assigned ASE, must calculate the safety 

issue’s risk values as specified in table 1 for each outcome in measures defined by the product 

directorate and record them in the MSAD record. Additionally, when calculating total 

uncorrected fleet and uncorrected individual risk, the units must be convertible to the number of 

fatal accidents for comparative purposes, whether or not an uncorrected risk guideline exists. 

You must calculate the time until control program risk guideline is reached if either conditions 

(1) or (2) from paragraph 2-9c are above directorate risk guidelines. 

(1) To calculate the risk values of the issue, you must: 

 Evaluate the risk based on the directorate’s methods and guidance for the 

particular product type; 

 Document the assumptions, methods and other supporting information 

describing how the probability and severity were determined; 

 Work with the applicable product directorate to gain conditional 

probability data that the directorate may compile as risk analysis “library data” for its products 

(e.g., hazard ratios and injury ratios). 

(2) Some ACOs have negotiated agreements with certain certificate holders such 

that the certificate holder performs the risk analysis on behalf of the FAA. In those cases, you 
10/01/2012 8110.107A 

13 

may review the certificate holder risk analysis per the negotiated agreement to verify that the risk 

analysis meets the objectives of this section. 

f. Determine Necessary Action. To assist the CARB in determining the type and/or 

need for corrective action (mandatory, non-mandatory or no action), you, the assigned ASE, 

must compare the risk values calculated for the safety issue against the product directorate’s risk 

guideline(s) for ADs or other mandatory corrective action. (The directorate’s minimum 

requirement is to provide an uncorrected individual risk guideline). See figure 5, Risk Guideline 

Diagram. 

Figure 5. Risk Guideline Diagram

Optional Corrective 

Action

Negligible Benefit as 

a Result of Action

Safety Improvement 

Range

(SAIB or Other Nonmandatory Optional 

Corrective Action)

AD Range

Possible 

Risk 

Values

Risk Guideline

Airworthiness 

Directive

2/3 

Guideline

CARB 

Required

2-10. CARB. 

a. You, the assigned ASE, must present your recommended action, along with your risk 

analysis, causal analysis and quantitative evaluation of the risk reduction of corrective actions to the 

CARB for concurrence. In some cases, a safety issue may go to the CARB several times before a 

final corrective action is selected. For example, the assigned ASE can elect to bring a given safety 

issue to the CARB prior to completing all analyses to provide awareness and obtain preliminary 

feedback. The goal of the CARB is to improve safety through better decision making. This is 

achieved by: 

 

(1) Improving robustness by reducing the number of single thread safety decisions. 

(2) Providing for cross-functional review, allowing others to raise concerns and 

contribute knowledge about a safety issue and proposed corrective action plan. 
10/01/2012 8110.107A 

14 

(3) Facilitating real-time, open exchange of safety issues across the key lifecycle 

disciplines among ACO, MIDO and AEG staff. 

(4) Providing a forum for the review of the preliminary risk analysis, risk analysis, 

causal analysis and corrective action(s) for a product type, leading to acceptance, rejection or 

revision of the proposed corrective action. 

(5) Increasing knowledge and experience in the AVS community. 

Note: CARBs are designed to precede the AD process, not 

replace it. CARB actions ensure a complete data package 

is submitted to the AD process. 

b. CARB Applicability. All safety issues with a risk above two-thirds of the risk 

guidelines for AD or other mandatory corrective action must be reviewed by the CARB. All 

ADs or other mandatory corrective actions must be reviewed by the CARB regardless of risk. 

Any unilateral corrective action considered on foreign products and technical no action required 

(NAR) decisions involving mandatory continuing airworthiness information (MCAI) must 

always be reviewed by the CARB. Emergency ADs and IARs can initially bypass a CARB 

review. However, after immediate actions are taken, the safety issue must go through the rest of 

the MSAD process, including the CARB. In rare cases where a CARB would be significantly 

delayed by lack of members and alternates, and where we must issue an AD, SAIB or other 

corrective action without further delay, the applicable ACO may allow a temporary bypass of the 

CARB. The CARB must review the corrective action during the next meeting. The CARB 

meeting minutes must be documented, and include attendees, subjects discussed, and decisions 

made. 

c. ACOs Select CARB Participants. The ACO manager is responsible for selecting 

and assigning representatives to CARBs, and for designating alternates for unavailable 

representatives. The ACO manager should coordinate with MIDO and AEG management to 

facilitate MIDO and AEG representation. The CARB should consist of the following personnel: 

(1) ACO or responsible office manager. 

(2) ASE or pilot assigned and presenting the safety issue. 

(3) At least three other ASEs, one with experience in the safety issue and two others 

that support CARB technical discipline diversity. This can be satisfied using program or branch 

managers with the appropriate experience. 

(4) Representation from the AEG and MIDO/CMO. 

(5) Other optional FAA representatives (such as standards staff, chief scientist and 

technical advisor, etc.) for a range of inputs to the safety issue corrective action. 

d. CARB Attributes. The CARB should: 
10/01/2012 8110.107A 

15 

(1) Permit open discussion and not suppress dissenting technical opinions; 

(2) Convene regularly as determined by the ACO manager (or delegate) to ensure 

timely review of safety issues and enable participants to attend; 

(3) If necessary, share resources across organizations and offices; 

(4) If necessary, use Web cast conferences and teleconferences to support the 

proper mix of expertise; and 

(5) If possible, reach consensus on a safety decision. In cases where consensus 

cannot be reached, the ACO or responsible office manager has final decision authority. 

e. Factors Not Related to Risk Analysis. In rare situations, the ASE or FAA 

management may, based on factors unrelated to the risk analysis, make recommendations not 

consistent with risk guidelines for ADs or other mandatory corrective actions. The decision to 

accept or reject these recommendations is made during the CARB. When this happens, the 

assigned ASE documents final decisions in the MSAD record. Factors not related to risk 

analysis must not be used to influence the objectivity of risk analyses as the risk analysis is 

intended as objective input into the decision. 

2-11. Safety Issue Cause(s) (Step 6.0). As shown in figure 2, the MSAD process identifies 

and mitigates product risk from safety issues. The goal is to determine the product-related 

cause(s) for the safety issue. If the causes are unclear, you, the assigned ASE, must conduct a 

structured causal analysis. 

a. A “structured” causal analysis uses a tool such as Apollo Root Cause AnalysisTM and 

the companion RealityCharting® Software.” 

b. A structured causal analysis is not required for issues with obvious causes and clearly 

identifiable fleet solution(s) unless directed by the CARB, or in cases where previous corrective 

action(s) were not effective. Fleet solutions include inspections, re-designs, limitations and/or 

other product/part corrective actions. 

c. If the causes are obvious to you based on engineering expertise and judgment, you 

must still document the causes based on your non-structured approach. Documenting all of the 

causes is an important step to support future trending activity and quick identification of 

systemic problems when causes reoccur. 

d. In addition, consider doing a structured causal analysis in all cases for complex and/or 

high-profile safety issues. The structured approach supports your assumptions and conclusions 

during the process, and guides the documentation of the cause(s), effect(s) and the causal 

analysis report. 
10/01/2012 8110.107A 

16 

2-12. Perform Causal Analysis (Step 7.0). Safety issues where causes are not obvious and/or 

product/part corrective actions are not easily identifiable require a structured method to identify 

causes. The MSAD process prescribes this structured causal analysis approach. When you 

perform a structured causal analysis, you trace the chain of events, identify contributing factors 

and develop a list of candidate solutions. 

a. Focus on identifying the part or product causes that can be addressed using a “fleet” 

corrective action (AD, SAIB or other optional corrective action). 

b. You may also identify other causes that contributed to the event. These “contributing 

factors” may include design, manufacturing, operations and maintenance failures and may have 

surfaced from “people” and/or “process” issues in a manufacturer, designer or operator’s 

organization. Causes may also include FAA process shortfalls. You should submit the causes to 

the appropriate organization for their review and corrective action. You should contact the 

cognizant ASI when manufacturing, maintenance or operations issues are identified in the causal 

analysis. 

c. Some ACOs have negotiated agreements with certain certificate holders such that the 

certificate holder performs the causal analysis on behalf of the FAA. In those cases, you must 

selectively review the causal analysis per the negotiated agreement to verify that it meets the 

objectives of this section. 

2-13. Document the Cause(s) (Step 8.0). Document the causes in the MSAD record using the 

causal taxonomy. MSAD requires you to document the output of a causal analysis, including at 

least: 

a. A problem statement (may be similar to the defined safety issue); 

b. Product/part causes; 

c. People/process causes, also called “contributing factors,” if applicable; and 

d. A causal analysis report (for structured causal analysis only), which is typically a 

document produced by a causal analysis tool in a standard format. 

2-14. Identifying Causes and Contributing Factors. 

a. Causal analyses may identify contributing factors that can influence a part- or 

system-level failure. Since contributing factors are not always addressed by ADs or SAIBs, you, 

the assigned ASE, should submit these factors to the appropriate organization for analysis and 

possible action. 

b. If you, the assigned ASE, identify that outside MSAD, an operational, maintenance 

or manufacturing process is contributing to a safety issue, you should send your analysis results 

and safety issue information to the appropriate organization for review and action (e.g., AEG, 
10/01/2012 8110.107A 

17 

MIO, MIDO, etc). You should follow-up to ensure that the organization understands and has 

sufficient information to address the safety issue. 

 

2-15. Evaluate and Select Corrective Action for a Fleet Issue (Step 9.0). You, the assigned 

ASE, based on the cause(s) identified in step 7.0, must identify candidate corrective action(s) and 

select the appropriate one(s) to reduce the fleet risk presented by the safety issue. 

a. Identify Candidate Corrective Actions (CCAs). Actions can range from initial 

mitigating to extensive final and terminating. You, the assigned ASE, must evaluate each CCA 

for its appropriateness and timeliness to mitigate the safety risk. Corrective actions typically are 

developed by certificate holders. Certificate holders typically submit these to the FAA and the 

FAA has the option of accepting, rejecting or developing alternative corrective action(s). When 

a certificate holder does not submit corrective action(s) for a concern, the FAA must develop 

necessary corrective action(s) to mitigate the risk to an acceptable level. CCAs can include: 

(1) Inspections; 

(2) Part repairs or replacements; 

(3) Modification/kit installations; 

(4) Limitations; 

(5) Rework; and 

(6) Process/procedure changes. 

 b. Determine the Corrective Action Vehicle. 

(1) You, the assigned ASE, must calculate CCA control program fleet and 

individual risk as defined in table 2 using paragraph 2-9.e.(1). 

(2) If new information becomes available late in the control program development 

that shows that the risk was much greater than first calculated, or if there was a significant delay 

in issuing the control program due to some unforeseen issue, you may find that the intended 

control program will now exceed the guidelines. In that case, the control program risk may be 

evaluated using the exposure from the current point in time (instead of since when the need for 

the control program was identified in paragraph 2-9 f., as described in table 2 on the next page). 

Care should be taken to avoid getting into these situations. It should be the norm to use the 

exposure since the need for the control program was identified in paragraph 2-9 f., and resetting 

the clock should be an exception. 

(3) If you decide not to follow the recommended corrective action, you must 

document your decision and what you based it on. Attach supporting documentation to the 

MSAD record. 
10/01/2012 8110.107A 

18 

c. Initiate Corrective Action. AD, SAIB and other corrective action processes are 

outside MSAD. They are defined in appropriate orders and the quality management system (QMS) 

process. Once the AD or SAIB is issued, the assigned ASE or other administrative personnel enters 

the corrective action information (AD number, SAIB number or other applicable information) into the 

MSAD record.
10/01/2012 8110.107A 

19 

Table 2 – Control Program Risk Value Definition, Purpose, and Mathematical 

Basis 

Risk Value Definition Purpose Mathematical Basis 

Control 

program fleet 

risk 

 

Risk within 

affected fleet 

while 

corrective 

action is taken 

(plus any 

residual risk 

not remedied 

by corrective 

action). 

Helps risk managers evaluate 

candidate corrective actions 

against a maximum allowable 

risk value with respect to 

effectiveness and timeliness. 

Computed as the product of the 

average severity and average per 

flight or per flight-hour probability 

of the occurrence, multiplied by 

the control program exposure 

(predicted number of flights (or 

flight-hours) for the fleet during 

the time taken to accomplish the 

corrective actions). The start of 

the control program is normally 

considered to be when the need 

for the control program was 

identified in paragraph 2-9 f., i.e., 

the risk typically includes the 

exposure since that time—it 

includes corrective action 

preparation time and AD flow 

time, as applicable. If actual 

corrective action incorporation 

rate is unknown, estimate 

corrective action flights or flighthours by using estimated time for 

AD issuance plus half the AD 

compliance time. 

Control 

program 

individual risk 

Predicted risk 

per flight or per 

flight-hour 

during the 

control 

program. 

Needed for cases of low fleet 

exposure that result in the control 

program fleet risk, as defined 

above, to be acceptable while the 

risk to an individual aircraft or 

person during the control 

program is unacceptable. Helps 

risk managers evaluate 

candidate corrective actions 

against a maximum allowable 

risk value with respect to 

effectiveness and timeliness. 

If only a subset of the fleet is 

subject to the risk, include only 

that portion in the analysis. 

Evaluate significant variations 

between identifiable subsets of 

the fleet (different models, 

different usages, etc.) as 

separate populations for the 

individual risk. 

Typically based on averages that 

apply to the fleet during the 

control program. However, there 

may be circumstances where you 

can calculate individual risk 

including risk values for special 

conditions and combinations of 

conditions, or for subsets of the 

fleet, for example by model or 

usage. 
10/01/2012 8110.107A 

20 

Figure 6. Evaluate and Select Corrective Action(s) Flow Diagram (expanded 

illustration of step 9.0 in figure 2) 

c. Evaluate AD CCAs using the Control Program Fleet Risk and Control 

Program Individual Risk Guidelines (CPRGs). This applies to AD CCAs only. Skip this task 

if you are proposing non-mandatory corrective action. You, the assigned ASE, should ensure 

that the CCA (or combination of corrective actions) calculated control program risk is at or 

below both the fleet and individual CPRG. 

(1) During this analysis, consider combined actions of a “bundle” of CCAs as a 

whole, for example interim action such as a repetitive inspection followed by a final action, such 

as a part replacement. Evaluate the corrective action plan for the total effect on the risk. 

(2) If the risk of a CCA exceeds either fleet or individual CPRG, consider 

eliminating or revising the candidate by either accelerating the implementation (e.g., replacing at 

‘B’ check rather than at ‘C’ check, or “inspect at 100-hr vs. 200-hr intervals”) and/or 

adding/modifying corrective actions. Use the directorate-established CPRG analysis method to 
10/01/2012 8110.107A 

21 

determine the action’s acceptability and timing by comparing it to the control program fleet and 

control program individual risk guidelines. 

Note: When considering compliance times for mandatory 

corrective action, do not unnecessarily extend the 

compliance time even if doing so would keep the control 

program fleet or control program individual risk below the 

CPRG. Work within existing maintenance schedules. 

 

d. CCA Evaluation. You, the assigned ASE, must evaluate each candidate corrective 

action. Ideal candidates are inexpensive, easy to perform, implemented quickly, 100 percent 

effective at reducing risk and do not introduce substitute risk (risk of unintended consequences). 

Most situations do not meet these ideals. Therefore, you must conduct a short evaluation of 

candidate action(s) using effectiveness, cost, timeliness of implementation and complexity. 

e. Select Preferred Corrective Action. Once you, the assigned ASE, have evaluated 

all candidate corrective actions against the attributes in paragraph 2-14.d., select the most 

appropriate one(s), balancing the attributes. You must document and submit your 

recommendation with all supporting documentation for review by the CARB. 

f. Interim Corrective Action. When issuing interim corrective action, you must add a 

date and associated comment field to the MSAD record. This date will act as a reminder that the 

final action still needs to be issued in time to meet the control program risk guideline. 

g. Terminating Corrective Action. When the terminating action is defined, you must 

calculate the control program fleet and control program individual risk to ensure it meets the 

fleet and individual CPRGs. Proceed through the corrective action selection process as defined 

in paragraph 2-14.e. The CARB must review terminating actions not previously discussed in the 

initial CARB. 

Note: For some safety issues the time needed to implement 

the initially proposed control program may exceed the 

control program incorporation time. This could occur due 

to the proposed control program requiring unusually 

extensive engineering and/or testing, unusually long time to 

produce parts, or unusual shop capacity constraints in 

installing the proposed corrective action. To effectively 

manage risk in those cases, an interim action should be 

taken prior to the initially proposed corrective action (final 

action). The control program risk of the combination of the 

interim action and the final action should be within the 

control program risk guideline. 

 

2-16. Submit to Process Owner for Further Analysis (Step 10.0). As described in figure 2, 

assigned ASEs discovering causes identified in other AIR business processes (like certification 

and rulemaking) should communicate those causes to process owners for action. 
10/01/2012 8110.107A 

22 

2-17. Submit Cause to Certificate Oversight Process (Step 11.0). Assigned ASEs who 

identify causes in the certificate oversight process, like design and production escapes, should 

communicate them to the certificate oversight representative for action. 

2-18. Document and Submit Issue to External Organization (Step 12.0). AFS, air traffic 

and other non-AIR FAA staffs may receive causal information from the MSAD process that 

identifies a specific condition in their business process or the certificate holders they oversee. 

The condition may warrant corrective action, as determined by their business process. 

Note: When assigned ASEs submit information to flight 

standards ASIs in the field (i.e., FSDO/CMO), the assigned 

ASEs should either submit the information through the 

cognizant AEG or, at a minimum, notify the AEG that 

information has been submitted directly to the field. 

2-19. Initiate AD, SAIB or other Corrective Action Process (Step 13.0). 

a. The CARB should use the risk analysis outputs to guide its decision whether or not 

to choose an AD, SAIB or other corrective action. If the CARB selects any of these options, the 

assigned ASE starts the corrective action process. 

b. Developing and issuing corrective actions may require exchange of information and 

further MSAD process analysis. You must use the MSAD process to track changes to the 

technical decision-making. 

2-20. Prepare Internal Feedback to MSAD Process Owner (Optional) (Step 14.0). MSAD 

is part of the AIR QMS process. AVS MSAD users can submit feedback to the MSAD QMS 

procedure and associated work instructions by submitting a corrective action request (CAR), 

preventive action request (PAR) or nonconformance record (NCR) through AVS QMS 

Information Technology Support (QMITS) system. 

2-21. Prepare Lessons Learned (Step 15.0). Either a senior COS ASE or assigned ASE 

should consider all safety issues to determine if the events, safety issues, risk analyses or 

corrective action selections are valuable teaching cases. If so, use the “Lessons Learned 

Nominations” function in the MSAD tool to capture the lessons. 
10/01/2012 8110.107A 

23 

Chapter 3. Follow On and Trending 

3-1. Monitor and Validate. The cognizant ASE must monitor and validate the effects of 

corrective action in the fleet by monitoring in-service data to ensure that the risk has been 

properly mitigated (see link B, figure 2). You can do this by identifying repeat and similar 

events using the MSAD record database. You must also watch for introduction of substitute risk 

due to unintended consequences of mitigating action. 

3-2. Trending. 

a. Data trending is defined as collecting and monitoring existing data to identify items 

that meet specific criteria or exceed established guidelines. Trending data is important because 

it: 

(1) Enables tracking known safety issues to ensure that their rate of occurrence does 

not cause risk to exceed established guidelines, and is consistent with the intent of the 

certification assumptions and analyses. 

(2) Allows the monitoring of the results of implemented corrective actions. We do 

this to verify that the implementation and results are as presumed, and that new problems were 

not introduced by the actions. 

(3) Identifies emerging safety issues, which are challenging to implement. Items 

may appear to be an issue, but very few would likely result in an accident if uncorrected. 

Therefore, you have to carefully decide on which data to trend and act. 

b. Conducting Trending. Trend analysis can be conducted by all AIR personnel 

responsible for monitoring and addressing product safety risks, as needed. Although MSAD 

trending is primarily based on fleet level events, it does not prevent us from trending at the 

certificate management level, looking for trends in people/process causes. MSAD event records 

can initiate trending, or management can assign it periodically. If the assigned ASE identifies a 

potential safety issue (see link C, figure 2), the ASE must perform a risk analysis per paragraph 

2-9. If an ASI identifies a potential safety issue, the ASI must submit that information to the 

cognizant ASE, who will assess the fleet risk and take appropriate corrective action, as 

necessary. 

c. Identifying Trends. Trending activities can include: 

(1) Identifying items to trend (parts, products, failures, etc.); 

(2) Analyzing cross-product trends; 

(3) Tracking trends and items of significant interest; 

(4) Tracking repeat events – similar failures that have occurred on multiple 

occasions, including: 
10/01/2012 8110.107A 

24 

 Repeat part failures (within makes, models and series or across them); 

 High part replacement rates (within makes, models and series or across 

them); and 

 Repeat safety issues (within makes, models and series or across them). 

(5) Identifying causes (during MSAD process); 

(6) Identifying most common part category or system failures; and 

(7) Identifying patterns or potential correlations (for example, when part A fails and 

part B fails, then event C occurs). 

Note: Not all events necessitate a trend analysis. You 

should focus on anticipated concerns. 

d. Figure 7 illustrates the trending process. 
10/01/2012 8110.107A 

25 

Figure 7. Data Trending Process Flow Diagram 
10/01/2012 8110.107A 

26 

Chapter 4. Applying MSAD to Foreign Products 

4-1. Introduction. This chapter describes how MSAD applies to safety issues on products designed 

and manufactured outside the United States. It covers how to handle events on these products, as well 

as how to review and disposition MCAI. 

4-2. Addressing MCAI. MCAI are documents issued by other State of Design Authorities (SoDA), 

following ICAO Annex 8, regarding unsafe conditions on products designed or manufactured in other 

countries. FAA Order 8040.5, Airworthiness Directive Process for Mandatory Continuing 

Airworthiness Information, offers general guidance on MCAI. 

a. If you are responsible for addressing the MCAI, follow the process in Order 8040.5 for all 

MCAI received. If you determine that unilateral action, as defined by Order 8040.5, may be 

necessary, enter the information into the MSAD database, creating an initial MSAD record. You then 

apply the MSAD process steps, beginning with risk analysis per paragraph 2-9. When requesting 

more technical information from the SoDA, specifically request information needed to perform the 

MSAD risk analysis step. This also applies when you believe that an MCAI does not represent a 

safety issue and a corresponding AD need not be issued. This does not apply when no AD required 

(non-technical NAR) decisions are made for administrative reasons. Typical administrative reasons 

may include instances when the SoDA has issued a revised or superseding MCAI and the FAA 

decides no AD is required for the initial or preceding MCAI, and instead writes an AD for the later 

MCAI. 

b. For an illustrated version of how to apply MSAD to MCAIs, see figure 8. 
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27 

Figure 8. MSAD Process for MCAI 

4-3. Addressing Events. Some events on foreign products will pass through the MSAD hazard 

criteria filter for a product type, and will need to be reviewed by the responsible FAA office. If you 

are responsible for a foreign product, review and disposition all events associated with that product 

using the MSAD process for foreign product data described in this section. Coordinate with the 

SoDA as needed, ensuring they are aware of any safety issues in order to address them. 

a. Hazard Criteria Analysis. Foreign product data will be automatically filtered per 

paragraph 2-6. 

b. Perform Preliminary Risk Assessment. If you have identified a safety issue requiring 

emergency corrective action or a potential safety issue, coordinate the MSAD event record 

information, along with the results of the preliminary risk assessment, with the SoDA to determine 

whether they intend to address the safety issue with an MCAI, are in the process of preparing an 

MCAI, or have already issued an MCAI. If an FAA AD exists that adequately addresses the safety 

issue, link the MSAD record item for the event to the FAA AD and reference it for future 

management of the issue. If you determine that no further action is necessary, close the MSAD 

record. No further action is required in the MSAD process, but the record is retained for trending. 

Prior to closing the MSAD event, you should ensure that MSAD events discovered to be false 

positives are marked. For cases when immediate action is warranted, after you notify the SoDA, you 
10/01/2012 8110.107A 

28 

should initiate FAA corrective action without waiting for the SoDA to take action or for the eventual 

MCAI. 

 

c. If the SoDA notifies us that they are taking no action or you determine that the SoDA 

action is not adequate, you will need to continue through the MSAD process from “Perform Risk 

Analysis,” per paragraph 2-9, to determine what further action, if any, is necessary. You may need to 

take unilateral action following the process described in Order 8040.5. 

d. Figure 9 is a depiction of the MSAD process flowchart including other SoDAs.

Figure 9. MSAD Process for Foreign Product Data

Proceed to perform risk analysis 

(figure 2, page 1, step 5.0)

START

Automation/ 

manual entry

Acquire data

Hazard 

Criteria

ASE

Inform SoDA

(that corrective action 

may be warranted)

Is SoDA 

action 

adequate?

Yes

Yes

No

Automation

Conduct hazard 

criteria analysis

Senior COS ASE

Perform preliminary 

risk assessment

Potential 

safety issue?

Does 

an FAA AD 

address this 

issue?

No

END

END END

No Yes
10/01/2012 8110.107A 

Chapter 5. Roles and Responsibilities 

5-1. Process Owner Responsibilities. AIR-150 will organize inter-directorate meetings at 

least annually to review and discuss MSAD information and lessons learned. The agenda may 

include MSAD process support--make/model lists, hazard criteria, risk analyses methods and 

risk guidelines--which the directorates are responsible to develop and maintain. The agenda may 

also include any cross-product issues identified as part of the MSAD process. These meetings 

can be combined with other meetings, and must be documented in meeting minutes. 

5-2. AIR-110 Responsibilities. The Engineering Procedures Office (AIR-110) develops and 

standardizes regulations, national directives, policy, procedures, and advisory material for COS. 

AIR-110 will work with AIR-150 to ensure MSAD supports the COS activities in AIR. 

5-3. AIR-120 and AIR-130 Responsibilities. The Technical Programs and Continued 

Airworthiness Branch (AIR-120) and the Avionic Systems Branch (AIR-130) will have access to 

the MSAD data to determine if the TSO process or specific TSOs need changes to address 

emerging safety issues in the aviation fleet. Both branches will also participate in the interdirectorate meetings described in paragraph 5-1. 

5-4. Directorate Responsibilities. Each directorate is responsible for developing and maintaining 

the supporting MSAD processes for their product type. 

 

a. Develop Hazard Criteria. Directorates will develop a list of hazard criteria by 

product type and perform sampling per paragraph 2-6.b. 

b. Develop Risk Measures and Risk Guidelines. Directorates will develop risk measures, 

risk guidelines and specify risk analysis methods. 

c. Establish Conditional Probabilities. Directorates will establish for their product type 

(with assistance from ACOs) conditional probabilities of aircraft-level outcomes given a base event 

occurrence. 

d. MSAD Process Maintenance. 

(1) Directorates must support the inter-directorate meetings described in paragraph 

5-1. 

(2) Directorate COS representatives must review hazard criteria samples (at least 

annually) and update hazard criteria as needed for their product type concerns. The results of 

this review should be recorded. 

(3) Each directorate, coordinating with industry, may adapt their risk analysis 

methods and risk guidelines, as needed. 

(4) Directorates must determine how often their conditional probability data is 

reviewed and revised. 
10/01/2012 8110.107A 

30 

5-5. Responsibilities of offices responsible for COS oversight. These offices must: 

a. Perform or oversee, per ACO/certificate holder agreement, the MSAD process 

consistent with the product type. 

b. Develop and maintain fleet size and age estimates (cycles or hours) for each model, 

or review and accept estimates supplied by the cognizant certificate holder. 

c. Develop and maintain model utilization rates, or review and accept estimates 

supplied by the cognizant certificate holder. 

d. Develop or review other basic data needed for risk analysis. 

e. Support the directorates as necessary in accomplishing their responsibilities. 
10/01/2012 8110.107A 

31 

Chapter 6. Background 

6-1. AIR SMS. The AIR SMS vision states, “AIR manages safety through a comprehensive 

systems safety approach, maximizing our value to aviation safety through influence and response 

to the changing aviation environment.” 

a. AIR SMS supports and aligns with AVS SMS requirements in VS 8000.367, 

Aviation Safety (AVS) Safety Management System Requirements, by establishing the MSAD 

process, which provides a safety risk management and safety assurance approach to AIR's COS 

mission. To achieve the AVS SMS vision and supporting goals, AIR decision-making processes 

need to evolve into an approach that is both quantitative and risk-based. 

b. A mature AIR SMS will give AIR a holistic approach using risk-based processes to 

support an enhanced focus on safety. SMS represents the first time AVS and AIR have 

attempted to manage risk throughout the product life cycle. Before this, much of FAA risk 

analysis had been an isolated qualitative activity, lacking standard methods for analyzing and 

managing risk over time. 

c. FAA Order 8040.4, Safety Risk Management Policy, establishes our safety risk 

management policy and requires all FAA lines of business to establish and implement a formal 

risk management program consistent with their role in the FAA. The order states: “The FAA 

shall use a formal, disciplined, and documented decision-making process to address safety risks 

in relation to high-consequence decisions affecting the complete life cycle.” 

d. AIR SMS addresses the requirements in Order 8040.4. After setting up an FAA 

SMS that uses risk-based decision making tools and processes, we expect that industry will 

develop or coordinate a corresponding SMS compatible with our model and tailored to each 

company’s needs. 

6-2. Industry Interface and Applicability. MSAD effectiveness relies heavily on in-service 

data from operators, manufacturers and other certificate holders. This data sharing approach is 

risk-based, reflecting the SMS principle of being proactive by using data-driven analysis. 

a. Accordingly, we have to develop MSAD interfaces with industry to foster data 

sharing. We expect that AIR offices, including headquarters, directorates and ACOs, will 

promote good working relationships with their respective industry stakeholders. 

b. In addition, since certificate holders are routinely responsible for developing 

corrective actions for product or part hazards in the fleet, we should harmonize industry and 

FAA processes as much as we can. Harmonized processes promote common understanding of 

the fundamentals of COS: data analysis, hazard identification, risk analysis methods, risk 

guidelines, causal analysis and appropriate corrective actions. MSAD is defined so that MSAD 

process steps, except the decision and issuance of an AD or SAIB, could be performed for us by 

industry when potential future SMS regulations that are applicable to certificate holders are in 

place. Some ACOs are working towards, or have in place, negotiated agreements with their 

certificate holders in which the certificate holder goes beyond statutory requirements and 

performs data analysis, hazard identification, risk analysis, causal analysis and corrective action 
10/01/2012 8110.107A 

32 

development in accordance with the product directorate’s MSAD objectives. In these cases, the 

FAA plays a critical oversight safety assurance role, as opposed to a safety risk management 

role.

6-3. Benefits of the MSAD Process. MSAD and its supporting tools and methods allow the 

current AIR COS process to evolve into a more risk-based, systemic, decision-making system. 

MSAD: 

a. Identifies safety issues and related causes that determine product-related corrective 

actions. 

b. Submits underlying process and people safety issues to certificate management, 

rulemaking and other business processes to enable a more complete aircraft life-cycle COS 

environment. 

c. Enables consistent standardized measurable risk-based decision making for COS 

across AIR. 

d. Quickly identifies safety trends using analysis of dependent variables (MSAD 

database). 

e. Builds a COS model that exemplifies what the FAA would like to see from industry 

in the future. 

6-4. MSAD Tool Support. 

a. This order defined MSAD minimum process requirements, not tool requirements. 

The MSAD database, however, is a tool used to store event data according to MSAD-required 

taxonomy. An assigned ASE conducts the MSAD process using the database and other support 

tools to: 

(1) Access, collect and store safety information; 

(2) Guide users through the process; 

(3) Track completion of the process steps; and 

(4) Support risk, causal and corrective action analyses. 

b. The database is intended to store all information input by the user, including 

calculations, analyses performed and technical decisions made for the MSAD record.
10/01/2012 8110.107A 

33 

Chapter 7. Exceptions 

7-1. Exceptions to Some Requirements of this Order. This chapter defines some specific 

situations where exceptions to some of the requirements of this order are authorized, and the 

extent of those exceptions. 

a. When certain higher-level policies require that an AD be written, do not use MSAD risk 

analysis results in making the decision to write the AD. The policy decision to write ADs in those 

cases was made during the course of rulemaking or other policy deliberations, and overrides the 

MSAD risk guidelines. The following are the limited authorized cases of an overriding higherlevel policy: 

(1) ADs for mandatory modifications required by the widespread-fatigue-damage 

rule (75 FR 69746, November 15, 2010, or later revision). 

(2) ADs to mandate the incorporation in the airworthiness limitations section of the 

maintenance manual new or revised damage tolerance inspections or safe-life limits required for 

§ 23.571, 25.571, 27.571, 29.571, 33.14, and 33.70 compliance. 

(3) ADs that are needed for Special Federal Aviation Regulation (SFAR) 88 

compliance. 

(4) ADs required by the aging aircraft program (69 FR 45936, July 30, 2004 and 

70 FR 5518, February 2, 2005, or later revisions) for changes to supplemental structural 

inspection programs and corrosion prevention and control programs (CPCP). 

b. ADs are issued to correct an unsafe condition in an aircraft, engine, propeller or 

appliance (products), and have a defined applicability at the time of issuance. On occasion, after 

AD issuance, the FAA may discover that the applicability did not include all the affected 

products, and the AD is superseded to increase the applicability. When the FAA supersedes an 

AD solely for this reason, do not use MSAD risk analysis results in making the decision to issue 

a supersedure, as the supersedure will be issued regardless of the risk result to meet ICAO 

obligations or as general policy. 

c. For the situations defined in paragraphs 7-1 a. and 7-1 b., the following exceptions to the 

requirements of the following paragraphs are authorized: 

(1) Paragraph 2-9, Record Risk Analysis Results (Step 5.0). 

(2) Paragraph 2-11, Perform Causal Analysis (Step 7.0). 

(3) Paragraph 2-12, Document the Causes (Step 8.0). 

(4) Paragraph 2-13, Identify Cause and Contributing Factors. 
10/01/2012 8110.107A 

34 

(5) Paragraph 2-14, Evaluate and Select Corrective Action for a Fleet Issue (Step 

9.0). 

(6) Some of the requirements defined in paragraph 2-15 a., CARB. See paragraph 7-1 

d. for requirements that remain in effect. 

d. When exceptions are made in accordance with this chapter, the following limitations and 

requirements remain in effect: 

(1) The issue and recommended corrective action must be presented to the CARB 

for concurrence per paragraph 2-15 a. 

(2) The CARB decision of the issue must be documented in the CARB meeting 

minutes per paragraph 2-15 b. 

(3) The exception of paragraph 7-1 b. may not be exercised if the unsafe condition 

of the superseding AD in any way differs from the superseded AD unsafe condition (the 

supersedure must be solely to add applicability). 
10/01/2012 8110.107A 

Appendix A 

Appendix A. Definitions and Acronyms (Continued) 

A-1

Appendix A. Definitions and Acronyms 

14 CFR Title 14 of the Code of Federal Regulations 

ACO Aircraft certification office. The aircraft certification directorate’s 

engineering operational element. This office administers and secures 

compliance with agency regulations, programs, standards, and procedures 

governing the type design of aircraft, aircraft engines, or propellers. It 

offers certification expertise on investigating and reporting aircraft 

accidents, incidents, and service difficulties. The term “ACO” refers to the 

Engine Certification Office (ECO), the Rotorcraft Certification Office 

(RCO), the Special Certification Office (SCO), Military Certificate Office 

(MCO) and all other ACOs. 

AD Airworthiness directive 

AEG Aircraft evaluation group 

AFS Flight Standards Service 

AIR Aircraft Certification Service 

ASE Aviation safety engineer 

ASI Aviation safety inspector 

Assigned ASE Directorate or ACO ASE with COS responsibilities for a specific aircraft or 

product safety issue 

AVS Aviation Safety Organization 

CAR Corrective action request 

CARB Corrective Action Review Board 

CAST Commercial Aviation Safety Team 

Causes Underlying circumstances, occurrences, and/or failures that contribute, or 

could contribute, directly or indirectly, to an event. 

CCA Candidate corrective action 

CICTT CAST/ICAO Common Taxonomy Team 

CMO Certificate management office 

Condition See “Safety Issue” 
10/01/2012 8110.107A 

Appendix A 

Appendix A. Definitions and Acronyms (Continued) 

A-2

CPRG Control program risk guideline. The upper limit of acceptable risk which 

assists the ASE in determining the adequacy, in terms of risk reduction, of a 

proposed candidate corrective action. These guidelines are characterized in 

terms of both fleet risk and individual risk. 

Corrected risk Residual risk that remains after corrective action is taken. When highly 

effective corrective action is taken, residual risk is considered to be zero. 

See also “Uncorrected Risk.” 

Corrective action Any action to mitigate a safety issue. Includes mandatory actions like ADs 

and rule changes, to correct an unsafe condition. Includes non-mandatory 

actions and recommendations like SAIBs and Aviation Alerts. Includes 

actions that either directly corrects the safety problem and/or mitigates risk 

with operational limitations or restrictions, like grounding a product from 

further flight. 

COS Continued operational safety 

CPCP Corrosion prevention and control program 

Cross-product Can be across product lines within a manufacturer, across products from 

various manufacturers, and/or across product-types, if parts, components or 

processes are common to other aircraft or engines. 

DAB Daily alert bulletin 

Event Any individual occurrence involving an aircraft or its components. 

Described in terms of what is observed (the symptoms) or recorded during 

the occurrence. Events typically trigger investigations that seek causes of a 

safety issue. The safety issue (or condition) is then evaluated for safety 

implications. 

FAA Federal Aviation Administration 

Fleet Aircraft, engine or propeller products of a type currently in service affected 

by a certain safety issue. 

FSDO Flight standards district office 

Hazard Any existing or potential condition that can lead to injury, illness or death to 

people; damage to or loss of a system, equipment or property or damage to 

the environment. A hazard is a condition that is a prerequisite to an 

accident or incident. 

IAR Immediately adopted rule 
10/01/2012 8110.107A 

Appendix A 

Appendix A. Definitions and Acronyms (Continued) 

A-3

ICAO International Civil Aviation Organization 

MCAI Mandatory continuing airworthiness information 

MIDO Manufacturing inspection district office 

MIO Manufacturing inspection office 

MSAD Monitor Safety/Analyze Data 

NAR No action required 

NCR Nonconformance record 

NPRM Notice of proposed rulemaking 

Outcome Result of an event, condition, or failure at aircraft level. 

PAR Preventive action request 

Preliminary risk 

assessment 

An initial assessment of the risk posed by a safety issue, often performed 

with limited data or qualitative information. This assessment is meant to 

quickly determine an issue’s potential risk and urgency, and is followed by 

comprehensive and quantitative analysis as data and circumstances permit, 

unless the issue is deemed to entail very little risk. 

Probability Ratio of the number of actual occurrences to the number of possible 

occurrences. For example, 1 in 1 million flight hours. Probability is often 

expressed with the denominator normalized to a single unit; therefore, 

1x10-6 per flight hour. Probability can also be evaluated against total 

exposure of the fleet (or other relevant parameter); as in "40% probability 

that a failure will occur”, or “an expected number of events, if the hazard is 

not addressed”. 

QMITS Quality Management Information Technology Support 

QMS Quality management system 

RCA Root cause analysis 

RGL Regulatory Guidance Library 

Risk analysis Process whereby hazards are objectively characterized for their severity and 

probability. The process can be either qualitative or quantitative. 

Risk guideline The upper limit of acceptable risk which assists the ASE in determining the 
10/01/2012 8110.107A 

Appendix A 

Appendix A. Definitions and Acronyms (Continued) 

A-4

need for AD or other mandatory corrective actions and the adequacy, in 

terms of risk exposure, of a proposed candidate corrective action. 

Risk Expression of the severity and probability of an undesired event. See also 

"corrected risk” and “uncorrected risk." 

Safety issue Cause(s), contributing factor(s), or finding(s) that led to, or could lead to, an 

unsafe outcome. Safety decisions are rendered on issues/causes, not events. 

For example, investigation of an uncommanded flight control surface 

movement--an event--might reveal that the cause was a circuit failure in the 

autopilot’s computer. Circuit failure is the safety issue/cause to evaluate for 

safety implications, and to take corrective action against. 

SAIB Special airworthiness information bulletin 

Senior COS ASE The assigned ASE who performs the preliminary risk assessment which has 

experience in COS duties. This person is not equivalent to senior engineers 

that exist in the ACOs. However, senior engineers may be qualified as 

senior COS ASEs. 

Service bulletin 

(SB) 

One type of "service document" (see below). In this order, the terms are 

synonymous. 

Service 

documents 

Publications by a type certificate holder, appliance or component 

manufacturer that offer information on safety, product improvement, 

economics and operational and/or maintenance practices. Publications 

include service bulletins, all-operators' letters, service newsletters and 

service digests or magazines. Not included are flight manuals and certain 

maintenance manuals required for FAA type certification or approval. 

(Source: AC 20-114, Manufacturers Service Documents) 

Severity The consequence or impact of a hazard in terms of degree or loss or harm. 

SMS Safety management system 

SoDA State of design authority 

STC Supplemental type certificate 

Substitute Risk Risk of unintended consequences from implementing corrective action 

Taxonomy For the purposes of MSAD, a standard industry language and set of 

definitions that improve the quality of information and communication 

within the aviation community. 

TC Type certificate 
10/01/2012 8110.107A 

Appendix A 

Appendix A. Definitions and Acronyms (Continued) 

A-5

TSO Technical standard order 

Uncorrected risk Risk that accumulates over time in the affected fleet if no corrective action 

is taken for a certain safety issue. See also "corrected risk." 
10/01/2012 8110.107A 

Appendix B 

B-1 

Appendix B. Administrative Information 

1. Distribution. Distribute this order to the Washington headquarters division and branch levels of 

the Aircraft Certification Service and Flight Standards Service, to the headquarters division and 

regional divisions of the Flight Standards Service, to aircraft evaluation groups, to all Aircraft 

Certification Service Directorates and certification offices and branches. Distribute to manufacturing 

inspection offices (MIO), manufacturing inspection district offices (MIDO), manufacturing inspection 

satellite offices (MISO), all flight standards district offices (FSDO), aircraft certification and 

airworthiness branches of the FAA Academy, and the International Policy Office, AIR-40. 

2. Authority to Change This Order. The issuance, revision, or cancellation of the material in this 

order is the responsibility of the AIR Safety Management Design and Analysis Branch (AIR–150). 

This branch will accomplish all changes, as required, to carry out the FAA’s responsibility to provide 

guidance for the Monitor Safety/Analyze Data (MSAD) process. 

3. Suggestions for Improvement. If you find deficiencies, need clarification or want to suggest 

improvements to this order, send FAA Form 1320-19, Directive Feedback Information, (written or 

electronically) to the Aircraft Certification Service, Administrative Services Branch, AIR-510, 

Attention: Directives Management Officer. You can also send a copy to the Aircraft Engineering 

Division, AIR-100, Attention: Comments to Order 8110.107A. If you urgently need an 

interpretation, contact Safety Management Design and Analysis Branch, AIR–150, at 202-267-8588. 

Always use Form 1320-19, in appendix C, to follow up each verbal conversation. 

4. Records Management. Refer to Orders 0000.1, FAA Standard Subject Classification System; 

1350.14, Records Management; and 1350.15, Records, Organization, Transfer, and Destruction 

Standards; or your office Records Management Officer or Directives Management Officer for 

guidance regarding retention or disposition of records.

5. Related Federal Regulations and Publications. 

 14 CFR Part 39. 

 FAA-IR-M 8040.1, Airworthiness Directives Manual. 

 FAA Order 8040.1, Airworthiness Directives. 

 FAA Order 8040.4, Safety Risk Management.

 FAA Order 8040.5, Airworthiness Directive Process for Mandatory Continuing 

Airworthiness Information. 

 FAA Order 8110.100, Special Airworthiness Information Bulletin.
10/01/2012 8110.107A 

Appendix C 

C-1 

U.S. Department 

of Transportation 

Federal Aviation 

Administration

Appendix C. Directive Feedback Information 

Please submit any written comments or recommendations for improving this directive, or suggest 

new items or subjects to be added to it. Also if you find an error, please tell us about it. 

Subject: Order 8110.107A 

To: Directive Management Office, AIR-510 

(Please check all appropriate line items) 

 An error (procedural or typographical) has been noted in paragraph ______ on page_____ 

 Recommend paragraph _____ on page _____ be changed as follows: 

 (attach separate sheet if necessary) 

 In a future change to this directive, please include coverage on the following subject: 

 (briefly describe what you want added): 

 Other comments: 

 I would like to discuss the above. Please contact me. 

Submitted by: ____________________________ Date: __________________ 

Telephone Number: __________________________ Routing symbol: _________ 

FAA Form 1320-19 (10-98)