CASS ... Too Little ... Too Late

Continuous Analysis and Surveillance FAR 121.373a: No surveillance ... no analysis

Changes need to be made

In order to be effective FAR 121.343 needs to be expanded. The NTSB in Chalks mentioned that the CASS is a “one-size-fits-all” rule. The Board specifically said that the FAA should move away from the one-size-fits-all language of FAR 121.343 and focus on a program that will more aggressively uncover and address any structural and or other continuing airworthiness issues.

A vigorous maintenance discrepancy tracking process must be included in the overall quality control system. The Board also cited insufficient FAA oversight. Principal maintenance inspectors should be required to attend and participate in all regular CASS committee meetings and join in the analysis of discrepancies and maintenance and inspection functions. The Board wants more oversight, this would be a quick start. The following recent change is a start at the assessment stage of inspection.

Recent changes, revisions to Order 8300.10

FAA Notice N8900.7, Revision to Order 8300.10, Volume 2, Chapter 65, and Volume 3, Chapter 37 now provides additional guidance to all principal inspectors and all other assigned aviation safety inspectors on revisions to FAA Order 8300.10. The Airworthiness Inspector’s Handbook,” Volume 2, Chapter 65, Assess Section 121.373 or 135.431, the “Air Carrier Continuing Analysis and Surveillance System,” which has been completely re-written, and cancels Volume 3, Chapter 37, “Monitor Continuance Analysis and Surveillance Program/Revision.”

The changes described in the inspector’s assessment of a carrier’s CASS have been expanded and made more detailed in order to focus more attention to more vigorous continuous assessment of the system.

These changes are an important step toward the refinement of CASS requirements under 121.373. But is it enough?

Safety data collection

FAA has numerous reporting systems (perhaps too many) in place today but only one is required by regulation. That is 121.373. When you look at all the reporting activities now in place one wonders what happens to all the collected information and does it achieve the desired objective?

ATOS, the Air Transportation Oversight System, is designed to be somewhat like the CASS in that it is a continuous but broader program designed to detect weakness and predict an accident before it happens. This is what the CASS is supposed to do, but has failed in too many cases. ATOS uses a systemic approach by attempting to evaluate all the elements of the air carrier’s operating environment and it is supposed to ensure that all the elements have safety built into their operating systems. But, this is a much broader look at the whole airline operation than the CASS. ATOS has yet to be fully implemented and fails to include all air carriers. Perhaps CASS should be merged into ATOS so that a uniform approach can be applied.

FOQA, Flight Operational Quality Assurance, is a far-reaching attempt by the FAA to capture flight data and other operational information. The stated purpose is to (again) focus on problems before they cause an accident. There are many concerns about the collection and use of this data from the pilots unions and of course their use in civil litigation. FOQA operates as a voluntary participation program.

ASAP, the Aviation Safety Action Partnership, is another voluntary data sharing program that has been around for awhile but shares the same concerns that all the data collection systems share … how will the data be used? Most carriers are reluctant to share raw data without adequate protections from disclosure. Of course the raw data of maintenance discrepancies are provided through the CASS. Many would suggest that many of the programs should be combined or eliminated altogether.

Aside from the above data collection activities there are others: Cockpit Voice Recorder Data, Flight Recorder Data, Self-Disclosure Data Program (AC00-58), and the Aviation Safety Reporting System.

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