1. The
LEading EdgE
A Comair Central Air Safety
SPRING 2009 Committee Publication
Rebirth of
ASAP
at Comair
By Dean Weaver,
CRJ 50 First Officer
This month safety at Comair takes an
enormous leap forward now that the
airline industry’s most powerful tool
to identify safety threats is returned
Photo by Brian Futterman
to pilots.
The 30th Anniversary CRJ900 sits underneath the saucer-shaped roof of Terminal 3 at John
The Aviation Safety Action Program F. Kennedy Airport. Delta’s Terminal 3 was a landmark structure when built in 1960 for Pan
(ASAP) is back after Comair man- Am. The four-acre roof with its large overhang was designed to keep passengers dry while
agers, pilot union leaders, and Fed- boarding planes in uncovered jet bridges. It was renamed the Pan Am Worldport in 1971
when Boeing 747s began parking at its gates.
eral Aviation Administration officials
agreed to a better-defined process
Now, the ASAP Event Review Com- The new agreements and manual
that stipulates how pilots are shielded
mittee with representatives from the should lay the foundation for building
from disciplinary action if they are
pilots union, the FAA, and the Comair trust between pilots and company
willing to explain their mistakes.
Corporate Flight Safety Department managers. This trust is essential
A two-party Letter of Agreement will investigate all safety incidents. because, without pilot participation,
between the union and the company The Chief Pilot’s Office will no longer ASAP cannot succeed.
creates a new administrative manual investigate safety incidents if the
pilot is participating in ASAP. The new ASAP program is designed
that details exactly how each ASAP
to quickly insulate pilots from disci-
report will be accepted into the pro-
Once a report is accepted into the plinary action to keep the focus on im-
gram. A three-party Memorandum of
ASAP program, the FAA has agreed provements to safety versus punish-
Understanding between the union, the
not to suspend pilot certificates ment for mistakes.
company, and the Federal Aviation Ad-
or pursue civil fines for mistakes.
ministration also has been approved. “Protection for a pilot now begins
Comair managers have agreed to
The halt any parallel investigation into the minute they make the phone call
to the ASAP Hotline,” said Captain
incidents accepted into ASAP and
InSIde… not to pursue company discipline. Chris Obertin, an ALPA Safety mem-
ber and representative on the ASAP
The most discipline a pilot partici- Event Review Committee. “Now,
pating in ASAP will receive is a Let- the investigation of ASAP events
3 ASAP Definitions ter of Warning from the FAA. This has officially shifted from the Chief
letter stays on the pilot’s file for two Pilot’s Office and Flight Operations
3 Important ASAP Info years. Letters of Warning are rare.
Since 2004, Comair has received
to Comair’s Corporate Flight Safety
Department. We believe this new
4 Frequently Asked 5,147 ASAP reports, and only 70
Letters of Warning have been issued
program will be very successful.”
ASAP Questions by the FAA. Please see ASAP page 2 

2. ASAP computer screen until the de-identi- Pilots who submit reports rejected
Continued from page 1 fied case is closed. for the “Big 5” are subject to FAA
enforcement action, law enforcement
The language in the new agreements ASAP reports are de-identified by action, and discipline by the company.
takes any gray areas out of the ASAP removing the flight numbers, dates, Rejection of reports for these reasons
process. Pilots and airline managers and names from the event. All data is extremely rare. Since the inception
have clear guidance on how to handle is kept in a secure room. Swipe card
any safety incident, said Captain of ASAP at Comair, there has never
access is given to only a handful of been a report rejected for the “Big 5.”
Matt Sanderson, manager of Comair Safety Department personnel at
Corporate Flight Safety. Comair. Airline managers can see the The ASAP ERC also has the ability to
“I think having the additional protec- analysis of safety trends at Comair vote unanimously to reject a report
tion from company discipline will but will not be given access to indi- for “intentional disregard for safety.”
foster a healthier reporting climate,” vidual cases unless they have been This also is a rare occurrence. Of
Sanderson said. “As pilots we must de-identified for training purposes. the 5,147 ASAP reports received at
realize this is our ASAP program, and Comair, only 17 were rejected for
Once pilots tell airline managers, in- “intentional disregard for safety.”
the more safety issues we report, the cluding a chief pilot, that they are using
more safety issues we can address.” ASAP all company investigations in-
, ASAP reports rejected for “intentional
The most obvious change pilots will volving the incident are referred to the disregard for safety” cannot be used
see when submitting an ASAP report ASAP ERC. However, airline managers by the FAA or Comair to discipline a
is that now it is all done electronically are still allowed to discuss time-critical pilot. Nor can statements made to the
via the Internet. The old tear and fax issues with pilots after an incident. ASAP ERC be used by Comair in any
sheets are gone. No more wonder- These conversations may include drug type of disciplinary action. Instead,
ing if the fax machine on the other testing, health and well-being of indi- the FAA and Comair may conduct
end was working after submitting an viduals, integrity of aircraft and other independent investigations into the
ASAP report. equipment, or removal from duty. incident. Both the company and FAA
may use information gathered from
The confirmation that a report is If the pilot’s ASAP report is later re- aircraft flight data recorders, main-
received is instantaneous, and the jected for any reason, the information tenance logbooks, and radar tapes
typed narratives should be easier for he provides in the ASAP report re- when investigating a pilot for “inten-
everyone to read. This system will mains confidential and cannot be used tional disregard for safety.”
not “time out” like electronic Irregular by the company or FAA for discipline,
Operations Reports and should be unless it is excluded for the “Big 5.” The only other reason to reject an
more user-friendly. ASAP report is for timeliness. The
Pilot reports will not remain confiden- ASAP ERC must be notified within
The ASAP Hotline number will still tial if reports are rejected for the “Big 24 hours from the end of the duty
exist, and pilots are required to notify 5,” which include: day for the date of the occurrence.
the ASAP Event Review Committee h Criminal activity This can be done by calling the ASAP
by phone within 24 hours after the Hotline and answering a few ques-
h Substance abuse
end of the flight sequence on the day tions. A full ASAP report must be
of the occurrence. This early notifica- h Controlled substances submitted within five days of the
tion is one of the requirements for an h Alcohol initial telephone notification.
ASAP report to be accepted.
h Intentional falsification
Please see ASAP page 3 
The new Internet-filed reports will be
done via a Web-Based Application
LEading EdgE
Tool (WBAT). Pilots will be given a
user name and password that allows The
them to log on and create a profile
with an e-mail and home address. The Leading Edge is a quarterly publication produced by volunteer Comair pilots
Once a case is closed, pilots will be who are members of ALPA’s Central Air Safety Committee. The goal of the com-
notified by e-mail. mittee is to promote and enhance safety at Comair.
Yet the most significant changes to Mail inquiries to:
this next-generation ASAP go far Comair MEC Editor: Dean Weaver
beyond report appearances. A very Attn: Leading Edge E-mail: Dean.Weaver@alpa.org
3490 Olympic Blvd., Suite 120
detailed process has been put in
Erlanger, KY 41018
place that dictates how each ASAP
submission is handled from the mo- Please share any ideas, questions, or comments you have with us.
ment the pilot clicks “Send” on the
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3. ASAP definitions
ASAP ASAP duties: The Event Review Committee (ERC) may assign to pilots making an
Continued from page 2 ASAP report these duties, which might include a crew resource management debrief,
interviews, and simulator training. Also required might be additional operating experi-
Once an ASAP report is accepted, ence with a line check airman; however, it is not a line check. The goal is to learn
the ASAP ERC will examine each about the causes of mistakes and prevent future mistakes as well as to train pilots to
report and look for systemic latent correct any deficiencies. These ASAP duties must be completed to the satisfaction
of the ERC. However, they do not include evaluated events such as line proficiency
safety threats. Once having identified checks or orals.
these safety concerns, the ERC can
Aviation Safety Action Program (ASAP): Designed by the FAA to encourage air carri-
work with airline managers, dispatch- ers and their employees to voluntarily report safety information that may be critical
ers, mechanics, schedulers, air traffic to identifying potential precursors to accidents. Safety issues are resolved through
control supervisors, and pilots to ad- corrective action rather than through punishment or discipline. It provides a method
dress any threats to safety. The goal for the collection, analysis, and retention of safety data. The FAA began this industry-
is accident prevention. wide program in March 2000. The program came to Comair in 2004.
event Review Committee (eRC): This group of three people reviews and analyzes all
The ASAP ERC may ask pilots to par- ASAP cases. The group has a representative from ALPA’s Central Air Safety Commit-
ticipate in a Crew Resource Manage- tee, Comair Corporate Flight Safety, and the FAA’s Flight Standards District Office.
ment debrief of the event or partici- This group of three meets on a regular basis and must reach a unanimous consensus
on each individual case when it comes to corrective actions or assigning ASAP duties.
pate in additional simulator training
It takes a unanimous vote of this group to reject a report.
or line-operating experience. The
goal of this additional training is to Letter of Correction: Issued to the pilot by the FAA demonstrating that corrective ac-
tions by the pilot were completed. This stays in the pilot’s record for two years.
improve pilot proficiency. The training
must be completed to the satisfaction Letter of no Action: Issued to the pilot by the FAA showing there was insufficient evi-
dence to prove a violation. It remains on file for 30 days.
of the ERC, but it is not considered a
line check and is not included in the Letter of Warning: Issued to the pilot by the FAA showing no ERC resolution was
pilot’s training records. reached. It remains on file for two years.
Sole-Source Report: This is an important term because it determines the level of disci-
Training events are rare, with about pline a pilot may receive when submitting an ASAP report. A sole-source report pro-
200 scheduled since the inception of vides the ASAP ERC with information that would otherwise be unobtainable. Because
the program. Every Comair pilot has this information is vital to improving safety, a pilot will not receive any discipline from
passed his or her ASAP assigned the FAA for a sole-source report accepted into ASAP.
training event, Sanderson said. A sole source is defined as: when the only source reporting the event is the pilot(s)
through ASAP report(s).
Another change to ASAP is a clause Example of sole-source report—an incident reported by a crew that nearly forgot to extend
in the two-party Letter of Agree- the landing gear but remembered in time to safely complete the landing without incident,
ment that preserves the integrity of unless reported by someone other than the flight crew.
the program even if tensions arise non–Sole Source: Every ASAP report is assumed to be sole source to the FAA, unless
between participants. determined to be otherwise known through FAA internal channels. An ASAP report
that involves an incident that the FAA has learned about from Air Traffic Control or an
The agreement has a 30-day “resolu- FAA inspector or through channels other than the ASAP ERC is non–sole source.
tion period” between union leaders
The FAA has agreed not to suspend pilot certificates or pursue fines against a pilot
and Comair managers. During this
whose ASAP report is accepted by the ERC. However, a pilot may receive a letter of
30-day period, the ASAP program warning for an FAR violation for a non–sole-source report if the FAA deems it neces-
will continue as usual, with the ERC sary. This letter of warning is the toughest disciplinary measure allowed under ASAP.
reviewing ASAP reports. It requires It stays on the pilot’s record for two years.
the head of the Comair MEC to Examples of a non−sole-source report:
meet with the president of Comair to 1. A crew files an ASAP report stating that it failed to level off at its assigned alti-
address the ASAP safety concerns. tude. The FAA receives a deviation notice through its Daily Report.
At the end of 30 days, the two must 2. A crew files an ASAP report discussing a GPWS terrain event. The FAA receives
meet again before any suspension of an FAA Hotline complaint from a passenger who was frightened by the abrupt
ASAP is permitted.h EGPWS recovery maneuvers during this flight.
3. A crew lands at the wrong airport by mistake. The event is common knowledge. h
ImPortAnt ASAP Hotline 1-866-274-7088
ASAP
(Call within 24 hours at the end of the duty day)
Electronic reports are submitted to: www.comairsafety.com
Info: Note: The ASAP program will be activated later this month. Pilots should continue to use
NASA’s Aviation Safety Report System until ASAP is active. Incidents filed prior to ASAP’s
being activated will not be grandfathered into the ASAP program.
Spring 2009 3

4. FAQs
Prepared by Dean Weaver,
Frequently Asked
ASAP Questions
necessity such as drug testing, such as radar tapes, mainte-
CRJ 50 First Officer/Air Safety health and well-being of individu- nance logbooks, or flight data
als, integrity of equipment, or recorders when gathering
Committee Member removal of a pilot from opera- information for an independent
tion. Pilots may discuss these investigation.
What happens when I call the
time-critical matters, but they
ASAP Hotline within 24 hours need to let managers know they How are ASAP duties
of the end of the duty day when are participating in ASAP. assigned to pilots?
the incident occurred?
do BOTH pilots have to submit • Participants may be asked to
• The pilot is protected, and any do a debrief so the ERC repre-
separate investigation by the ASAP reports and notify the
sentatives or Corporate Flight
company or Federal Aviation Ad- hotline individually? Safety staff can identify trends
ministration is halted. Any inves- or causes and work to prevent
• YES, the ASAP ERC must be
tigation conducted under ASAP future mistakes at the airline. A
notified within 24 hours of the
will be done confidentially by the pilot may be assigned a train-
event. Each pilot must submit an
ASAP Event Review Committee ing event in the simulator and
electronic report as soon as pos-
and Comair Corporate Flight retrained to proficiency. The
sible but no later than five days
Safety. The chief pilots and other program does not allow the
after the event.
managers will not have access company to counsel, suspend,
to these confidential reports and • If the pilot was unaware of an or discharge any participant, or
subsequent investigations. Some event, such as an ATC devia- to issue a letter of warning. The
of the de-identified information tion, a later submission may be FAA cannot suspend or revoke
may later be used for training accepted. Pilots have 24 hours the license of a pilot who is
purposes. to submit a report upon learn- accepted into ASAP. However,
ing they have been involved in a the FAA may issue a letter of
• The report is de-identified by re-
non−sole-source event. warning, which will remain on file
moving the flight number, names
of crewmembers, and date of for two years, or issue a letter of
What if my ASAP report no action, which is on file for 30
the event.
is later rejected? days.
• The Chief Pilot’s Office and
• If the report is rejected, the • A pilot’s ASAP duties could
ALPA status representatives
company and the FAA may start require additional training,
have agreed to abide by any cor-
their own independent investi- such as a simulator event, but
rective actions set forth by the
gations. However, neither the the company will not conduct
ASAP Event Review Committee.
company nor the FAA can use evaluation events such as line
• An Irregular Ops Report must the pilot’s ASAP narrative in the checks, proficiency checks, or
still be filed within 24 hours, but investigation. Nor can written or oral checks.
the pilot can have this report verbal statements made to the
reviewed by ALPA Safety Com- ERC or Corporate Flight Safety • Most of the time a pilot will
mittee members prior to sub- be used in these independent receive an e-mail to sign in to the
mission. Remember, an IOR is investigations. The only time secure ASAP website, known as
done to let the company know an ASAP report can be used is WBAT, to read a new message.
of an event. It is not the time for if it is rejected for the “Big 5,” The message may simply thank
confession or the time to ana- which include criminal activity, the pilot for participating in ASAP
lyze how the mistake could have substance abuse, controlled sub- and tell him the case is closed.
been prevented. IORs are not stances, alcohol, and intentional Additionally, the message may
de-identified and classified like falsification. offer some areas for the pilot
ASAP reports. to review to address the event.
• ASAP reports are off-limits for Sometimes, the pilot may receive
• A chief pilot or other Comair reports rejected for “reckless a phone call with some advice to
manager may contact the pilot disregard for safety.” But the prevent a future mistake.h
to discuss matters of operational FAA and Comair may use data
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