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).
