Laura L. Booth
Federal Aviation Administration
600 Maryland Ave SW, Suite 610E
Washington, DC 20024
RE: Draft Advisory Circular AC 120-66C, Aviation Safety Action Program (ASAP)
Dear Ms. Booth,
On behalf of the Transportation Trades Department, AFL-CIO (TTD), I am pleased to provide comments on the FAA’s Draft Advisory Circular AC 120-66C, Aviation Safety Action Program (ASAP). By way of background, TTD consists of 32 affiliate unions representing workers in all modes of transportation, including several unions in the aviation sector who have members that participate in ASAPs at their place of employment. We therefore have a vested interest in the circular.
Through this notice, FAA has proposed a new advisory circular on ASAPs, which allow aviation workers to report safety issues and violations without fear of discipline or reprisal. For years, TTD aviation unions have supported and helped develop these programs, and have found that when employees are able to share information in such an environment, significant safety improvements can be made from the data collected. TTD and its unions firmly believe that the use of ASAPs is integral to safety in the aviation sector.
As FAA proposes and considers the draft circular, it is important that the ASAP program continues to be a pillar of safety culture, and a resource for aviation workers. In its draft, FAA makes several changes that could have a positive impact on safety and the ASAP reporting process. However, we also caution FAA against changes which harm the trust that aviation workers place in the program and dis-incentivize reporting, resulting in the loss of a critical safety tool. Our comments in full may be found in the attached comment bundle. We also strongly endorse the comments filed by several TTD-affiliated unions: the Air Line Pilots Association (ALPA), the Association of Flight Attendants-CWA (AFA-CWA), and the Transport Workers Union of America (TWU).
We thank the FAA for the opportunity to comment on the draft Advisory Curricular, and we look forward to working with the agency in the future.
Sincerely,
Larry I. Willis
President