Cost and Benefit Analysis vs Successful Safety Programs: Is the FAA and A4A Using Flawed Logic to Manage Safety Improvements? Do Pilots Actually Know Safety Better?

Air Transport Association (ATA), or now Airlines for America (A4A) and the FAA can not claim all of the credit for the huge improvement in airline safety over the last decade in my opinion. As a matter of fact and record, both the FAA and ATA now A4A, opposed, and opposed with great vigor, virtually every safety of flight recommendation from pilot groups and pilot associations, from individual pilot recommendations directly to the FAA and/or the employer company, from the NTSB and from just about every safety foundation, association and organization, not just in the last decade, but in the rememberable history of this writer. It has only been after sustained high levels of Washington lobbying, high profile professional papers delivered, public relations campaigns and other dedicated efforts that the FAA has agreed to any safety regulatory or legislative improvements and on the part of commercial companies, after very tough pilot associations legal negotiations for contractual safety improvements.

Examples? Collision Avoidance Systems (TCAS) for Cargo, Flight Duty and Rest Regulations, Improved Flight Crew  Training Requirements, Cockpit Smoke Equipment, improved security, higher ATC standards for aircraft handling and routing around severe convective weather, Aircraft Rescue and Firefighting (ARFF), Crash Fire and Rescue (CFR) at airport equipment and manning requirements and training, hazardous materials air cargo handling rules, regulations and laws.

Again, these are but a few of the many safety improvements worked for by commercial pilot associations, pilot trade groups, as well as various global flight safety oriented foundations.

Now let’s talk ASAP, the Aviation Safety Action Program. The joint commercial pilot working group worked 1993 to Sept 1995 on the Proposed Draft FAA Advisory Circular for Airline ASAP, based on the prototype successful program established by American, Allied Pilots Assn and the FAA Southwest Region. The FAA however sat on that AC, until publishing their first draft in Oct 1998 . The Final ASAP Advisory Circular appeared I believe in 2001. Many airlines then fought ASAP participation until finally agreeing and adopted ASAP in the mid 2000’s, fully ten years after it was recommended.

So I would challenge anything stated about safety by the FAA and A4A in terms of their advocacy and management thereof. In fact the FAA and A4A opposed ASAP and virtually all of these safety programs that eventually became very valuable programs.  Could it be argued that FAA and A4A are anything but an impediment to airline safety?

Oh, one more important point. All of the safety recommendations made by pilot associations and adopted as regulation, rule or law, have worked!!  I would argue that this is why the commercial airline industry is safer today than 10 years ago. That is why we are safer today than ten years ago, not because the FAA and A4A have argued the supposed “Cost and Benefit Analysis” at every safety program proposed.

It is my opinion that lawyers for the FAA and A4A have used “Cost and Benefit Analysis” in some cases to delay safety programs and have not, in so doing, protected the industry from costs. Quite the opposite is true in my opinion. This delay may have actually led to repeated human factorsmishaps of the same type being suffered throughout the industry again and again without resolution.

These costs related to commercial aviation disasters have wreaked financial havoc in the commercial airline industry by allowing hundreds of millions of dollars and hundreds of lives to be wasted, while substituting legal wrangling and administrative procedures to take precedence over safety.

For safety, look to the person with a personal stake in the argument and improvement.  Do not look to the supposed “Cost Benefit Analysis” argument for any value in safety.

Published by Capt. Paul Miller

Aviation safety expert with 43 years in the sky

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