The FAA Academy’s Regulatory Standards Division (AMA-200) recently implemented a new process to measure and communicate the quality of training curricula taught at the Aeronautical Center. The Curriculum Risk Assessment (CRA) system leverages Quality Management Systems (QMS) tools to identify, measure, and record potential issues among a wide range of aviation safety-related courses that are delivered via AMA-200 personnel at the FAA Academy.
In the dynamic field of aviation safety oversight, there is a continuous flow of changes among policies, guidance, and regulations. This steady flow of revisions requires continuous amendments to the training materials used in Flight Standards Service (AFS) courses. When such revisions are not made into the curricula in a timely manner, the content of the courses drifts away from the original course design. This is referred to as “Practical Drift” [see Figure 1] causing an increased risk to course materials over time. Through the CRA system, course managers assigned to oversee the training delivery, can document the need for changes, and communicate the status of each course to the sponsoring organizations.
The value of having a CRA system is best demonstrated by an example:
Regulations regarding the operation of Small Unmanned Aircraft Systems (SUAS) were recently changed. Failure to incorporate these changes into relevant FAA course materials that are delivered to Aviation Safety Inspectors (ASIs) would certainly decrease safety in the National Airspace System. A suitable risk statement for this example is: If ASIs are not properly trained on the new regulations, SUAS operators may be authorized to engage in activities that are contrary to the regulations. Using safety risk assessment techniques, the “Likelihood” of this occurring is determined to be “Probable.” The “Severity” of a SUAS operating in the National Airspace System outside of the regulatory requirements is deemed “Hazardous.” Once the Likelihood and Severity are assessed, a consistent measurement of the level of risk associated with the course materials can be made using a Risk Assessment Matrix [Figure 2].
Using the Risk Assessment Matrix, the risk rating for this example is determined to be “Red”, which is unacceptably high. In the interest of safety, the course material cannot be delivered unless some form of mitigation is in place to reduce the risk to an acceptable level. A suitable mitigation strategy would be to supplement the course materials with the current regulations. This action ensures that the ASIs understand the new regulations, while effectively reducing the likelihood of risk from “Probable” to “Extremely Remote.” Greatly reducing the risk level allows the course to be taught with confidence and utmost safety until the content can be appropriately revised.
Using the CRA process, members of the FAA Academy can consistently and accurately measure the risk of each course conducted by AMA-200, and implement mitigations that are equally consistent and measurable. Additionally, the CRA provides an understandable form of communication regarding the accuracy and relevancy of course materials to senior FAA management, policy offices, and other stakeholders.
Mr. Carl Hayes, Procedures and Standards Program Manager, AMA-200, managed the development and implementation of this innovative process. When asked to describe the CRA system and explain how it helps to improve safety, Carl says, “this multi-faceted approach ensures that the data is accurate, and when issues are identified, an appropriate response is generated to ensure that a collaborative solution is obtained. This proactive approach is designed to resolve issues permanently, as opposed to applying short term corrections.” Carl went on to say “FAA Academy Course Managers and Instructors play a vital role in identifying, analyzing and documenting the risks for their courses. The CRA gathers a wide range of data concerning the operational health of each course into one primary location. This allows AMA-200 management to make informed decisions concerning the conduct of the courses. Once a course is identified as being high risk, it undergoes a robust internal review process which includes a Risk Assessment Review Board. If the Board confirms that an unacceptable risk exists, the AMA-200 division manager approves the CRA, and it is transmitted via formal communication to the respective technical sponsor for disposition.”
The new CRA process fully supports the AFS Core competencies of Interdependency, Critical Thinking, and Consistency. Through Interdependency, the CRA system allows for a formal communication across organizational Lines of Business (LOBs), drawing on the expertise of FAA personnel in the best positions to make informed, collaborative decisions. Critical Thinking is supported by a combination of QMS and Safety Risk Management (SRM) procedures that support data driven safety actions. Consistency is ensured because a well-defined system is used to identify and document issues and then determine a clearly defined response action.
The FAA Academy’s AMA-200 staff is fully committed to providing the finest training possible to the Flight Standards Service workforce. Through innovative programs such as the CRA system, this organization is leveraging the talent of its people to fully support the FAA mission.
