9.
The data recovery strategy should ensure a sufficiently representative capture of flight information to maintain an overview of operations. Data analysis should be performed sufficiently frequently to enable action to be taken on significant safety issues.
10.
The data retention strategy should aim to provide the greatest safety benefits practicable from the available data. A full data set should be retained until the action and review processes are complete; thereafter, a reduced data set relating to closed issues can be maintained for longer term trend analysis. Programme managers may wish to retain samples of de-identified full-flight data for various safety purposes (detailed analysis, training, benchmarking etc.).
11.
Data Access and Security policy should restrict information access to authorised persons. When data access is required for airworthiness and maintenance purposes, a procedure should be in place to prevent disclosure of crew identity.
12. Procedure Document; this document signed by all parties (airline management, flight crew member representatives nominated either by the union or the flight crew themselves) will, as a minimum, define: a) The aim of the FDM programme. b) A data access and security policy that should restrict access to information to specifically authorized persons identified by their position. c) The method to obtain de-identified crew feedback on those occasions that require specific flight follow-up for contextual information; where such crew contact is required the authorised person(s) need not necessarily be the programme manager, or safety manager, but could be a third party (broker) mutually acceptable to unions or staff and management. d) The data retention policy and accountability including the measures taken to ensure the security of the data. e) The conditions under which, on rare occasions, advisory briefing or remedial training should take place; this should always be carried out in a constructive and non-punitive manner.
f) The conditions under which the confidentiality may be withdrawn for reasons of gross negligence or significant continuing safety concern. g) The participation of flight crew member representative(s) in the assessment of the data, the action and review process and the consideration of recommendations. h) The policy for publishing the findings resulting from FDM.
13. Airborne systems and equipment used to obtain FDM data will range from an already installed full Quick Access Recorder, in a modern aircraft with digital systems, to a basic crash protected recorder in an older or less sophisticated aircraft. The analysis potential of the reduced data set available in the latter case may reduce the safety benefits obtainable. The operator shall ensure that FDM use does not adversely affect the serviceability of equipment required for accident investigation.
Appendix to ACJ OPS 1.037 (a)(4)
Getting to grips with FOM
The following table provides examples of FDM events that may be further developed using operator and aeroplane specific limits. The table is considered illustrative and not exhaustive.
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