During the 1990s reinventing government movement, there was a proliferation of voluntary programs across government as President Clinton and Vice President Gore streamlined the regulatory enforcement process while also encouraging agencies to maximize voluntary compliance by business (Balleisen 2010). Voluntary programs remain widespread in government today, as regulatory agencies have come to embrace programs that see firms as active participants in their own governance while firms view voluntary programs as an efficient and flexible way to govern themselves and apply industry best practices (Short and Toffel 2010).
To gain access to this valuable safety information, the FAA has developed a suite of voluntary safety reporting programs that offer a regulatory incentive to both air carriers and employees who voluntarily submit incident reports to the agency. The agency uses this data to proactively target its oversight of air carriers and operators while also identifying systemic areas of safety concern across the country. The three main voluntary programs operated by the FAA that gather this data are the Aviation Safety Reporting System (ASRS), the Voluntary Disclosure Reporting Program (VDRP), and the Aviation Safety Action Program (ASAP). Each of these programs has important differences in the way it is structured, how it is implemented, why it was created, and the type of data it collects that lead to a variety of outputs and challenges. The proliferation of these programs may be a direct result of increasing reluctance to release proprietary information because of fear of litigation.
- As a new industry or risk area is identified, there is a period of proliferation of rules and enforcement action to change behavior. Over time, the regulatory agency produces more and more rules to constrain new behaviors. As the regulated entities adapt and compliance levels rise, public and governmental attention will wane. When this regulatory equilibrium sets in, resources for regulatory oversight typically remains flat or diminishes while at the same time the regulated industry becomes more complex. This period leads to an information asymmetry between the regulator and industry. The next stage in this cycle is when the regulatory agency, faced with waning support elsewhere, turns to the entity it is regulating for support.
- While ASRS received almost 49,000 reports from members of the aviation community in 2009, the program faces several challenges:
- Perception as a General Aviation Program: Several in the aviation community have questioned the continued need of ASRS with some calling the program a “general aviation reporting system” (Air Carrier Interview 5/13/2010).vi
- Lack of Awareness of ASRS Outputs: Interviewees within the FAA and air carriers noted that they had never seen a report or Alert Bulletin produced by ASRS despite regular publications of same. The proliferation of ASAPs within individual carriers and employee groups has greatly diminished the reliance on ASRS protection and outputs.
- Competition with other FAA Programs: As more and more carriers enter into agreements to share their proprietary safety data with government-industry collaborative such as ASIAS, ASRS faces increasing perception of the program as a redundant expenditure.
- With increasing amounts of information, “Silver’s dilemma” becomes increasingly dominant. It states that the “signal-to-noise-ratio” falls, rather than increases as the sources and volume of information grows. More data is a mixed blessing: risks arise as information growth outpaces the ability of individuals and groups to process it.