Transcript

Development of voluntary reporting system of aviation safety information in Japan

Satoshi ISHIDAAviation Safety and Security

Promotion Division, JCABJAPAN

Thirty Fourth APEC Transportation Working Group Meeting, Brisbane, Australia13-17 June 2011

TPT-WG34, Brisbane, Australia

Thirty Fourth APEC Transportation Working Group Meeting, Brisbane, Australia , 13-17 June 2011

3. Establishment of voluntary information system (③)  under Non-punitive circumstances

1. Definition and framework of State Safety Programme (SSP) (①)2. Equalized statement of Safety Management System (SMS) framework (②)

Annex 1 Annex 6-Ⅰ Annex 6-Ⅲ Annex 8 Annex 11 Annex 13 Annex 14

Personnel Licensing

Operation ofAircraft

-Commercial Aeroplanes

Operation ofAircraft

-Helicopters

Airworthinessof Aircraft

Air TrafficServices

Aircraft AccidentAnd IncidentInvestigation

Aerodromes

SSPDefinitions

SMSFramework

①SSPDefinitions

SMSFramework

SSPDefinitions

SMSFramework

①① SSPDefinitions

SMSFramework

① SSPDefinitions① SSP

DefinitionsSSP

Definitions

SMSFramework

SSPFramework

Attachment C

SSPFramework

Attachment J Attachment J Attachment A Attachment D Attachment F

SSPFramework

SSPFramework

SSPFramework

SSPFramework

Attachment C

SSPFramework

Appendix 4 Appendix 7 Appendix 4 Appendix 6 Appendix 7

②② ② ② ②

Voluntary reporting system

① ① ① ① ① ① ①

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Amendment of Annexes to the Chicago Convention (effective date: 11/2010)

TPT-WG34, Brisbane, Australia

Thirty Fourth APEC Transportation Working Group Meeting, Brisbane, Australia , 13-17 June 2011

Transition to new management system of aviation safety in Japan

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FY2010 FY2011 FY2012 FY2013

ICAOUSOAP

SSP implementation

Development of Voluntary Reporting System

Framework for implementation

Performance-based   SMS

ALOSSPI

Research and Examination

Coordination with affiliates

Improvementof legal system

CSA Transition to CMA CMA

TPT-WG34, Brisbane, Australia

Thirty Fourth APEC Transportation Working Group Meeting, Brisbane, Australia , 13-17 June 2011

Japan’s current reporting system:ASI-NET (Aviation Safety Information Network)

• Operated by a foundation since 1999• Reporting system aimed only at flight crew• Collected data: de-identified, not disclosed • Government ensures protection of safety

information by its inaccessibility to the reporting system

• No immunity from administrative sanction or criminal prosecution

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TPT-WG34, Brisbane, Australia

Thirty Fourth APEC Transportation Working Group Meeting, Brisbane, Australia , 13-17 June 2011

Reporting system of aviation safety information

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Mandatory reporting system by pilot in

command

CAA #76, 76-2

InjuryAccident

MajorIncident

which may cause accident

Minor incidentwhich may affect safe operation

Mandatory reporting system by operator

CAA #111-4

Pilots

Other Unsafe Operation / Condition

No access by JCABto the information reported through this system

CAA : Civil Aeronautics Act of Japan

ASI-NET ( operated by the

third party )Airlines / Cargos

Voluntary reporting system by operator

TPT-WG34, Brisbane, Australia

Thirty Fourth APEC Transportation Working Group Meeting, Brisbane, Australia , 13-17 June 2011

Key points at issue for the development of voluntary reporting system

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Annex13, Chapter8, item8.3“A voluntary incident reporting system shall be non-punitive and afford protection to the sources of the information.”

1.

• ICAO standard requires “Non-Punitive”1 voluntary incident reporting system

• ASI-NET is intended only for air operators: A voluntary reporting system for all parties involved in aviation including ATC, CNS and airport operation is necessary

• Exploratory committee meetings were held this year to discuss toward effective implementation

• This presentation shows points at issue and opinions delivered at the exploratory committee

TPT-WG34, Brisbane, Australia

Thirty Fourth APEC Transportation Working Group Meeting, Brisbane, Australia , 13-17 June 2011

Case study• US: Aviation Safety reporting System (ASRS) since 1976

– Operated by NASA

• UK: Confidential Human Factors Incident Reporting Program (CHIRP) since 1982– Operated by the CHIRP Charitable Trust

• EU: Directive 2003/42/EU

Based on the concept of “Just Culture” Willful misconduct and gross negligence are not covered Collected data: de-identified Disclosed in public (ASRS) / Not disclosed except summary report

(CHIRP) Immunity:

– Judicial proceedings not instituted for collected data– Mitigation of administrative sanction 7

TPT-WG34, Brisbane, Australia

Thirty Fourth APEC Transportation Working Group Meeting, Brisbane, Australia , 13-17 June 2011

Scope of the voluntary reporting system

• Information to be collected– Handling of speculation/hearsay– Reporting format that promotes reporters to suggest

improvements

• Reporters considered– Passengers, employees involved in non-aviation field– Reporting through SMS operated by industry is

preferred rather than individual reporting in order to avoid bypassing organizational reporting systems and duplicated reports

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TPT-WG34, Brisbane, Australia

Thirty Fourth APEC Transportation Working Group Meeting, Brisbane, Australia , 13-17 June 2011

Operator of the voluntary reporting system

• Non-punitiveness and confidentiality of safety information are eventually achieved in ASI-NET, but not ensured by enforcement policy

• In the case that non-governmental institutions collect data reported by the government-operated fields (ATC, CNS, operation of some airports), information security must be considered

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TPT-WG34, Brisbane, Australia

Thirty Fourth APEC Transportation Working Group Meeting, Brisbane, Australia , 13-17 June 2011

How to ensure Non-punitive circumstances

• Common understanding is needed for all parties involved in the aviation field

• Incentive is necessary to promote voluntary reporting

• Reviewed in light of personnel affairs, administrative guidance/sanction and criminal prosecution

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TPT-WG34, Brisbane, Australia

Thirty Fourth APEC Transportation Working Group Meeting, Brisbane, Australia , 13-17 June 2011

Personnel View

• Objective: aviation sector operated by the government in addition to private enterprises– ATC, CNS, operation of some airports

• Incident reported through voluntary reporting system should not be noted in the personnel record

• Impact on career may be considered

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Thirty Fourth APEC Transportation Working Group Meeting, Brisbane, Australia , 13-17 June 2011

Administrative View

• Administrative guidance should be considered non-punitive as a measure for ensuring safety– e.g. Letter of notice/warning

• Possible ways for reduction/exemption from administrative sanction:– Stipulation of waiver on enforcement policy– Segregation of collected data from the government

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Thirty Fourth APEC Transportation Working Group Meeting, Brisbane, Australia , 13-17 June 2011

Penal View

• Voluntary reporting system should not apply to accidents and major incidents with injury which are subject to the penal code

• As the cultural background, victims’ sentiment is valued rather than the importance of investigation of the cause of accident

• Further discussion is necessary based on particular cases collected through the voluntary reporting system for considering protection of reporters from criminal prosecution

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Thirty Fourth APEC Transportation Working Group Meeting, Brisbane, Australia , 13-17 June 2011

Securing confidentiality of the source of information

• Information of the reporter must be confidential and protected from regulatory/judicial authorities in a proper manner

• As with most voluntary reporting systems, reporter’s personal data is de-identified by using “confidential report”

• Personal information contained in the report should soon be deleted from the database 14

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Thirty Fourth APEC Transportation Working Group Meeting, Brisbane, Australia , 13-17 June 2011

Future discussion of enforcement policy

• Role models were reviewed in the exploratory committee

• Further study is necessary for establishment of clear criteria for execution of administrative sanctions

• Development of effective and feasible enforcement policy along with administrative operation is needed

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TPT-WG34, Brisbane, Australia

Thirty Fourth APEC Transportation Working Group Meeting, Brisbane, Australia , 13-17 June 2011

Conclusion

• A voluntary reporting system is now in the process of development in Japan

• Research and discussion of diverse aspects was conducted in the exploratory committee

• Discussion on the Non-punitive circumstances is focused on personnel affairs and administrative guidance/sanctions

• Further discussion is necessary for introducing an effective and feasible enforcement policy

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Thirty Fourth APEC Transportation Working Group Meeting, Brisbane, Australia , 13-17 June 2011

FIY: Safety Information Protection Task Force (SIP TF)

• The establishment of SIP TF is recommended in HLSC2010 and authorized in A37

• Scope: Making findings and recommendation for development/amendment of relevant ICAO SARPs and guidance materials

• A kick-off meeting was held on May 4-5, and working groups were established for further research and discussion

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Thirty Fourth APEC Transportation Working Group Meeting, Brisbane, Australia13-17 June 2011

Thank you


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