ATOS: Safety and inspection process for the Millenium

Feb. 1, 1999

ATOS: Safety and Inspection Process for the Millennium

Will It Provide a Higher Level of Safety or an Enforcement Gold Mine?

By Stephen P. Prentice

February 1999

Stephen P. Prentice is an attorney whose practice involves FAA-NTSB issues. He has an Airframe and Powerplant certificate and is an ATP rated pilot. He worked with Western Airlines and the Allison Division of GMC in Latin America, servicing commercial and military overhaul activities and is a USAF veteran.

Technicians in the air carrier business will be hearing quite a bit about ATOS in the near future. You may already have heard the magic words ATOS from one of your air carrier inspectors who probably just completed a course of instruction on it.

Technicians in Part 135 or 121 operations are acutely aware of the inspection process that goes on all the time with respect to their operations. Oversight and surveillance is designed to be constant and from time to time, the operations inspection people at FAA headquarters swoop down on you and perform a NASIP (National Aviation Safety Inspection Program) inspection. Enforcement sanctions usually follow.

NASIP has been the routine inspection process for many years and was considered to be the most intensive process to insure regulatory compliance by an air carrier. The NASIP inspections that we are all familiar with will eventually go away in their present form and will not be applied to carriers under ATOS. Unfortunately, it took Valujet to start the ball rolling and now the inspection process is going to change dramatically for the future.

ATOS stands for Air Transportation Oversight System. To quote from FAA publications ". . . ATOS is a new FAA oversight approach that uses system safety principles and systematic processes to assure that air carriers have safety built into their operating systems."

Safety will be built in and somewhat automatic under this new system, that is, if it works as advertised.

Back when Valujet jumped on the scene, the FAA was severely criticized from all sides because they were perceived as not doing their job. Their programs and their inspectors were alleged to have been ill-equipped and poorly trained. Of course, those of us in the business know this just was not true, but the politics of the day required a reaction to this accident and others. ATOS — this new safety and compliance oversight initiative is the direct result of all the reviews that occurred during and since that time.

FAA enlisted the aid of Sandia National Labs, an agency of the Department of Energy that has extensive background in safety and security areas. FAA requested Sandia to provide their expertise in improving the so-called Surveillance Improvement Process (SIP) from 1976 in order to sharpen the FAA oversight process. From this relationship grew Sandia's contribution in putting together the ATOS system. Implementation of ATOS however, will mean more government intervention into your air carrier activity. In addition, more budget, more resources, and as usual, more people will be required.

Don't get the wrong impression. ATOS is a well thought out and well-intentioned program designed to solve air safety problems. The main aspect of ATOS that was absent from previous inspection programs, as I see it, is the huge increase in the collection of operations data. When all this data is collected; it is analyzed, cataloged, and digested. Conclusions are gathered in order to identify potential weaknesses and strengths of air carriers operations. After collection, these inspection reports are fed back to the carriers with any dangerous trends highlighted. The dangerous trends are what the system is designed to detect somewhat automatically.

The whole system is simply going to be computer-based. Data will be put into the machines regarding failures, incidents, and many other factors; and the computer will weigh this data and kick out a conclusion. Pretty scary stuff. Just think, the computer will tell the air carrier what needs to be done. Not real people. The other facet is that the air carriers will provide the data to hand the FAA the facts to possibly bring action against them. However, in addition to the dangerous trends, the good things that are found are also highlighted. Best practices are sought and hopefully will be shared with others who might benefit from their use.

Do we see a problem in taking proprietary practices and providing them to other competitors? You bet! It might be dangerous to the health of the whole program. This area will have to be carefully looked at.

The FAA has finally come to the conclusion that the enforcement process for regulatory compliance does not and cannot provide the highest level of safety. Sure, it gets the attention of the people concerned by imposing fines and suspensions and even revocations, but does it really enhance safety? The answer after analysis was a resounding NO!

The new approach will include an aggressive and hopefully a consistent scientific method to assist in getting to the highest level of safety. However, this recognition does not by any means suggest that we will have a massive layoff of lawyers in the legal enforcement department at the Regions and in Washington. Quite the contrary. The new database may generate a huge collection of violations. Many continue to voice concerns that this new database will be used to force compliance by threats and coercion. We have to keep in mind that enforcement philosophy changes depending on which way the political winds are blowing. FAA says that enforcement will not be the tool of preference to ensure regulatory compliance. Many say, "believe that, and I have a bridge to sell you." Remember the "ticket" issuance system that was proposed just this last year? It's still out there waiting for the right time to start.

Trust has never been the strong suit of the FAA authorities. Nonetheless, there is a somewhat kinder and gentler attitude being published, at least for the implementation of this new system. ATOS will provide the inspector with better data and improved documentation of the problem areas. Better to document the enforcement action? Perhaps.

Another key element of this new system is the pressure to build into each element of an air carriers operation what I like to call, a safety trigger. This may seem redundant at first, because after all, we do have significant inspection processes in place in all operations. But, are they designed to ring a bell when something is out of line? This is a key element of the process. FAA wants ATOS to be self-executing so it will tell us when something is out of tolerance and may compromise safety or at worst, cause an accident. We have to remember — FAA admits that mere compliance with regulation does not provide the highest level of safety!

Initially, only ten major air carriers will have this new system applied to them. In addition, any new entrants into the game will be governed by this new system. Other 121 and 135 maintenance and operations people will be encouraged to start applying the basic principles of ATOS to their individual companies. Some at the smaller companies might ask where all of the support people and other staff to run computers and the like will come from? FAA has not given much thought at this time to how the smaller carriers will handle ATOS, or for that matter, how its final form will function. The primary focus at this time will be on new entrants and the existing Big Ten air carriers.

The plan will require what is now called a Certificate Management Team to lay out a surveillance plan for each carrier and adjust it once a year. In addition, data analysts, data evaluators, and an overall Certificate Management Office in Washington will be required. Even dispatch is slated to have its own inspection system for its functions, as the need arises.

One of the important aspects of ATOS is the heavy emphasis it places on safety in general. Although safety is usually given some lip service in just about every program that comes out of Washington, it is raised to a significant level under the ATOS system.

Safety Directors in concert with Chief Inspectors and Maintenance Directors will all share overall responsibility for ferreting out dangerous procedures or practices and causing them to be eliminated or changed.

Stay tuned, we will give the nuts and bolts in a follow-on article.