A Twist on Advisory Circular 00-58

Who is covered by the voluntary disclosure program?

On the other hand, keep in mind that your 00-46 safety program filing is private and anonymous. If a complaint for certificate action is laid on you there will always be a record of the violation in your personal file at the FAA, even though you may be immune from sanction because of your valid NASA filing. There is some dispute in this area and many would maintain that any complaint filed after a safety report filing would simply be invalidated (no record) from its beginning. Although there seems to be a lack of cases on the point there is abundant dicta (court discussion) that suggests invalidation. There seems to be abundant authority to invalidate the attempt at enforcement. Forward your comments to aerolaw@att.net.

Stephen P. Prentice is an attorney whose practice involves FAA-NTSB issues. He has an Airframe and Powerplant certificate, is an ATP rated pilot, and is a USAF veteran. E-mail: aerolaw@att.net

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