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6 Barriers
Pages 44-49

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From page 44...
... In order for AIR to contribute as much as possible to improvements in aviation safety, the FAA in partnership with industry, Congress, the Department of Transportation, and other involved parties must take aggressive action to overcome barriers associated with the following: · external pressures and influences on the FAA · coordination and communications within the FAA · legal issues · the rulemaking process · the economic impact of proposed changes to the safety management process EXTERNAL PRESSURES AND INFLUENCES Highly publicized accidents are often caused by factors not associated with the greatest aviation hazards. Unfortunately, time and patience are required to determine the causes of any accident and to understand how to prevent a reoccurrence.
From page 45...
... COORDINATION AND COMMUNICATIONS establishment of a senior interagency communications or safety management board that would coordinate the government's public comments on aviation disasters Many of the individual organizational elements within the FAA enjoy considerable autonomy over their assigned areas of responsibility but lack an effective means of communicating with each other and resolving differences. As demonstrated by the long time it typically takes to make regulatory changes, the lack of communication sometimes prevents the FAA from taking timely action to improve overall safety or operational efficiency.
From page 46...
... These issues are associated with the potential for public disclosure of sensitive information under the Freedom of Information Act, the possibility of regulatory enforcement against individuals or companies who voluntarily disclose unfavorable safety data, and increased exposure to legal liability arising from the litigation discovery process in an environment where more data is collected, stored, and shared. The recommended safety management process advocates the voluntary participation of airlines, manufacturers, and other stakeholders during the long period it would take to develop new regulations mandating compliance.
From page 47...
... , and/or letters of understanding with manufacturers, operators, pilot organizations, and others to serve the public interest and improve safety by encouraging the voluntary sharing of safety data, including data generated by industry safety analyses. This may involve limiting enforcement action based on voluntarily shared data and protecting such data from release to other parties.
From page 48...
... A similar problem will occur as the safety management process becomes more proactive, identifying safety actions that should be taken to eliminate risks before they cause an accident. Manufacturers and operators bear the cost of making safety improvements, and they will not support improvements unless the identified risks are credible and the corrective action seems reasonable in terms of effectiveness, direct costs, and indirect costs, including disruptions in operations and damage to their corporate reputations.
From page 49...
... The FAA should work with industry to develop confidence in the cost-benefit analyses used to justify changes in the safety management process. The FAA should also subsidize pilot projects by operators and manufacturers to validate the cost effectiveness of new systems for data collection, database management, and analysis.

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