This journal article, Secondary Learning and the
Unintended Benefits of Collaborative Mechanisms: The Federal Aviation
Administration’s Voluntary Disclosure Programs, was in my field of interest
and study. Published in Regulation and Governance trade journal,
I was able to relate to the subject matter throughout the article. This article is well organized as all
components that are expected in a professional article have been systematically
organized: Abstract (with keywords), Introduction, Methodology, Table and
Conclusion. The sections have been
well-developed all the way through.
Starting with the title, the authors’ work is concisely described and
reflected.
Abstract
The Abstract succinctly briefs the reader
as to what the paper will entail. The
authors explain to the reader that the advantages of voluntary disclosure
programs provide regulatory agencies with valuable information on risks that
exist in the airline industry as well as situations and areas of
non-compliance. The incentives that are
offered for disclosures include immunity from prosecution or reductions in
enforcement penalization. Subsequently
mentioned, as the article title reveals, is the introduction to the concept of
secondary learning through disclosures.
This is done through two case studies with the Federal Aviation
Administration’s voluntary disclosure programs: the Aviation Safety Action
Program (ASAP) and the Voluntary Disclosure Reporting Program (VDRP). The reasoning of the abstract is well served
by giving the reader an insight to ascertain the paper’s purpose.
Keywords
The Keywords
used were “aviation”, “process-oriented aviation”, “regulatory inspections”, “secondary
learning”, and “voluntary disclosure”.
Although some readers may find “aviation” to be slightly generic in this
context, the remaining words assembled would be satisfactory to use in a search
engine.
Introduction
The introduction
retains the attention of the reader by describing in detail the background of
the subject matter. The authors explain
that regulatory agencies have traditionally used command and control modes for
regulation. But now collaborative tools such
as voluntary disclosure programs are becoming increasingly popular with
governmental agencies. The authors
explain that these programs are “extremely controversial”, however, at this
point they do not go into detail as to why.
They explain the benefits of organizations, companies, and disciplines voluntarily
reporting their own violations for “reduced sanctions” as well as the opportunity
to collaborate with the regulators to repair or mitigate problems or issues. This is a win-win situation for the
regulators as these programs increase the amount of available information at a
very low cost to the agency. As the
reader progresses through the introduction, the authors now mention that
scholars have criticized the programs as giving agencies a free ride that
without command and control mechanisms to supplement them, is “completely
ineffective”. Again, a further
elaboration of the minus points could help accentuate the positives later. The authors are successful in giving the
reader solid background information regarding the voluntary reporting systems
to regulators.
The focus of the
paper, however, is to highlight the unconsidered (i.e. side) benefits of the
program: The secondary learning that occurs above and beyond that of violation
information. The authors define
secondary learning as “those details often invisible to those outside an
organization or inside the organization but not ‘on the ground’.”
The researchers base the results in their article on
two questions: Firstly, “Is there evidence
that secondary learning occurs within voluntary disclosure programs?” And secondly, “What are the structural
elements of voluntary disclosure programs that lead to a more effective and
complete exchange of secondary information?”
With these comprehensive questions, they are able to provide themselves
with the framework to move forth in their research in conjunction with the
FAA’s ASAP and VDRP programs.
The article continues in a well-organized manner
with well-developed sections. As the
benefits of voluntary disclosure to regulatory agencies has been stated. The authors continue with the assertion of
benefits to air carriers. These include
industry reduced enforcement and sanctions, increased flexibility, and access
to government-funded technical assistance.
Other side benefits mentioned through scholarly references include a
positive reputation with the public as being seen as socially responsible and
safe. The regulators also benefit from
public perception as being seen as “good guys”.
Literature Review
The authors synthesize the literature in a
well-organized manner by using their reference sources with quotations to
solidify their objectives. For example,
when justifying yet another reason why regulatory agencies should embrace
voluntary disclosure, they quote Pfaff & Sanchirico (2000), “…the best
information is in the hands of the industry, and it is difficult to obtain
without cooperation.” Quotes from one
scholar are often supplemented with those of other scholars: “Voluntary
disclosure programs should at the very least help regulators overcome access
issues by increasing available information about regulatory violations and
potential problems (Lyon & Maxwell, 2007).”
After a solid background is given regarding
voluntary disclosure, the article continues to point out that industry managers
often face challenges in monitoring and understanding lower level employees which
may be due to improper communication channels or even changes in
personnel. Therefore the FAA voluntary
disclosure programs are designed to allow joint ventures and secondary learning
due to the industry’s common objective of improving safety. These collaborative efforts also result in
the building of trust in relationships of the parties involved. Within the article, the authors develop a
definition of secondary learning in voluntary disclosure programs by revealing
the presence of secondary learning in the operation of two voluntary disclosure
programs operated in conjunction with the FAA: ASAP and VDRP. This secondary learning gives key input to
management as to areas of potential risk at the operational level of the
company.
Only the two programs are examined by the
authors. And as it may have beneficial
to examine (at least) one more, the authors confidently claim that the two
programs alone accurately identify which structural elements of voluntary
disclosure programs lead to secondary learning.
Methodology
Perhaps one of the more interesting and unique
aspects of this study is the methodology used.
The researchers explain their methodology in a clear and succinct
manner. The ASAP and VDRP studies were
used because these voluntary disclosure programs differ in several key areas
that can assist in assessing which area, as well as to what degree, secondary
learning is taking place during the interaction between the FAA and air carrier
employees. The authors state that the
FAA has historically had a “close” relationship with commercial aviation. They leave their statement slightly ambiguous
without any reference as to how they came to this conclusion.
13 observations and two interviews were used in the
data collection process. Although this
showed a positive approach to sampling by not limiting the method to only one
type, the authors limited the sampling to only two major legacy carriers, one
low-cost carrier, and one regional carrier.
The authors laud their choices as a broad sampling of the air carrier
industry. However they do not recognize
that there was no representation of the cargo carriers as well as the
non-scheduled supplemental airlines.
These latter two are noteworthy contributors to the industry and their
inclusion may have resulted in a broader, and perhaps more accurate, range of
industry-represented data.
The interviewees from the air carrier side were
chosen through a snowball approach as recommended by the FAA participants
involved. As this may be seen as an
easier task at hand for the researchers, it could be argued that perhaps a more
random approach of sampling may have yielded a broader range of participants
from the air carriers. Having said this,
the recommended individuals for the interviews were all intimate with the ASAP
and VRDP programs and thus the authors may argue that this snowball method was
indeed the preferred method for data collection.
The “key” interviewees were specifically chosen for
their roles in the programs. It cannot
be disputed that these regulators were well-qualified for this study. FAA representatives interviewed included
three FAA headquarter staff who were responsible for designing and implementing
ASAP and VDRP, four FAA field inspectors responsible for overseeing ASAP and
VDRP at four different airlines, four different air carrier managers
responsible for implementing ASAP and VDRP, one NASA official responsible for
analyzing ASAP data, and one aviation trade association official who was
responsible for creating VRDP and who has experience in implementing both
programs.
Each recorded interview lasted between one to one
and a half hours. Other participant
interviewee groups included air carrier ASAP representatives, FAA Certificate
Management Office principal maintenance inspectors, flight standards voluntary
safety branch personnel, as well as other groups which the authors felt would
make worthy contributions. As previously
stated, and arguably, a more random sampling may have been considered versus
the snowball approach to gathering participants. Although the questions asked were from a
pre-orchestrated interview protocol, interviewees had the freedom to take the
interview in any direction they chose.
The researchers ensured that their data were
comprehensive by including secondary sources consisting of scholarly sources,
media accounts of the ASAP and VDRP programs, as well as documentation from
Congressional hearings, reports from the General Accountability Office (GAO)
and Department of Transportation Inspector General (DOT-IG). All data collected from both interviews were
analyzed using an open coding scheme
that was developed to gain insight into behavior by regulators and airline
officials in both programs. The
researchers triangulated the coded interview data with the secondary source
data to derive an in-depth examination and analysis of the ASAP and VDRP.
As the well-explained methodology concludes, the
authors continue the article by giving a background of the FAA’s mode of
operation. They explain in relative
detail of how the FAA historically used a command and control approach towards
regulation, but later changed to a more process-oriented approach to the safety
oversight of air carriers. Although a
respectable amount of information is offered on this topic, references are
limited.
After a comprehensive background briefing, the
authors elaborate on two central focuses of the study, the ASAP and VDRP. They explain the Aviation Safety Action
Program as a voluntary disclosure program allowing airline employees to report
safety events to the FAA and to their managers without the FAA or the air carrier
taking punitive action against the employee based on the information in the
report. The Voluntary Disclosure
Reporting Program is subsequently defined as a program that offers airlines
reduced regulatory enforcement actions if they voluntarily report systemic problems
within their operational structure and work collaboratively with their local
FAA office on designing a solution to the problem. In short, the ASAP protects the employee
while the VDRP protects the air carrier and the ASAP involves particular events
while the latter involves problems that are systemic. The authors give full, detailed explanations of
both programs.
Although the authors mention that the information
disclosed is protected from the public under the Freedom of Information Act
(FOIA), they do not mention why it is
protected from public disclosure. This
slightly ambiguous mention could be clarified to the more detail-oriented, and uninformed,
reader that this information is exempt from public disclosure because
14 CFR Part 193 (Protection of Voluntarily Submitted Information), i.e.
voluntary submissions, are protected from the public under this act.
One tertiary benefit of ASAP and VDRP mentioned is
that this voluntary reporting helps the FAA because of scarce instructor
resources. Albeit critics may declare
that this revelation may overshadow the hiring of more inspectors. Although this can initiate a noteworthy
debate, it is outside the scope of this research project.
An airline’s Continuous Analysis and
Surveillance System (CASS) team, i.e. quality assurance personnel, are
responsible for conducting internal audits and collecting data from the ASAP
and VRDP programs to identify hazards, trends, and anomalies in the system. These programs provide both airline
management and FAA with valuable information about potential risks that may
exist within the airline’s operating system.
More notably, the programs offer the local FAA office valuable insight
into the air carrier for which they have oversight. Detailed examples of this are repeatedly
given in the article.
One particular example of secondary learning that is given was the
result of the deep involvement with pilots involved in the ASAP program. Air carrier managers became aware that safety
messages through cell phones or emails are not an effective way to provide
up-to-date safety information to the pilots:
“…between
flights they have got a lot going on in their lives and they are not as
inclined to pick up a safety publication and read it thoroughly like we think
they should for a variety of reasons… (Our) pilots are all signed up for
company email, but very few of them check it.”
Just
the same, the authors provide examples backing up their statements that the
VRDP also provides an important source of secondary information to the
FAA. They continue to assert that the
FAA is exposed to internal decision making within the carrier as to what
decisions would be feasible, in the airline’s opinion, and what decisions would
not be—and why not. Perhaps one of the
more explicit revelations is that the local FAA office gains insight into the
overall safety culture of the air carrier’s upper management. Air carrier decisions are openly negotiated
and discussed in front of the FAA throughout the VRDP process.
The
authors mention that critics in both the air carriers and FAA may find it
cumbersome that two programs are doing the same thing and thus together are
inefficient. This would be an ideal
place for the authors to reemphasize a major, relevant different between the
two programs: ASAP is an individual or employee-level reporting program, while
VDRP is a company-wide reporting program.
An amenity to the article is a
nicely constructed table by the authors that is inserted to sum up many of the differences between the ASAP and VDRP
and clearly explain how each program works.
As the explanations can get lengthy, this table serves as a clear
summation of the two.
As the subject matter discussed in the article can
be intricate, especially to the non-aviation reader, one of the strongest
attributes the authors have demonstrated in this article is clarifying points
through examples. While several are
used, they are all effective.
As
the authors set out to answer their questions about secondary learning, their
research and findings, it is clear that their objective is met. An investigators role is to connect their
theory to the data. The authors in this
case have successfully done so through their research.
Throughout the article, the authors use language
that is easy to understand and aimed at audiences from non-aviation
backgrounds. These are noted in
parenthetical examples such as, “We were arriving STL [St. Louis
International Airport] and had a big tailwind. We were
cleared
via the KAYLA [name for a navigation aid or waypoint] arrival…” i.e. STL and
KAYLA are explained for the non-aviation reader who may unlikely be able to
understand these. The grammar,
punctuation, and diction throughout the article are professional, although I
did find a word misspelled that should not have been overlooked in an article
published in a professional journal such Regulation
and Governance, e.g. the word recurrence
had been misspelled as reccurrence
(p. 443, 2nd para.) Clearly
an oversight, it was the only one I found.
Overall, the article is well-written.
Most
importantly, the authors are convincing through their findings. Although they do make mention of other agency
programs such as the Securities Exchange Commission’s Consolidated Supervised Entities
program, no reference is made of some other more relevant aviation-related
programs such as NASA’s Aviation Safety Reporting System (ASRS).
Lastly,
although it is mentioned how these voluntary
reporting systems can be applied to other industries, the authors do not
mention applying it to other sectors in aviation such as large corporate flight
departments and non-scheduled operators.
This could be an area of examination and analysis for future research.
Conclusion
The
authors are succinct in their conclusion that these programs can help build a
“reservoir” of information that both regulators and managers can use in the
future to evaluate reports and suggest solutions and regulations. The building of trust between related parties
is once again emphasized.
My
recommendation for this article is that of acceptance with the optional minor
revisions mentioned herein. The authors
keep the reading interesting while sufficiently adding to one’s knowledge base
while adhering to the standards of the Regulation
and Governance journal.
I
also recommend that this article be used for future research for investigators
and SMS professionals seeking to implement similar programs in other global
regions within their own regulatory structure.
Reference
Cited
Mills, R & Reiss D.R. (2014). Secondary
learning and the unintended
benefits of collaborative mechanisms: The Federal
Aviation Administration’s voluntary
disclosure
programs. Regulation & Governance, (pp. 437–454).
