Submit an OSAP Report
AFA Leads the Way in Aviation Safety Action Programs for Flight Attendants
By Former MEC Safety, Health and Security Chairperson, Valerie Walker; updated by Melissa Madden, MEC Safety, Health and Security Vice Chairperson
The purpose of the Onboard Safety Action Program (OSAP) is to improve safety through the prevention of accidents and incidents by encouraging Flight Attendants to voluntarily report safety issues and events that will help everyone involved identify and correct specific problems.
While it may seem completely out of the ordinary to be encouraging our Members to report a violation that would normally invoke a disciplinary response, both the FAA and the airlines provide protection from discipline for reports accepted into the program because of the value of the information to address safety issues. For reports of an apparent violation of Federal Aviation Regulations (FARs), the Flight A ttendant may receive a Letter of Correction or Warning Notice from the FAA, but this does not constitute a finding of a violation. The FAA will hold the correspondence in their files for a period of two years; nothing will be placed in the Flight Attendant’s personnel file. Additionally, United Airlines will not take any punitive action upon the employee based on the good faith reporting of a safety incident.
There are five exclusions to the immunity rules. The reported event must not appear to involve criminal activity, substance abuse, controlled substances, alcohol, or intentional falsification.
This type of non-punitive safety reporting system had long been lobbied for by many pilot unions, and has been very effective in addressing and improving issues that affect the cockpit. United pilots have had a program in place since 2000, and the program has migrated to other divisions including Maintenance, Dispatch and Airport Operations.
An employee observing a safety-related event should complete a report form within 24 hours following the completion of their domestic ID (48 hours internationally) and submit it to the OSAP manager. The manager then removes the employee name from the report and forwards it to an event review committee (ERC) consisting of one representative from each OSAP party, the FAA, UA, and AFA, who will review the de-identified report and will decide together what action, if any, should be taken. The OSAP manager then follows through to ensure the recommended corrective actions are complied with. The manager will serve as the point of contact for inquiries concerning the status of report.
Another benefit that was sought by AFA and adopted by OSAP is that when a Flight Attendant makes a report, it will be forwarded to the NASA Aviation Safety Reporting System (ASRS). The ASRS collects, analyzes, and responds to voluntarily submitted aviation safety incident reports in order to lessen the likelihood of aviation accidents. ASRS data is used to:
- Identify deficiencies and discrepancies and industry-wide so that these inconsistencies can be remedied by appropriate authorities.
- Support policy formulation by planning for improvements industry-wide.
- Strengthen the foundation of aviation human factors safety research. This is particularly important since it is generally conceded that over two-thirds of all aviation accidents and incidents have their roots in human performance errors.
Reports submitted to NASA ASRS are only for safety analysis and cannot be used for any other purpose.
The OSAP, along with ASRS, will help promote a safer working environment for all of our Flight Attendants. More information will be forthcoming after the FAA approves the program. Until then, we encourage you to review FAA Advisory Circular AC 120-66B, or talk to one of your ALPA counterparts.
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Benefits to Flight Attendants
Flight Attendants benefit from the Onboard Safety Action Program (OSAP) by being able to report violations of safety regulations and Company safety policies without fear of discipline or FAA enforcement action. For example, Flight Attendants concerned with being unable to perform their exit row briefings 10 minutes prior to door closure could report that they were unable to do this because passengers were not seated until the very last minute, without any concern for discipline or fines for failing to comply with a obligatory safety procedure. A Flight Attendant who had to stow trash in the lavatory for landing on a certain flight because there was no room in any acceptable trash stowage locations could submit an OSAP report in order to address the problem without the worry of incurring a fine from the FAA.
While many of our procedures and policies may look good on paper, what actually takes place on the line may differ greatly. Reporting information that affects the safety of our airline is valuable to all involved - especially the company and the FAA, so much so, that they are willing to suspend their normal course of action, such as discipline, work history notations, and civil penalties. The hope is that employees who are protected from discipline will be more concerned with reporting and less concerned about incriminating themselves or others. The program has been well received amongst Flight Attendants and to date has successfully identified many safety risks previously unknown to United and the FAA..
If a safety violation is observed by an FAA inspector or a supervisor, a Flight Attendant may still be able to submit an OSAP report, provided they meet certain criteria. In this situation the report must be filed timely, the incident must be inadvertent, must not involve criminal activity, substance abuse or alcohol involvement by a working employee, or intentional falsification of information. The reasons for allowing a report after observation of a violation are many, but primarily, it is human nature not to want to incriminate oneself. A Flight Attendant who may be cited for cracking ice in the galley during taxi could elect to say nothing, or could provide insight as to the reasons for doing this. Perhaps reporting that a full dinner service on a route that is almost always turbulent would lead to some service changes; thus avoid pressuring Flight Attendants into violating the regulations by preparing the galley on taxi.
There are many opportunities to improve cabin safety. We would like to eliminate inadvertent slide deployments, and avoid doors being left armed, to name a few. OSAP offers an opportunity, to those Flight Attendants who wish to participate, to fully discuss the factors leading to the action, without censure, so that better procedures can be created that will eliminate the possibility of human error in the future.
We encourage those participating in the OSAP program to feel free to provide any and all information that may be useful in improving the current regulations, policies and procedures. By providing a full explanation, problems submitted into the program can be corrected, and other Flight Attendants will not be compelled to repeat the mistake.
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What to Report
The Onboard Safety Action Program was launched January 15th, 2005. As the first Aviation Safety Action program specifically designed for Flight Attendants, we created a model program for the industry that will enable inflight safety professionals to report violations or possible safety issues that may affect aviation safety, while at the same time protecting them from fines or discipline.
In 2010, we agreed to a continuing Memorandum of Understanding, (MOU) signed by AFA, UAL and the FAA.
When a Flight Attendant has or thinks she/he has:
- Identified a potential safety hazard
- Violated an FAR
- Violated a safety policy or procedure
- Failed to follow safety guidance in the FAOM
- Or, they are just not sure,
they should file an OSAP report on Flying Together/SkyNet. A link is also provided on our United AFA website. Each Flight Attendant involved must file a report in their own words in order to obtain individual perspectives. The OSAP is here to identify, with Flight Attendant assistance, underlying safety issues, find root causes, recommend corrective actions and then track reports to ensure problems do not recur. Contrary to our usual recommendations to provide only information specifically requested, and because of the protective provisions afforded by this agreement, it is asked that Flight Attendants be candid and provide as much information about the underlying causes as possible, as accurate information is essential to eliminating the problem.
Remember, the report must be submitted within 24 hours (48 internationally) of the completion of the ID, the alleged violation must be inadvertent and must not appear to involve an intentional disregard for safety. The reported event must not involve criminal activity, substance abuse, controlled substance, alcohol or intentional falsification by an employee.
Keeping in mind that the purpose of this program is to identify and correct safety issues at United Airlines and in the industry, please feel free to contact your local Safety, Health & Security Committee for further information.
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What happens to an OSAP Report
As we have covered before, Flight Attendants who are concerned about a safety issue or a potential violation of regulation or company safety policy can take advantage of certain protective provisions by submitting an Onboard Safety Action Program (OSAP) report via SkyNet, within 24 hours (48 hours internationally) after completion of their ID, or within 24 hours of becoming aware of the possible violation. Alternatively, a report can be filed using the OSAP hotline, via FLTLINE option 7, but in those instances, a report must also be submitted via Flying Together/Skynet within 72 hours.
After a report is submitted, it is "scrubbed of identifying details, including names, so as to protect the anonymity of the submitter. On occasion, de-identified reports may be forwarded to appropriate departments for investigation and response to the event. If another employee is mentioned or involved, they will be given the opportunity to also file a SAP report, either an OSAP, or the appropriate SAP for their division. They, too, are afforded the same protections from fines and/or discipline offered to the original reporter. This reinforces the program's intent of evaluating systemic issues to improve our safety procedures, eliminating the possibility of human error. The submission of a detailed report will provide the corporation the necessary tools to affect change.
The Event Review Committee (ERC) evaluates the report, or event. If it meets the criteria, and is timely, it will be accepted into the program. Unless extenuating circumstances exist, or it is a sole source report, an untimely report will not be accepted. If the incident did not occur while performing the duties of a Flight Attendant, the report will be closed, and will not be forwarded or used for any other purpose.
Concise reports should contain enough information to be thoroughly evaluated. If a Flight Attendant is unable to perform the exit-row verification process before door closure, provide any and all information about events leading up to the violation. Was boarding delayed? What was the staffing? Was everyone in the proper boarding position? Were the exit row passengers late? All of this information is essential. The protective provisions enable Flight Attendants to openly report the event. If the report contains insufficient details, the OSAP Manager or the AFA ERC Representative may contact the reporter.
If a report is not accepted, that report will not be forwarded to the affected division or to the FAA, except in the case of criminal activity, intentional falsification or drug/substance use by a working employee. Reports which appear to involve harassment or discrimination will not be accepted into the program. Instead, a member of the ERC will contact the submitter directly to offer them alternative venues for reporting the incident. The contents of an accepted report will not be used to initiate or support any company disciplinary action, nor will it be used as evidence for any purpose in an FAA enforcement action. If a report does involve a violation of an FAR, the Flight Attendant may receive a letter from the FAA that will remain in their FAA file for up to two years. The Flight Attendant may also be assigned corrective action, to ensure required skills are performed to proficiency. The ERC may also utilize AFA Professional Standards, if indicated.
Many Flight Attendants have benefited from the OSAP program. The contents of many reports have provided the company and the FAA with invaluable information about the operational effectiveness of procedures and regulations. All reports are kept in the FASRS/OSAP database, and are used to track recurring problems and to trend events. Even the most minor incident could serve as a key to making our working environment and our airline safer.
Remember, OSAP reports must not involve:
- An Intentional disregard for safety,
- Alcohol or drug use by a working employee,
- Criminal activity, or
- Intentional falsification.
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What's the difference between OSAP and FASRs?
Both FASR (Flight Attendant Safety Reporting) and OSAP are reporting vehicles for safety issues, however FASRS is a company-sponsored reporting system, whereas OSAP is a non-punitive safety action program – negotiated and agreed to by the company, the FAA and the AFA. OSAP is designed to report inadvertent FAR violations, inadvertent violations of company safety regulations, and/or policies and procedures which undermine safety, or might contribute to violations of company safety policies, or FAR requirements. All OSAP reports are de-identified, and if accepted, the reporter is provided the protective provisions of the program, and will not be disciplined by the company, or fined by the FAA. OSAP's non-punitive provisions encourage reporters to be candid and truthful about their actions, but more importantly, the reason(s) behind their actions. This allows the Event Review Committee (ERC) to really understand the "root cause" behind these violations, identify and address those root causes.
FASRs meanwhile, is a more straight-forward safety reporting system, which collects safety, security, health and other data. The reporter is not afforded the protective provisions of OSAP, nor are the reports de-identified. Typically, FASRs would be the appropriate venue to report galley or aircraft equipment issues, security events, facility issues (domicile or employee parking lots), etc. Reports are forwarded (assigned) to the appropriate department or station for research and follow up. These "assignees" are then tasked with providing a response to the Flight Attendant. Let's take a look at the difference between the reporting systems.
Reports which identify broken bins or carts being boarded, or chronic deviations from catering SOPs at a given station, would best be reported in FASRs.
Reports of round-trip "turn galleys" which have limited trash space, and causes the Flight Attendants to stow trash in the lavatory for landing, belong in OSAP. In this case, company catering policies/decisions are undermining safety, and implicitly "encourage" the Flight Attendants to violate FARs. The Flight Attendants should also file an OSAP report to "self-disclose" their violation, and identify the underlying root cause/safety issue.
Most security reports/violations should be reported in FASRs, as the OSAP program cannot accept a "security" report which involves a TSA violation. This is due to the fact that the FAA, not the TSA, has agreed to the OSAP program, and the FAA does not have the authority to grant protective provisions to individuals who violate TSA regulations.
A report around a broken (and deferred) secondary barrier on a certain aircraft should be reported in FASRs.
A report which indicates there is confusion around the secondary barrier procedures between Flight Attendants and Pilots might best be suited to OSAP. In this case, the root cause/ safety issue has both training and FAOM guidance implications – despite the report itself being around "security" procedures. While TSA security violations cannot be accepted into OSAP, procedures, training and FAOM guidance on a range of subjects, could be accepted. Violations around expired badges, violation of security procedures (door access violations, etc) should not be reported in OSAP.
Non-compliant FAOM reports could be accepted into OSAP under a narrow set of circumstances – particularly if they identify a company policy or procedure which undermines a Flight Attendant's ability to keep their FAOM compliant. For example, inconsistent or inadequate notification of the revision, out-of-date Hotboards, FAOM LEPs which are in error, inconsistent distribution, (sometimes the revision is in the mail file, sometimes it's placed elsewhere) - all are actions, procedures or policies which undermine Flight Attendant's efforts to remain compliant. These "root cause" issues which could contribute to FAOM non-compliance, should be reported into OSAP. The company has an obligation to support Flight Attendants in their efforts. Similarly, Flight Attendants have an obligation to maintain up-to-date FAOMs. OSAP should not be used if the non-compliance is due to a Flight Attendant's failure to fulfill this obligation, or personal circumstances which have contributed to the Flight Attendant not fulfilling this obligation. Reports of these nature, particularly if the Flight Attendant is involved in the disciplinary process, give the appearance of using OSAP as a "Get out of Jail Free" attempt, rather than an honest attempt to provide valuable safety information to the company and the FAA.
OSAP is a valuable tool for identifying safety hazards and risks, which also provides benefits to Flight Attendants in the form of safer working conditions, and under appropriate circumstances, protective provisions from company or FAA actions. It is important to maintain the integrity of our OSAP program by continuing to identify safety hazards, and filing OSAP reports for those qualifying events, as based on the criteria mentioned in Part 1 and also in our FAOM.
If you have any questions or comments regarding the OSAP program, please contact your local AFA Safety, Health & Security Committee for further information.
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OSAP Reports Integrated With NASA Reporting System
Not only does your OSAP report help to identify safety concerns at United, it also helps identify safety concerns industry wide. Part of our OSAP program, and something that AFA was a strong proponent of, includes automatic reporting to the NASA Aviation Safety Reporting System (ASRS). ASRS is a part of the government’s effort to maintain and improve aviation safety, and functions much like OSAP except it serves the entire aviation industry, and not just one carrier or department. ASRS collects aviation safety incident reports nationwide from aviation employees, and acts on the information these reports contain by identifying industry wide deficiencies, and issues alerting messages to persons in a position to correct them. The database is a public repository, which serves the FAA's and NASA's needs and those of other organizations worldwide that are engaged in research and the promotion of safe flight.
Incident reports are read and analyzed by ASRS's aviation safety analysts. The analyst staff is composed entirely of experienced pilots and air traffic controllers. They have experience with air carriers, military, and general aviation, as well as Air Traffic Control. Each report received by the ASRS is read by a minimum of two analysts, who identify hazards that are discussed in reports and flag that information for action. When hazards are identified, an alerting message is issued to the appropriate FAA office or aviation authority. Analysts' also classify reports and diagnose the causes underlying each reported event. Their observations, and the original de-identified report, are then incorporated into the ASRS's database.
When an OSAP report is submitted, the report is automatically sent electronically to ASRS, where it also reviewed and becomes a part of their database. The identifying strip is then removed and sent to the Flight Attendant reporter. In addition, a copy of the ASRS Callback newsletter, a letter explaining ASRS, and other material are also enclosed in the mailing. No further action is necessary by the Flight Attendant.
OSAP has been running almost a eight (8) years now, and has been successful at identifying several safety issues at United, providing protections from discipline and FAA enforcement action for all employees involved in inadvertent safety violations. If you have questions about the program, please contact your local safety committee.
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