Principles and Characteristics of a Confidential, Non-Punitive, Close Call Safety Reporting System Elements of Existing Systems Existing models of close call safety reporting systems used by the Aviation Safety Action Program (ASAP), FAA/NASA Aviation Safety Reporting System (ASRS), the FRA/BTS pilot system (C3RS/BTS), and the FRA/NASA pilot system (C3RS/NASA). : Elements of Existing Close Call Safety Reporting Systems Element Description ASAP ASRS C3RS/NASA C3RS/BTS Voluntary Reporting Rely on employees to voluntarily report safety incidents and concerns. Reports submitted to an Event Review Committee (ERC) composed of representatives from FAA, management, and labor. Reports submitted to an independent third-party agency. Reports submitted to an independent, agency. Reports submitted to an independent, agency. Confidential Reporting Take care in ensuring that identities of reporting individuals cannot be disclosed; some protect the identity of the carrier. Personally identifiable information (PII) is not destroyed; reports are not protected from legal disclosure. PII is removed once the report has been processed, coded, and stored in a database. PII is removed once the report has been processed, coded, and stored in a database. PII is not destroyed, but carefully protected under the Confidential Information Protection and Statistical Efficiency Act (CIPSEA), Title V of the E-Government Act of 2002. party
Non-Punitive Close call safety reporting systems provide protection from disciplinary action for employees that submit a qualifying report, which encourages individuals to voluntarily report safety close calls. In some cases, the carrier is protected from regulatory discipline as well. Employees who submit qualifying reports receive a corrective action letter in lieu of civil penalty action. Employees who submit qualifying reports are protected from disciplinary action. Employees who submit qualifying reports are protected from disciplinary action. The carrier is protected from FRA enforcement action as well. Employees who submit qualifying reports are protected from disciplinary action. The carrier is protected from FRA enforcement action as well. Third-Party Data Collection and To ensure confidentiality, most but not all, call safety reporting systems employ a third-party agency to receive, process, and, in some cases, investigate the reports. An independent third-party agency is not employed. Reports are analyzed by the ERC. Currently 166 of these programs send duplicate data to the NASA ASRS system. NASA is the agency for ASRS. NASA receives and processes the reports and follows up with phone calls when necessary to clarify details. Reports are coded and entered into the system for later analysis. NASA is the agency. NASA receives the reports directly and conducts a thorough analysis that includes an in depth callback using industry experts. NASA compiles event reports that are forwarded to the corresponding PRT after de-identification. NASA retains aggregated de-identified coded data. BTS is the third-party agency. BTS receives the reports directly and conducts in-depth follow-up interviews with employees who submit reports using industry experts. BTS compiles composite reports on close call events that are forwarded to a Peer Review Team (PRT) at the FRA pilot site for further analysis. BTS retains all information, including PII. identification party
Analysis and Feedback Analyses performed by close call safety reporting systems vary and therefore the systems provide different feedback. ERCs analyze individual reports, identify actual or potential problems, and propose solutions for those problems. NASA performs analysis to identify deficiencies and discrepancies in aviation systems that are reported to the stakeholders of the aviation industry All PII or carrier is removed. Aggregated, reports are available to all stakeholders and the general public on the ASRS website. Analysis initially performed by NASA through data coding protocols. Data are sent to PRTs housed at the individual railroads where they are further analyzed. PRTs consist of representatives from management, labor, and the FRA, including employees. PRTs perform root-cause analysis of each reported incident and make recommendations to management for corrective action. PRTs can also conduct analysis of reports to identify patterns and trends. FRA’s system uses PRTs housed at railroads to analyze reports. PRTs consist of representatives from management, and the FRA, including front-line employees. PRTs perform root-cause analysis of each reported incident and make recommendations to management for corrective action. PRTs can also conduct carrier-level analysis of reports to identify patterns and trends. In addition, C3RS analyzes and reports on agency and industry trends. level
Stakeholder Involvement and All four systems have actively engaged all industry stakeholders in the process. The confidential nature of the reporting systems equal priority to reports made by any individual, regardless of position within an organization. All employees covered under the implementing MOU can report safety concerns. All reports are given equal weight. The ERC structure involves multiple stakeholders in the analysis of reports. Anyone involved with safety-critical operations can report safety concerns. All reports are given equal weight. Results are reported industry-wide through alert bulletins, newsletters, teleconferences, and participation in industry and government forums. Any employee covered under the implementing MOU can report safety concerns without fear of retaliation or discipline. All reports are given equal weight. PRT structure involves all stakeholders in the analysis of reports, empowering those involved to put their unique perspectives and experience to work improving safety conditions. Trends are not reported beyond the individual railroad in most cases. Any employee covered the implementing MOU can report safety concerns without fear of retaliation or discipline. All reports are given equal weight. PRT structure involves all stakeholders in the analysis of reports, empowering those involved to put their unique perspectives and experience to work improving safety conditions. Trends are not reported beyond the individual railroad in most cases.