Memo From AMFA-SWA ASAP ERC Representatives

April 27, 2016

Southwest Airlines recently issued a memorandum covering the Voluntary Disclosure Reporting Program (VDRP). This is a program by which Southwest can self-disclose noncompliance issues to the FAA.

The use of the VDRP only protects the Company. The Aviation Safety Action Program (ASAP) is for the employee to self-disclose their part in a noncompliance event.

There are strict timelines for the VDRP that the Company must adhere to. When a noncompliance issue is discovered, it should be reported to Southwest as instructed in the memorandum, followed by the employee making a call to the ASAP hotline, followed by filing an ASAP report. In doing this, both the Company (via VDRP) and the employee (via ASAP) have protection from civil penalty under the respective program.

This letter was re-issued because there were some issues that we dealt with the normal Southwest "just handling it" approach. These issues were discovered by the FAA and had not been reported through the VDRP process. In handling matters this way, while we thought we were doing "what’s best," it leaves us open for fines and penalties. In these cases, had Regulatory Affairs been notified and the VDRP process been able to function we would have been able to avoid the consequences.

The basic differences between the programs were discussed in a memo that was sent out on August 17, 2015, through Tech Ops News; a copy of that memo is attached for reposting on the station union boards.

Sincerely,

Larry Dildine -Primary AMFA–SWA ASAP Representative

John "Pepper" Atkinson  -Alternate AMFA–SWA ASAP Representative

Pdf file here

Please keep in mind that the Voluntary Disclosure Reporting Program (VDRP) does not replace the Aviation Safety Action Program (ASAP) when it comes to reporting noncompliance.

??The VDRP is intended for the air carrier to voluntarily disclose a potential noncompliance to the FAA, regardless of the reason for the noncompliance.

The ASAP is intended for the Employee to voluntary disclose a potential FAR violation, as well as any general Safety concern.

??Both programs support Safety and compliance for both the Employee and the Company.

??Timelines for reporting must be followed as outlined by the respective Advisory Circulars

(ASAP is AC 120-66; VDRP is AC 00-58).

Remember, only ASAP provides the Employee the benefit of avoiding FAA enforcement action (including certificate action) and Company disciplinary action. When you notify your Leader of a potential noncompliance, please consider following up with an ASAP report regardless of whether the event results in a VDRP.

ASAP Event Review Committee (ERC)

Pdf file here