FAA's Proposed SDR Revisions Receive Scathing Reviews

Editor's note: ASW culled the following comments from the Federal Aviation Administration (FAA) docket:

FAA aviation safety inspectors

Robert Corcoran: "The [FAA proposal to overhaul the service difficulty report (SDR) system] does not ask for sufficient information to do meaningful trend analysis. Attached is an SDR, highlighted with the items this [Notice of Proposed Rulemakeing (NPRM)] calls for. Notice that there is no requirement for either part numbers, part names, or legible, meaningful text to accurately describe the failure, malfunction or defect. This is valuable information to effectively trend problems. I suggest that a requirement for this information be included (when available) in these proposed rules."

The airlines

American Airlines: "It is our opinion that this new final rule excessively burdens the industry with additional requirements with little value to the safety of the flying public. We emphatically believe this rule, as written, will be anti-productive and inconsequential to safety. ...

"The FAA response concerning 'Value of Service Difficulty Reports' states, 'In the past, the SDR database may not have been utilized to its fullest potential. Some reporting requirements were subjective, causing inconsistent reporting which could lead to analysis of incorrect data and errors in trend analysis.' American could not agree more ... We feel there were no significant changes to the rule that will substantially improve the quality of the reportable information.

"Currently, American submits over 2,000 Mechanical Reliability Reports (MRR) every year. Reviewing previous data that was not considered reportable under the MRR rule but would be reported under the new SDR rule, will cause American to increase their reportable items by an estimated 250+ percent annually. ...

American Trans Air: "Airlines have a vested interest in safe and efficient operation of their aircraft. We are in support of the FAA's role in the industry of rule enforcement and oversight in the public's interest. ... The current reporting system lacks some basic information standards. The new rule attempts to fix this by spelling out what data is needed for each event. ... The main problem with this information having any practical utility is the FAA and operators will be overwhelmed with data collection due to the ambiguity and perhaps unintended widening of the scope of reportable items."

Delta Air Lines: "...does not believe that the collection of [SDR] information is necessary as, over time, it has proved to be an ineffective tool for addressing reliability trends."

Federal Express: "While expansion of the structural and corrosion reporting was expected, FedEx had hoped that the FAA would take this opportunity to eliminate the duplicate reporting they require. On the original eleven 'Aging Aircraft' types, structural/corrosion findings must be reported once ... and the same information is required to be reported a second time per this rule. Such requirements are wasteful of the operators' resources, only support bureaucracy and increase the potential for the operator to accidentally violate the rule or the AD [airworthiness directive] by submitting one and not the other."

Air Canada: "Our primary concern with this proposal rests with the fact that we have seen no demonstrated increase in safety as a result of mandatory reporting. Though we have been routinely filing reports via the Canadian SDR program, which we understand is linked to the FAA database, we have yet to see any real benefits to offset the costs imposed by data collection."

Associations

Air Transport Association (representing most major scheduled carriers): "The FAA provides no examples of any proactive action benefiting aviation safety that have arisen from the many years of SDR submission."

ATA (from a Powerpoint presentation at a public meeting Jan. 5, 2001): "Our members have conservatively estimated that the number of original SDR reports will increase 30 to 50-fold! Is the FAA staffed to process this increase?"

Regional Airline Association: "RAA members have spent millions of dollars in man-hours over the last 40 years in providing SDR data to the FAA with little or no benefit to the regional industry."

National Air Carrier Association: "The FAA states that the full benefit of the [SDR] program has not been realized because operators have not been forthcoming with the required reports. We wonder why, if the proper performance of the agency's functions was degraded by not getting the information, it did not enforce the rule that was already in place?

The unions

International Association of Machinists: "Despite these major improvements, the IAM sees further room for change. For example, we support an additional requirement that aircraft total time and cycles be recorded. Further, station and flight numbers should also be required to permit tracking of particular problems occurring at a specific station or airport."

From individuals

Paul Kolbenschlag: "For the past 16 years I, and the company I founded, have been engaged primarily in the analysis and distribution of aviation safety and mechanical reliability data, the principal source of which is the FAA Service Difficulty Reporting System databases. ...

"With that background, my principal comment is that the proposed changes encompassed in this NPRM appear to have been made in good faith by persons who had little to no knowledge of the overall SDR program. Several proposals are completely unrealistic and unworkable, while others have been previously tried and discarded. ...

"The present SDR program can be made to work by more clearly targeting the data to be collected while eliminating the collection of unneeded reports. The present system of requiring submission of reports only of inflight occurrences while not collecting equally and more serious reports of deficiencies discovered during inspection and maintenance is irrational."

Alex Richman, AlgoPlus Consulting (Dr. Richman is also an ASW contributing editor): "SDRs are extremely useful. In spite of the current limitations in SDR data, it is possible to collate the records for individual aircraft. Improved reporting of registration and serial numbers, FAA's emphasis on additional and more timely data will make the Service Diffuculty Report System a vital part of the safety data network. "