Aviation Safety: Better Guidance and Training Needed on Providing
Files on Pilots' Background Information (30-AUG-02, GAO-02-722).
The Pilot Records Improvement Act, enacted on October 9, 1996,
responded to seven fatal commercial air carrier accidents that
were attributed, in part, to errors by pilots who had been hired
without background checks. The act, which took effect on February
6, 1997, requires air carriers, before making final hiring
decisions, to obtain information for the past 5 years on a pilot
applicant's performance, qualifications, and training from the
Department of Transportation's Federal Aviation Administration
(FAA), employers, and the National Driver Register (NDR). The act
also includes provisions to protect pilots' rights. FAA oversees
compliance with the act and has broad responsibility for
overseeing aviation safety. According to GAO's analyses of FAA
and NDR databases and carriers' responses to GAO's surveys,
compliance with the act has generally increased since it went
into effect, but compliance is not always complete or timely. The
available data are not adequate to determine industrywide
compliance. According to their responses to GAO's surveys,
carriers are not always aware of the act's requirements for
protecting pilots' rights. FAA has taken limited steps to
oversee compliance with PRIA. Under the act and its broad
responsibility for aviation safety, FAA can issue implementing
regulations, develop guidance, conduct inspections to monitor
carriers' compliance, and initiate enforcement actions when it
finds evidence of noncompliance. FAA has not issued regulations
because it regards the act as self-implementing and believes that
its regulatory resources should be reserved for higher agency
priorities. Although FAA provided guidance for carriers, it was
slow to update the guidance after the act was amended. Although
they generally found records useful in making hiring decisions,
carriers were divided in their opinions on whether the records
were worth the cost. However, both groups of carriers found
information from other sources, such as the job interview, the
carrier's flight evaluation of the pilot, and the results of the
carrier's training program, more helpful.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-02-722
ACCNO: A04702
TITLE: Aviation Safety: Better Guidance and Training Needed on
Providing Files on Pilots' Background Information
DATE: 08/30/2002
SUBJECT: Aircraft accidents
Aircraft pilots
Airline personnel
Civilian personnel records
Commercial aviation
Hiring policies
Noncompliance
Transportation safety
NHTSA National Driver Register
******************************************************************
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GAO-02-722
A
Report to the Chairman and Ranking Democratic Member, Subcommittee on
Aviation, Committee on Transportation and Infrastructure, House of
Representatives
August 2002 AVIATION SAFETY Better Guidance and Training Needed on
Providing Files on Pilots* Background Information
GAO- 02- 722
Letter 1 Executive Summary 2
Purpose 2 Background 2 Results in Brief 3 Principal Findings 5
Recommendations for Executive Action 8 Agency Comments 8
Chapter 1 9
Introduction PRIA Requires Air Carriers to Conduct Background Checks on
Pilot Job Applicants 11
PRIA Requires FAA to Provide Periodic Reports and Three Studies 14
Congress Amended PRIA Twice 15 Objectives, Scope, and Methodology 17
Chapter 2 21
Actions to Comply with Required Requests for Pilot Records Increased, but
Available Data
Are Not Adequate to Determine the Extent of Compliance 21 Background Check
Hiring Carriers Requested the Most Records from FAA and Made the
Requirements Are Fewest Requests to Other Carriers 27 Increasing, but
Carriers Said They Generally Receive Records on Time from FAA and NDR but
Still Have Some Problems Obtaining Records from
Compliance Is Not Other Carriers 32
Always Complete or Timely
Chapter 3 38
Air Carriers Have Not Some Carriers Said They Are Unaware of PRIA*s
Requirements for
Protecting Pilots* Rights 38 Consistently Followed Some PRIA Files
Contained Inappropriate Information That Should PRIA*s Requirements
Have Been Excluded 41 for Protecting Pilots* The Opportunity for Pilots to
Correct Their Records May Come Too
Late 43 Rights
Chapter 4 47
FAA Oversight of PRIA FAA Has Specific Responsibilities under PRIA as Well
as Broad Responsibility for Aviation Safety 47
Implementation Has FAA Has Developed Guidance on PRIA 48
Been Limited Several Factors May Hamper FAA*s Operations Inspection
Ability to
Monitor Compliance with PRIA 53 Conclusions 55 Recommendations for
Executive Action 57 Agency Comments 57
Chapter 5 58
Most Carriers Found Carriers Generally Found PRIA Records Helpful in
Making Hiring
Decisions but Less Helpful than Information from Other PRIA Records
Helpful Sources 58 but Were Divided on Carriers Differed on Whether PRIA
Is Worth the Cost 65 Whether They Were
Most Carriers Favored Changes That Would Make Additional Information
Available under PRIA 67 Worth the Cost Appendixes
Appendix I: Fatal Aviation Accidents That Involved Pilots with Prior
Safety Problems Were Cited in Passing PRIA Legislation 71
Appendix II: Methodology 73 Mail Surveys of Carriers 73 Database Analyses
78 Pilot Interviews 81
Appendix III: Survey of Part 121s: Pilot Records Improvement Act 82
Appendix IV: Survey of Part 135s: Pilot Records Improvement Act 101
Appendix V: Chart on Items Needing Clarification by FAA 121
Appendix VI: Overview of FAA Form 8060- 11 122
Appendix VII: Air Carriers* Costs to Comply with PRIA in 2000 125
Appendix VIII: GAO Contacts and Staff Acknowledgments 126 GAO Contacts 126
Staff Acknowledgments 126
Tables Table 1: Information Air Carriers Must Request and Review under
PRIA 11
Table 2: Aviation Operators with Active Part 121 and/ or Part 135
Certificates as of April 13, 2001 13 Table 3: Key Changes to PRIA from
Amendments 16 Table 4: Carriers That Made at Least One Request to FAA for
Pilot
Background Records, July 1998 through April 2001 24 Table 5: Requests for
FAA Records and NDR Driver Information
Records, 1997 through 2001 28 Table 6: Records Releasable under PRIA and
FOIA from PRIA*s
Implementation on February 6, 1997, through January 11, 2002 68 Table 7:
Percentage of Carriers That Supported Including
Additional FAA Information in Response to PRIA Requests 69 Table 8:
Confidence Limits for the Percentage Estimates for Question 22 75
Table 9: Confidence Limits for the Percentage Estimates for Question 6 75
Table 10: Confidence Limits for the Percentage Estimates for
Question 9 76 Table 11: Confidence Limits for the Percentage Estimates for
Question 21 76 Table 12: Summary of Survey Returns for Carriers That Made
PRIA
Requests to FAA 78 Table 13: Databases Used in GAO Analyses 79
Figures Figure 1: Carriers* Requests to FAA for PRIA Background Checks on
Pilots, February 1997 through December 2001 23
Figure 2: Carriers* and Pilots* Requests for Information on Pilots* NDR
Information, February 1997 through December 2001 26 Figure 3: Number of
Reported Requests for Pilot Records Received by Part 121 Carriers and
Sampled Part 135 Carriers, 1997
through 2000 27 Figure 4: Percentage of Carriers That Reported Requesting
PRIA Records in 2000 31
Figure 5: Percentage of Carriers Reporting the Receipt of PRIA Records in
2000 36 Figure 6: Part 121 Carriers* Reported Awareness of Seven of PRIA*s
Requirements for Carriers When Hiring Pilots 39
Figure 7: Part 121 Carriers* Reported Awareness of PRIA*s Requirements for
Carriers Responding to PRIA Requests 40
Figure 8: Percentage of Part 121 Carriers That Identified a Great or Very
Great Need for Clarification of How to Proceed in Certain Situations 49
Figure 9: Views of Part 121 Carriers on the Helpfulness of PRIA
Information in Making Hiring Decisions 59 Figure 10: Views of Sampled Part
135 Carriers on the Helpfulness of PRIA Information in Making Hiring
Decisions 60 Figure 11: Extent to Which Part 121 Carriers Reported That
PRIA Records Were a Factor in Decisions Not to Hire a Pilot 62 Figure 12:
Views of Part 121 Carriers and Sampled Part 135 Carriers on the
Helpfulness of PRIA Records in Making Hiring Decisions 63
Figure 13: Views of Part 121 Carriers and Sampled Part 135 Carriers on the
Helpfulness of Non- PRIA Information in Making Hiring Decisions 64
Abbreviations
AOPA Aircraft Owners and Pilots Association ATOS Air Transportation
Oversight System CFR Code of Federal Regulations
DOT Department of Transportation FAA Federal Aviation Administration FOIA
Freedom of Information Act NDR National Driver Register NTSB National
Transportation Safety Board PRIA Pilot Records Improvement Act
Executive Summary Purpose The Pilot Records Improvement Act (PRIA),
enacted on October 9, 1996,
responded to seven fatal commercial air carrier accidents that were
attributed, in part, to errors by pilots who had been hired without
background checks. Subsequent reviews of these pilots* records revealed
prior safety violations or training problems. PRIA, which took effect on
February 6, 1997, requires air carriers (carriers), before making final
hiring decisions, to obtain information for the past 5 years on a pilot
applicant*s performance, qualifications, and training from the Department
of Transportation*s Federal Aviation Administration (FAA), employers
(often other carriers), and the National Driver Register (NDR). 1 The act
also includes provisions to protect pilots* rights. FAA oversees
compliance with the act and has broad responsibility for overseeing
aviation safety.
Interested in how effective PRIA has been, the Chairman and Ranking
Democratic Member of the Subcommittee on Aviation, House Committee on
Transportation and Infrastructure, asked GAO to determine (1) whether
hiring carriers have complied with the act by requesting pilots* records
from FAA, NDR, and other carriers and whether these records were provided
in a timely manner; (2) whether carriers, NDR, and FAA have complied with
the act*s requirements for protecting pilots* rights; (3) what FAA has
done to oversee compliance with the act; and (4) whether carriers believe
the act has been helpful to them in making pilot- hiring decisions
and is worth the cost. Background PRIA applies to the vast majority of U.
S. commercial air carriers that transport paying passengers or cargo.
These include carriers operating
interstate (1) under Part 121 of the Code of Federal Regulations, using
largely jet aircraft with more than nine passenger seats, and (2) under
Part 135, using primarily other types of aircraft with nine or fewer
seats. A few carriers have dual certificates to operate under both Part
121 and Part 135.
To accomplish its objectives, in part, GAO conducted two nationwide,
anonymous mail surveys of Part 121 and Part 135 carriers that had made at
least one request to FAA for information under the act. This population
included 124, or 86 percent, of the 144 carriers that operate under Part
121 or have dual operating certificates and 1, 144, or 39 percent, of the
2, 915
1 NDR is maintained by the National Highway Traffic Safety Administration,
which is within the Department of Transportation.
Part 135 carriers that had made at least one request to FAA for
information. GAO mailed surveys to all 124 Part 121 or dual- certificate
carriers and to a random sample of 350 Part 135 carriers. While the
responses of the Part 121 carriers are representative of all such
carriers, the responses of the Part 135 carriers are, subject to sampling
error, representative of those Part 135
carriers that made at least one request to FAA but may not be
representative of all Part 135 carriers. Results in Brief According to
GAO*s analyses of FAA and NDR databases and carriers* responses to GAO*s
surveys, compliance with the act has generally increased since it went
into effect, but compliance is not always complete or timely. The
available data are not adequate to determine industrywide compliance.
Nevertheless, hiring carriers have increasingly requested and
received pilot records from FAA, NDR, and other carriers, as required, and
the agencies and other carriers have increasingly provided the required
records within 30 days, as required. FAA, in particular, has accelerated
its response time by developing a centralized database that enables the
agency to generate up- to- date pilot records within minutes. However,
hiring carriers have requested widely varying numbers of records from FAA,
NDR, and other carriers, even though they are generally required to
request records from all three sources for each pilot hired. Specifically,
GAO*s database analyses show that hiring carriers requested about 30,000
more records from FAA than from NDR from 1997 through 2001. During the
same period, according to the survey responses, hiring carriers requested
thousands fewer records from other carriers than from either agency. These
large discrepancies in the number of requests indicate some degree of
noncompliance* an indication consistent with data gathered by FAA
inspectors at GAO*s request, which show that hundreds of pilots were hired
by Part 135 carriers that either requested no pilot records from FAA or
requested records for fewer pilots than they hired. Additionally, a few
carriers responding to GAO*s surveys self- reported noncompliance,
indicating that they had requested records from all three required sources
for half or fewer of the pilots they hired. Finally, hiring carriers
reported receiving pilot records less often from other carriers than from
FAA and NDR and, in a few cases, reported never receiving the records.
According to the hiring carriers, other carriers were also less likely
than FAA and NDR to provide the records on time. Delays in providing the
records can be costly for both carriers and pilots because, although a
hiring carrier is allowed to make a conditional offer to a pilot and begin
training the pilot
before receiving the required records, the carrier is not allowed to make
a
final hiring decision and use the pilot to fly passengers or cargo until
the records have been received.
According to their responses to GAO*s surveys, carriers are not always
aware of PRIA*s requirements for protecting pilots* rights. For example,
many carriers said they were unaware of requirements for notifying pilots
of requests for their records and for giving them opportunities to review
their records and to submit written comments to correct any inaccuracies
before final hiring decisions are made. Pilots also lacked awareness that
they could request copies of their records from current as well as former
employers, according to officials from the Airline Owners and Pilots
Association and several pilots that GAO interviewed. Additionally, carrier
officials and pilots told GAO that some files contain records that, under
the act, should be excluded to protect pilots* rights. In reviewing a
limited number of PRIA files, GAO identified some inappropriate records,
including ones that were more than 5 years old, were unrelated to a
pilot*s
performance as a pilot or a driver, or reported disciplinary actions that
had been overturned. Removing inappropriate records or correcting
inaccuracies is problematic because, although PRIA allows a pilot to
review the records maintained by a current or former employer, the act
does not establish procedures for removing any inappropriate records or
correcting any inaccuracies, and it does not provide for the pilot to
submit comments to correct any inaccuracies until the records have been
sent to the hiring carrier* too late to prevent the carrier from seeing
any potentially damaging information. FAA has taken limited steps to
oversee compliance with PRIA. Under the
act and its broad responsibility for aviation safety, FAA can issue
implementing regulations, develop guidance, conduct inspections to monitor
carriers* compliance, and initiate enforcement actions when it finds
evidence of noncompliance. FAA has not issued regulations because
it regards the act as self- implementing and believes that its regulatory
resources should be reserved for higher agency priorities. Although FAA
provided guidance for carriers, it was slow to update the guidance after
the act was amended. In addition, FAA e- mailed information on PRIA to its
own staff, but it has not included this information in its training for
inspectors or revised its inspection handbooks to include the act*s
requirements. Without information on the act in their training and
inspection handbooks, FAA inspectors are not prepared or prompted to
review carriers* compliance with the act. FAA*s ability to oversee
compliance with the act is also limited, since the act does not require
carriers to retain the records FAA needs to monitor and enforce
compliance. This report contains recommendations
designed to strengthen FAA*s ability to oversee compliance with the act.
FAA officials agreed with these recommendations.
While generally finding PRIA records useful in making hiring decisions,
carriers were divided in their opinions on whether the records were worth
the cost. Nearly three- quarters of the Part 121 carriers and about
threefifths of the Part 135 carriers that GAO surveyed found PRIA records
helpful. However, both groups of carriers found information from other
sources, such as the job interview, the carrier*s flight evaluation of the
pilot, and the results of the carrier*s training program, more helpful.
About half of the Part 121 carriers and about one- third of the Part 135
carriers considered
the PRIA information they received in 2000 worth the cost. Principal
Findings Actions to Comply with
From PRIA*s implementation in 1997 through 2001, carriers requested PRIA
Background Check records from FAA, NDR, and other carriers for thousands
of pilots. The
Requirements Are number of requests generally increased each year until
2001, when the Increasing, but Compliance economic recession and September
11 terrorist attacks depressed the demand for air travel and slowed pilot
hiring.
Is Not Always Complete or Timely Although the available data are not
adequate to determine overall compliance rates, carriers made varying
numbers of requests for records to FAA, NDR, and other carriers. According
to FAA and NDR data, carriers
requested thousands more records from FAA than from NDR each year from
1997 through 2001. In addition, carriers responding to GAO*s surveys
reported receiving thousands fewer requests each year than FAA and NDR
reported. Some carriers also reported requesting fewer records from other
carriers than from FAA or NDR.
According to industry representatives and carrier hiring officials, most
carriers received PRIA records from FAA and NDR, and carriers generally
reported receiving these records on time. Although FAA initially had
difficulty providing the records within 30 days, its Aviation Data Systems
Branch consolidated three separate databases in 1998, and the agency is
now generally able to generate a response letter for a carrier within
minutes. Hiring carriers reported receiving records from other carriers
less frequently, and a few said they never received the records. Hiring
carriers also reported more delays in receiving records from other
carriers. Without
complete PRIA information, carriers are not allowed to use pilots to fly
passengers or cargo, and delays in receiving records can be costly to both
carriers and pilots.
Carriers Reportedly Were Carriers varied considerably in their awareness
of PRIA*s requirements for Not Always Aware of and protecting pilots*
rights, according to their responses to GAO*s surveys. In Did Not Always
Follow general, their responses indicated more awareness of requirements
that are PRIA*s Requirements for
applicable when hiring than of requirements that are applicable when
responding to requests from other carriers. Hiring carriers were least
often Protecting Pilots* Rights
aware that they must give pilot applicants an opportunity to submit
written comments to correct any inaccuracies in their PRIA records before
making final hiring decisions, and responding carriers were least often
aware that they must allow current or former pilot employees to review
their records
within 30 days of making a written request. According to carrier
officials, pilots, and GAO*s review of a limited number of PRIA files,
pilot records sometimes include outdated or inappropriate information,
such as records of overturned disciplinary actions. If pilots are aware
that PRIA gives them the right to review the records maintained by a
current or former employer and if they exercise that right, they can
determine whether any of the information in their records is inappropriate
or inaccurate, and they may be able to persuade the employer to remove or
correct the information. However, PRIA does not establish procedures for
removing inappropriate or inaccurate information, and it does not give
pilots an opportunity to submit written comments to correct any
inaccuracies until after the records have been sent to the hiring carrier*
too late to prevent the carrier from receiving information that may
jeopardize the pilot*s chances of being hired. Several carrier officials
told GAO that they did not know how to remove records that they believed
were unfair. Finally, when carriers and pilots disagree over PRIA records,
there are no procedures for resolving their differences.
FAA Has Provided Limited To promote compliance with PRIA, FAA issued an
advisory circular for
Oversight of Compliance carriers in May 1997, but it did not revise the
circular until September 2001,
with PRIA even though the law was amended in December 1997 and April 2000.
In addition, the revised circular includes a sample form that requires
pilots to waive two provisions of the law designed to protect pilots*
rights and
inappropriately shifts the responsibility for notifying the pilot of a
request for records from the responding carrier to the hiring carrier.
These changes are not in conformance with the act.
Although FAA has e- mailed guidance on PRIA to its own staff, it has not
yet incorporated this guidance into its training classes for inspectors or
into the handbooks that they use to monitor carriers. FAA inspectors have
reported few violations of PRIA, and the agency has opened 10 enforcement
cases against carriers, 7 of which resulted in warning letters or were
closed with no action. This level of inspection and enforcement activity
seems low compared with the indications of potential noncompliance that
GAO identified during its review. Without information about PRIA in their
training classes or inspection handbooks, FAA inspectors have no reminders
to check for compliance with the act. Although FAA maintains that it
monitors carriers* processes and procedures for complying with the law,
FAA cannot determine whether carriers follow these processes and
procedures unless it performs at least some spot checks. FAA*s ability to
enforce PRIA is also hampered by the
absence of a requirement for carriers to maintain copies of the PRIA
records they receive for pilots they hire.
Carriers Generally Found The majority of both the Part 121 and Part 135
carriers responding to GAO*s
PRIA Helpful, but Were surveys reported that PRIA records were helpful in
making hiring Divided on Whether It Is decisions. In their view, FAA
information on enforcement actions closed Worth the Cost
during the past 5 years was most helpful, and FAA*s verification of the
pilot*s medical record and the pilot*s NDR information were least helpful.
The carriers also indicated that information from other sources, such as
the job interview, the carrier*s flight evaluation of the pilot, or the
results of the carrier*s training program, was more helpful than PRIA
information. The total costs of implementing PRIA, most of which are borne
by carriers,
are difficult to estimate, primarily because they often are not tracked
separately from other costs. For 2000, the Part 121 carriers estimated
spending $7,000, on average, to implement the act, while the Part 135
carriers estimated spending $1, 000, on average. About half of the Part
121 carriers and about one- third of the Part 135 carriers believed their
PRIA costs for 2000 were justified by the usefulness of the information
received. The remaining carriers did not believe their PRIA costs were
justified.
Recommendations for GAO recommends that the Secretary of Transportation
direct the FAA
Executive Action Administrator to develop guidance for carriers on the
information that is to be included in and excluded from PRIA files; have
carriers put in place a
system that will allow the carriers and FAA to check compliance with all
PRIA requirements, especially whether required pilot background checks
have been completed for pilots hired; revise the sample form for hiring
carriers to conform with the act*s provisions; post information on pilots*
rights under the act on FAA*s Web site; and incorporate information on
PRIA into the training classes and inspection handbooks for FAA
inspectors. Agency Comments We provided the Department of Transportation
with a copy of our draft report for review and comment. In our draft
report, we recommended that FAA develop a regulation requiring that
carriers maintain records of background checks on the pilots they hire for
as long as the pilots remain
in their employ. FAA agreed that carriers need to maintain these records
so that it can monitor and enforce their compliance with the law, but it
proposed a change in its administrative guidance rather than a regulation
to achieve this goal. We agreed that such a change could accomplish the
intent of our initial recommendation and revised the recommendation
accordingly. FAA concurred with all other recommendations in our draft
report.
Chapt er 1
Introduction Between 1987 and 1994, errors by pilots whose backgrounds had
not been checked prior to hiring were identified as contributing factors
in seven crashes of scheduled carriers involving 111 fatalities. The
National Transportation Safety Board (NTSB), which investigated these
crashes, found that each of the pilots involved had been hired despite a
poor
performance history, prior safety violations, or both. In each case, NTSB
reported, the carrier had lacked access to, or had failed to obtain, the
pilot*s records with previous employers before hiring. Accordingly, on
four separate occasions between September 1988 and October 1995, NTSB
recommended that carriers obtain information from the Federal Aviation
Administration (FAA) and previous employers on a pilot*s training,
performance, and safety history before hiring. 2 NTSB later also
recommended that information about the pilot*s driving record be checked
with the National Driver Register (NDR). 3 In June 1988, we likewise
recommended, after surveying carriers* pilot- hiring practices, that FAA
encourage carriers to review a pilot*s safety history before making a
hiring decision. 4 On October 9, 1996, Congress enacted the Pilot Records
Improvement Act (PRIA) to help ensure that fatal crashes would not again
occur because, in part, carriers had not investigated the backgrounds of
the pilots they hired. 5 The act, which took effect on February 6, 1997,
requires that air carriers conduct background checks on all pilot
applicants. The vast majority of commercial carriers carrying paying
passengers or transporting cargo are classified as air carriers because
these carriers meet specific statutory requirements that are discussed in
more detail later in this chapter. These carriers are, therefore, subject
to the act. Besides requiring that carriers obtain key records from FAA,
past or current employers for whom the
applicant worked as a pilot, and NDR, PRIA includes provisions to protect
pilots* rights and to protect those furnishing records from liability for
providing the information. 2 See appendix I for a list of NTSB reports
that recommended pilot background checks following four crashes. 3 NDR is
maintained by the National Highway Traffic Safety Administration, which is
part of the Department of Transportation. 4 U. S. General Accounting
Office, Aviation Safety: Air Carriers Should Check Pilot Applicants*
Safety History, GAO/ RCED- 88- 154 (Washington, D. C.: June 7, 1988). 5
None of NTSB*s reports on commercial airplane crashes from January 1995
through July 2001 cite inadequate background checks on pilots as a
contributing factor.
PRIA also gives FAA responsibility for overseeing compliance with the act,
by stating that FAA may prescribe regulations as necessary to ensure
compliance with the requesting and receiving of pilot records, protect the
personal privacy of anyone whose records are requested as well as the
confidentiality of those records, and preclude further dissemination of
those records by the person requesting them. Furthermore, as the agency
responsible for aviation safety, FAA has a broader responsibility to
promote the safe flight of civil aircraft in air commerce by prescribing
regulations and minimum standards for the aviation industry. 6 To carry
out this responsibility, FAA issues regulations and develops guidance. FAA
also
performs inspections to ensure compliance with federal statutes and
regulations and has the authority to take enforcement actions against
violators. Specifically, FAA regulates and monitors the safety of air
transportation and air commerce through its safety programs, which
provide the initial certification, periodic surveillance, and inspection
of airlines, airports, repair stations, and other aviation entities,
including pilots. These inspections are intended to primarily detect
actual violations of statutes or regulations. When safety inspectors
identify violations, FAA guidance requires that such violations be
investigated, appropriately addressed, and reported.
The Chairman and Ranking Democratic Member of the Subcommittee on
Aviation, House Committee on Transportation and Infrastructure, asked us
to review the status of PRIA since its enactment in October 1996.
Specifically, they asked us to determine the following:
whether (1) hiring air carriers have complied with the act by requesting
and receiving key documents about pilot applicants before making final
hiring decisions and (2) FAA, NDR, and other carriers have complied with
the act by providing these documents in a timely manner;
whether air carriers are aware of PRIA*s requirements for protecting
pilots* rights;
what FAA has done to oversee compliance with the act; and
whether air carriers believe PRIA has been helpful to them in making
pilot- hiring decisions and is worth the cost.
6 49 U. S. C. 44701.
Until recently, pilot hiring was expected to keep pace over the next
decade with projected growth in air traffic and anticipated pilot
retirements. With the economic downturn in 2001 and the September 11,
2001, terrorist attacks, however, the demand for air travel declined. As a
result of the September 11 attacks, concerns about aviation safety and
security are
likely to remain central, and pilot background checks, such as those
required by PRIA, may assume even greater importance.
PRIA Requires Air PRIA requires that air carriers conduct background
checks on a pilot job Carriers to Conduct
applicant. Specifically, PRIA requires them to request, from FAA, previous
air carrier and other employers, and NDR, and review information about
Background Checks on the applicant*s qualifications, performance, and
training over the past 5 Pilot Job Applicants
years. This information is to be provided within 30 days, and a reasonable
fee may be charged to the requesting carrier for the service. Table 1
identifies the information required from each source.
Table 1: Information Air Carriers Must Request and Review under PRIA
Source Pilot information required
FAA Certificate( s), medical certificate, aircraft type ratings with any
limitations, and a summary of any legal enforcement action resulting in a
violation that was not subsequently overturned. a
Air carriers and other previous Records related to employment; training,
qualifications, proficiency, or professional competency employers
(including comments and evaluations by a check airman); b any disciplinary
actions (that have not
been overturned); any release from employment; and any other records
related to the individual*s performance as a pilot that are maintained by
the employer, except records pertaining to flight time, duty time, or rest
time. NDR c Driver identification information from states for probable
matches with a pilot whose license has been revoked, suspended, canceled,
or denied or who has been convicted of certain serious traffic- related
violations, such as driving while impaired by alcohol or other drugs.
Carriers are to then contact the state( s) involved for detailed violation
information and to ensure that the information is for the pilot. a FAA
maintains this information in three databases: (1) the Comprehensive
Airmen Information System contains information on all FAA- certificated
pilots and can be used to verify a pilot*s certificate and type rating,
thereby verifying a pilot*s qualification for flying a specific type of
aircraft; (2) the Civil Aerospace Medical Institute*s database contains
information about the class of medical certificate held by the pilot, the
date of issuance, and any limitations or restrictions that are based on a
medical condition; and (3) the Enforcement Information System contains
information on FAA*s enforcement proceedings against a pilot, including
warnings, certificate actions, and monetary penalties.
b Regulations require that a pilot*s flying skills be tested during
periodic *check rides* either by an FAA inspector or by a carrier*s
designated representative, called a check airman. c Carriers usually
obtain driver identification information from the chief driver- licensing
official of a state. NDR is maintained by the National Highway Traffic
Safety Administration within the Department of
Transportation. Source: GAO presentation of information from FAA and NDR.
PRIA Applies to Air Carriers PRIA*s definition of an air carrier is based
on several statutes. An air carrier subject to PRIA is operated by a U.
S. citizen 7 who directly or indirectly provides air transportation;
provides interstate air transportation* that is, transports passengers
or property across state lines by aircraft as a common carrier for
compensation, or transports mail by aircraft; and
operates as a common carrier* that is, advertises to the public to carry
persons, property, or mail for hire. To operate as an air carrier, a
carrier must have an air carrier certificate issued by FAA under Part 119
of Title 14 of the Code of Federal Regulations (CFR). FAA issues a number
of operating certificates under various parts of
the CFR. FAA may require an aviation operator to have several of these
certificates, depending on the number of passengers carried, the weight of
the aircraft, and whether the aircraft is used to fly out of state or
carry mail. For example, Part 121 certificates are generally issued to
major carriers who operate turbojet- powered airplanes or airplanes with
more than nine passenger seats, excluding crew members* seats, or
airplanes having a payload capacity of more than 7, 500 pounds. Part 135
certificates are generally issued to small carriers operating other than
turbojet- powered airplanes having no more than nine passenger seats and a
payload capacity of 7,500 pounds or less. The criteria for issuing
certificates under Parts 121
and 135 have changed since the late 1980s and early 1990s, when the seven
fatal accidents that led to PRIA*s enactment occurred. At that time, all
seven carriers operated under Part 135 certificates; however, under the
7 The term *U. S. citizen* refers in this context to a person,
partnership, or corporation.
new criteria, all of these carriers would operate under Part 121
certificates. 8 As of April 13, 2001, FAA had identified 3,059 operators
with active certificates to operate under Parts 121 and 135 or with dual
certificates to operate under both. The vast majority of these operators
are air carriers
and thus are subject to PRIA. (See table 2.)
Table 2: Aviation Operators with Active Part 121 and/ or Part 135
Certificates as of April 13, 2001
Certificate Number of operators
Par t 121 117 Par t 135 2,915 Part 121/ 135 a 27
Tot al 3,059
a These operators have dual certificates to operate under both Parts 121
and 135 of the Federal Aviation Regulations. Source: FAA analysis of data
in the Flight Standards Operations Specifications database.
PRIA Includes Provisions to PRIA includes several provisions to protect
the privacy of a pilot*s records Protect Pilots* Rights
during the hiring process and indicates how a pilot can obtain and comment
on the records contained in PRIA files. First, PRIA specifies that,
generally, only information covering a 5- year period preceding the date
of the employment application or the date of the request is to be
forwarded to the hiring air carrier. Second, to help ensure that a pilot*s
records are not requested without permission, a carrier must obtain the
pilot*s written consent before requesting the release of records from FAA,
NDR, and
8 In 1996, FAA issued a final rule requiring that commuter operations
conducted in airplanes with 10 to 30 passenger seats be conducted under
Part 121 of title 14 of the CFR. Previously, scheduled passenger- carrying
operations in airplanes with over 30 seats or a payload capacity of more
than 7,500 pounds were conducted under Part 121, and operations in
airplanes with 30 or fewer seats and a payload capacity of 7, 500 pounds
or less were conducted under Part 135. Part 121, which provides the safety
requirements for all major air carriers, was generally considered to have
more restrictive requirements than Part 135. This change in the criteria
was in response to several Part 135 commuter accidents that had occurred
in previous years and the need to bring most passenger operations under
one level
of safety.
current or former employers. PRIA also includes provisions to protect air
carriers from liability for providing a pilot*s records and requires that
they not provide records without first ensuring that the pilot*s consent
has been obtained. Finally, PRIA limits access to a pilot*s records to
those individuals directly involved in the hiring process and restricts
the use of those records
to assessing the pilot*s qualifications as part of making a hiring
decision. To further protect a pilot*s privacy, a carrier must protect the
confidentiality of these records. PRIA also provides a pilot with access
to his/ her PRIA records. Whenever a
request is received, a carrier, employer, or agency has 20 days to notify
the pilot of the request and of the pilot*s right to receive a copy of the
PRIA file. If requested in writing by a pilot, a copy of the PRIA file
must be provided within 30 days of the pilot*s request. Under PRIA, a
pilot has the right to
submit written comments to correct inaccuracies in the records before a
final hiring decision is made. To further protect the rights of pilots
under PRIA, FAA may prescribe such regulations as may be necessary to
protect the personal privacy of any pilots whose records are requested,
preclude the further dissemination of records received, and ensure prompt
compliance with requests for PRIA records. PRIA Requires FAA to PRIA
required FAA to provide a written report to Congress on the act*s Provide
Periodic
implementation 18 months after the act was passed and at least once every
3 years thereafter on proposed changes to FAA*s records, carriers*
records, Reports and Three
and other employers* records. If FAA does not recommend changes to Studies
PRIA, the act also requires the agency to give reasons for its position.
FAA provided Congress with two reports that were issued in October 2000
and April 2002. Neither report recommends any change to (1) the agency*s
current system of collecting and maintaining certificate records on airmen
or on legal enforcement actions and (2) air carrier and other records
required to be furnished under PRIA. FAA did not recommend any change
because it thought that the existing records and system were effective and
met PRIA*s requirements.
PRIA also required FAA to conduct three studies related to carriers*
procedures for hiring pilots* two jointly with representatives of the
aviation industry. The three studies that FAA transmitted to Congress 9
recommended additional research on, rather than changes to, carriers*
pilot- hiring practices, but FAA has not yet begun any of the recommended
research. According to officials in the Air Transportation Division, FAA
has not pursued any of the proposed research because it has not yet heard
whether Congress agrees with the studies* findings.
Congress Amended To clarify some of PRIA*s requirements and to lessen the
act*s burden on PRIA Twice
smaller carriers, Congress passed amendments in December 1997 and April
2000 that narrowed and clarified PRIA*s scope and provided some relief in
areas that had proven burdensome to some carriers. The April 2000
amendment also directed FAA to carry out certain actions related to PRIA.
Table 3 summarizes the major changes resulting from these amendments.
9 Federal Aviation Administration, Report to Congress: Pilot Pay- for-
Training Study (Washington, D. C.: February 1998); Report to Congress:
Pilot Minimum Flight Time Requirements Study (Washington, D. C.: March
1998); and Report to Congress: Air Carrier Pilot Pre- Employment Screening
Standards and Study Criteria (Washington, D. C.: March 2000).
Table 3: Key Changes to PRIA from Amendments Amendments Date Key changes
P. L. 105- 142 12/ 05/ 1997 Changed the timing of when carriers must
request and receive PRIA information from before hiring the pilot to
before allowing the pilot to begin service.
Narrowed the requirement for background checks from all previous
employers to just those who had employed the individual as a pilot of a
civilian or public aircraft.
Established that carriers must maintain their own training and other
records on pilots at least 5 years to bring that requirement in accordance
with the time frame during which PRIA records may be requested.
Specified that copies of records be provided to pilots no later than 30
days following the receipt of a written request.
Allowed an exception to the requirement for obtaining background
information when the former employer no longer exists, as long as the
carrier can document a good- faith attempt to obtain such information.
Permitted some small operators, before receiving requested records, to
allow a pilot to begin transporting passengers for a period of 90 days if
the pilot would be flying nonscheduled operations. a P. L. 106- 181 4/ 5/
2000 Excluded the U. S. Armed Forces, the National Guard, or a reserve
component of the U. S. Armed Forces from the sources from which a carrier
must request and obtain a pilot*s flight records. Limited the types of
records to be provided to those pertaining to an individual*s competency
and performance as a pilot.
Expanded the good- faith exception to allow carriers to begin using
pilots whose records are sought from a foreign government or entity.
Directed FAA to provide carriers with electronic access to FAA records
to make access to background information on pilots more efficient and
timely and to develop regulations as necessary to protect the pilots*
privacy.
a This exception applies to operators of aircraft with a payload capacity
of 7,500 pounds or less, or of helicopters, on flights that are not
scheduled operations. Source: GAO summary of PRIA amendments.
The December 1997 amendment made a key change that allows a carrier to
request and review a PRIA file after hiring an applicant as long as the
carrier completes the background check before allowing the pilot to fly an
aircraft with passengers or cargo. Initially, the act required all
carriers to request and review a pilot*s records from FAA, NDR, and
previous employers before hiring the pilot. This requirement caused delays
in hiring decisions because, at the time of the amendment*s enactment, FAA
and
some carriers could not meet the 30- day deadline. As a result, Congress
amended the act to permit a carrier to perform these background checks
after the pilot was hired as long as they were completed before the
carrier used the pilot to fly passengers or cargo* a step often referred
to as the final hiring decision. In essence, this amendment gives carriers
the option to use PRIA information not as part of a pilot*s initial
screening process but as a last check before the pilot is put into the
cockpit.
Objectives, Scope, and To meet our objectives, we gathered quantitative
and qualitative Methodology
information from a variety of sources for the period from PRIA*s
implementation in February 1997 through July 2002. Our primary method for
addressing the four objectives was two nationwide, anonymous mail surveys*
one for Part 121 carriers and one for Part 135 carriers. Carriers with
dual certificates, that is, authorized to operate under both Part 121 and
Part 135, received the Part 121 survey, and we include the responses of
these carriers with the Part 121 responses throughout this report. The
surveys, conducted from June through September 2001, provided data on the
carriers*
compliance with the act, including the timeliness with which they
received records from FAA, NDR, and other carriers;
use of information to hire pilots;
costs incurred because of the act*s requirements;
awareness of actions to protect pilots* rights;
views on PRIA*s usefulness;
opinions on which aspects of PRIA require more clarification or
guidance; and
recommendations for improving PRIA. The survey population included the
Part 121 and Part 135 air carriers that had made at least one request to
FAA for PRIA information from July 1998, when FAA began tracking such
requests electronically, through April 30, 2001. This population includes
124, or 86 percent, of the 144 carriers that operate under Part 121 or
have dual certificates to operate under both Parts
121 and 135. All 124 of these carriers received the survey. However, the
survey population covers only 1,144, or 39 percent, of the 2,915 Part 135
carriers. Of these 1,144 carriers, we randomly selected 350 to receive the
survey. Although we would have preferred to survey a representative sample
of all Part 135 carriers, we were unable to do so in a manner that would
produce reliable data because we were unable to identify and
pretest carriers that were out of compliance with the requirement to
request documents from FAA. Thus, we cannot discuss the opinions and
experiences of the 1,771 Part 135 carriers that did not submit requests to
FAA for PRIA information. The surveys requested historical data from
PRIA*s implementation in February 1997 through December 2000 for those
questions to which carriers said during pretesting that they could provide
more complete information. Where this was not the case, we requested that
carriers provide data for calendar year 2000 to offer the most current and
reliable perspective on carriers* compliance with the act. We did not
verify the information provided in our surveys. (See app. II for a more
detailed discussion of our methodology.) 10
Besides analyzing our survey responses, we used other methods to address
the first objective on the extent to which carriers have complied with the
act by obtaining key documents about pilot applicants before making final
hiring decisions and whether FAA, NDR, and carriers have provided these
documents in a timely manner. Specifically, we interviewed carrier
officials who were responsible for requesting and reviewing PRIA
information as part of their hiring decisions. We also analyzed FAA and
NDR data on carriers* PRIA requests. We performed limited internal testing
of the database that FAA uses to respond to PRIA requests, but we did not
independently review the validity of the data it derives from three other
FAA databases. We also did not independently review the validity of the
NDR database that states use to provide information to carriers about
pilots* driving records. To obtain further information on compliance with
PRIA by Part 135 carriers, FAA, at our request, asked its principal 10
Data results from our surveys of Part 121 and Part 135 carriers are
reported differently for the body of our report and for the two survey
appendixes (see apps. III and IV). Survey results cited in this report may
combine several individual questionnaire categories. For
example, in asking about the degree that some non- PRIA information helped
carriers make pilot- hiring decisions, we report percentages that are
based on responses ranging from *very
helpful* or *moderately helpful* to *not very helpful.* Categories such as
*other,* *uncertain,* and *did not do this* and missing responses are not
included in these percentage calculations for the body of this report.
This approach presents in the body the views of carriers that expressed an
opinion on each question. In the survey appendixes, we do include these
categories in the data reported, when they are present, in order to report
the complete range of information generated. Their inclusion can cause a
difference in the percentage calculations for those questions affected in
the survey appendixes, as compared with the percentages for the same
questions in the body of this report. Throughout this
report, we include data on Part 121 carriers* responses to our surveys. If
Part 135 carriers* responses were within the sampling error (plus or minus
7 percentage points for most survey questions), we note that the responses
were similar and do not report them separately.
operations inspectors 11 in April 2001 for information on which Part 135
carriers should have made requests to FAA for PRIA records in calendar
year 2000. Specifically, FAA asked these inspectors to determine how many
pilots each of these Part 135 carriers had hired that year and how many of
the carriers operated only intrastate and thus might be exempt from PRIA*s
requirements. FAA received information on about 842 of the 2,915 Part 135
carriers in operation, 798 of which were interstate carriers subject to
PRIA. We analyzed the information about hiring and certification to
operate interstate operations and compared it with requests for PRIA
information
made to FAA by these same carriers in 2000 to determine whether these 798
carriers had requested information from FAA for at least as many pilots as
they had hired.
To help determine our second objective of whether FAA, NDR, and carriers
were aware of PRIA*s requirements to protect pilots* rights, we also
interviewed officials from these two federal agencies, carrier hiring
officials, aviation associations, representatives of a major pilot union,
and private aviation attorneys to understand how well PRIA has been
working, including the effectiveness of measures to protect pilots*
rights. To understand pilots* views of PRIA, we interviewed a sample of 20
pilots at hiring fairs and carriers. We also interviewed and reviewed the
PRIA files of
27 pilots whom we identified as having reported experiencing problems with
their PRIA records because they had contacted FAA, congressional staff, or
our office.
To determine our third objective of what FAA has done to oversee
compliance with PRIA, we reviewed the agency*s policies, guidance, and
internal documents about implementation as well as the reports and studies
to Congress that FAA generated in response to the act. We also interviewed
program officials at the Department of Transportation (DOT), FAA
headquarters, and FAA field offices responsible for responding to PRIA
requests from carriers, generating the data needed for these
responses, and overseeing the program*s implementation. We also reviewed
enforcement cases initiated by FAA against carriers that had violated
PRIA*s requirements. 11 Principal operations inspectors lead teams of FAA
inspectors that conduct inspections of such items as pilots* certification
and performance, flight crews* training, and in- flight record keeping.
To address our fourth objective on the extent to which carriers believe
the act has helped them make better pilot- hiring decisions, we surveyed
Part 121 and Part 135 carriers, as previously stated. We also interviewed
officials
from aviation associations, representatives from a major pilot union, and
private aviation attorneys to understand the impact of PRIA on making
better pilot- hiring decisions. In addition, to obtain information on the
act*s
costs to FAA, NDR, carriers, and pilots, we reviewed FAA*s submissions on
costs to the Office of Management and Budget, which are required under the
Paperwork Reduction Act. We discussed the costs of PRIA with officials
from all of these organizations as well as with officials from state
motor vehicle agencies that process the vast majority of carriers* PRIA
requests for pilots* NDR information.
We conducted our work from August 2000 through July 2002 in accordance
with generally accepted government auditing standards.
Actions to Comply with Background Check Requirements Are Increasing, but
Compliance
Chapt er 2
Is Not Always Complete or Timely Efforts to comply with PRIA have
increased since the act took effect in February 1997, but compliance is
not always complete or timely. Although available data are not adequate to
determine the extent of industrywide compliance, our analyses indicate
that hiring carriers have requested and agencies and other carriers have
provided background checks on increasing numbers of pilots. However, our
analyses also suggest greater compliance with some PRIA requirements than
with others. Both FAA and NDR databases and carriers* responses to our
surveys indicate that hiring carriers requested the required records more
often from FAA than from NDR, even though the carriers are required to
request records from both organizations for all prospective pilots. The
survey responses further indicate that hiring carriers requested the
required records still less frequently from other carriers. In general,
the hiring carriers reported
receiving the requested records on time more frequently from FAA and NDR
than from other carriers. Delays in receiving these records can negatively
affect both pilots and carriers.
Required Requests for As discussed in chapter 1, PRIA, as amended,
requires hiring carriers to
Pilot Records request and review information for the past 5 years on a
pilot applicant*s
qualifications, performance, and training. This information is to be
Increased, but
obtained from FAA, NDR, and carriers and other employers, apart from the
Available Data Are Not
military, who employed the applicant to fly passengers or cargo. While FAA
Adequate to Determine and NDR maintain data on the requests for PRIA
records that they receive,
there are no centralized data on requests between carriers. the Extent of
Compliance
According to our analyses of FAA and NDR databases and carriers* responses
to our surveys, the number of requests for background checks increased
steadily from 1997 through 2000. However, requests did fall in 2001,
reflecting the downturn in air traffic resulting from the economic
recession and the terrorist attacks of September 11. Although this
generally steady growth in the number of requests suggests increasing
compliance with PRIA*s requirements for requesting records, we could not
assess carriers* compliance because data are not available on how many and
which pilots were hired each year by each carrier that is subject to PRIA
and whether each subject carrier requested records from all three required
sources for each pilot hired. When we began our review, FAA did not know
which carriers were subject to PRIA, but following discussions with us,
FAA agreed to analyze its Operations Specification database to make
this determination. 12 Information regarding carriers* requests for
records from the three required sources is not available because federal
laws and regulations do not require that carriers report it to FAA or that
FAA maintain it. FAA does not believe that the costs of gathering and
maintaining these data would be worth the benefits to aviation safety.
Requests for FAA According to FAA data, the number of requests for
background checks
Background Checks nearly doubled from 14, 938 in 1997 to 27,104 in 2000.
With the recession
Increased and the terrorist attacks, the number dropped to 21, 047 in
2001. From
February 1997, when PRIA was implemented, through December 2001, carriers
requested background checks on 111, 552 pilots from FAA. (See fig. 1.) The
required records include a pilot applicant*s flight certificate, medical
certificate, and enforcement history. 12 Specifically, FAA determined that
all 138 carriers with Part 121 or dual operating certificates and 2,550
Part 135 carriers are subject to PRIA because they are authorized to
conduct interstate operations and therefore fit the act*s definition of an
*air carrier.* Furthermore, according to FAA*s analysis, only a handful of
the remaining Part 135 carriers carry mail and are also subject to the
act.
Figure 1: Carriers* Requests to FAA for PRIA Background Checks on Pilots,
February 1997 through December 2001
Source: GAO analysis of FAA data.
Although the number of requests to FAA for background checks increased,
not all carriers requested records. According to our analysis of FAA*s
records, fewer than half of the 3,059 carriers in operation as of April
13, 2001, requested PRIA background checks from FAA on at least one pilot
from July 1998, when FAA began tracking PRIA requests by carrier, 13
through April 2001. Without data on how many pilots were hired or on how
many carriers hired at least one pilot during the period of our review, we
could not determine how many carriers should have requested records.
13 Although FAA maintains data on the number of PRIA requests it has
received since the act*s implementation in February 1997, the agency did
not begin automated tracking of requests by carrier until July 1998.
Consequently, we were not able to determine how many carriers made PRIA
requests during the first 16 months of the program or whether the
requesting carriers were Part 121 or Part 135 carriers.
In addition, the Part 135 carriers were less likely than the Part 121
carriers to request records. According to our analysis of the available
automated data for July 1998 through April 2001, 39 percent of the Part
135 carriers requested PRIA records from FAA at least once, compared with
86 percent of the Part 121 carriers. (See table 4.) Again, data were not
available to determine whether or to what extent the lower percentage for
Part 135
carriers was related to compliance. On the one hand, information provided
by FAA indicated that over 900 Part 135 carriers have only one pilot,
making it unlikely, FAA officials said, that they hired any pilots during
this period. Furthermore, 4 percent of the Part 135 carriers we surveyed*
all of whom had made at least one request to FAA for PRIA records*
reported
that they did not hire any pilots from 1997 through 2000. On the other
hand, as discussed later in this chapter, we found evidence of Part 135
carriers that hired pilots but may not have complied fully with PRIA*s
background check requirements.
Table 4: Carriers That Made at Least One Request to FAA for Pilot
Background Records, July 1998 through April 2001
Number in Number that made at Type of certificate operation least one
request Percentage
Par t 121 a 144 124 86 Part 135 2, 915 1,144 39
Total 3, 059 1, 268 41
a For survey purposes, the responses of carriers that hold dual
certificates as Part 121/ 135 carriers are combined with the responses of
Part 121 carriers. As of April 13, 2001, there were 27 Part 121/ 135
carriers in operation and 117 Part 121 carriers. We deleted 5 Part 121
carriers because they subsequently went out of business and were not
available to respond to the survey. Source: GAO analysis of FAA data.
Requests for NDR The number of requests for NDR driver information
records, 14 primarily Information Increased
from carriers but occasionally from pilots, 15 also increased, although
NDR data, like FAA data, show a drop in 2001 in response to the recession
and the September 11 terrorist attacks. Specifically, the number of
requests increased from 9, 549 in 1997 to 23,104 in 2000, but dropped to
18,175 in 2001. (See fig. 2.) According to NDR data, carriers and pilots
made 81, 509 requests for driver information from PRIA*s implementation
through
December 2001. The NDR information required for PRIA purposes includes
records of revocations or suspensions of a driver's license for such
serious offenses as reckless driving, driving while intoxicated, or drug
convictions.
14 Throughout this report, we use the term *NDR information* to refer to
NDR driver information records provided in response to PRIA requests, both
by NDR and by state motor vehicle agencies, which largely assumed this
responsibility in 1998. 15 Although carriers are required to receive NDR
information from NDR or a state motor vehicle agency, carriers sometimes
ask pilot applicants to request the information. If the
pilots identify themselves in their requests to NDR as pilots or specify
that they are requesting the NDR information for PRIA purposes, NDR
includes their requests in its PRIA database. Furthermore, indicating that
the request is for NDR information ensures that the information provided
includes records of convictions or suspensions in all 50 states, not just
those in the state that supplies the information.
Figure 2: Carriers* and Pilots* Requests for Information on Pilots* NDR
Information, February 1997 through December 2001
Source: GAO analysis of NDR data.
Carriers Reported Increased The carriers we surveyed reported receiving
increased numbers of requests Requests for Pilot Records
for pilot records from hiring carriers for each year from PRIA*s
implementation through 2000, the last year covered by our survey. These
requested records include information about a pilot*s training and
performance as well as the results of drug and alcohol testing. For the
period from 1997 through 2000, the Part 121 carriers reported that the
number of requests received nearly tripled, and the Part 135 carriers
reported that the number of requests nearly doubled. (See fig. 3.) The
number of Part 121 carriers that reported receiving such requests rose
from 67 in 1997 to 91 in 2000, and we estimate that the number of Part 135
carriers receiving such requests increased from 461 to 931 during this
period.
Figure 3: Number of Reported Requests for Pilot Records Received by Part
121 Carriers and Sampled Part 135 Carriers, 1997 through 2000
Note 1: As discussed in chapter 1 and appendix II, we surveyed only those
carriers that made at least one request to FAA for pilot background
checks. Note 2: Numbers of records are reported for those carriers that
said they had requested PRIA records for all or almost all pilots they
hired. Source: GAO analysis of survey data from Part 121 carriers and Part
135 carriers that had made at least one request to FAA for pilot
background checks.
Hiring Carriers Under PRIA, carriers that hire pilots should make the same
number of
Requested the Most requests to FAA and NDR, and they may be required to
make more or fewer requests to other carriers, depending on how many
employers their pilot Records from FAA and
applicants had in the preceding 5 years and whether records are required
Made the Fewest
from those employers. According to our analysis of data from FAA and
Requests to Other
NDR and from our surveys of carriers, FAA received thousands more requests
for records than NDR and carriers, and both FAA and NDR
Carriers received thousands more requests than carriers.
Requests for FAA Records According to FAA and NDR data, from 1997 through
2001, carriers Far Exceeded Requests for requested records for about
30,000 more pilots from FAA than from NDR,
NDR Information and in each of those years, carriers made thousands more
requests to FAA
than to NDR. (See table 5.)
Table 5: Requests for FAA Records and NDR Driver Information Records, 1997
through 2001 Requests to FAA
Requests for NDR information by Year by carriers a carriers and pilots b
Difference
1997 14, 938 9,549 5, 389 1998 23, 584 13,333 10, 251 1999 24, 879 17,220
7, 659 2000 27, 104 23,104 4, 000 2001 21, 047 18,175 2, 872
Total 111, 552 81,509 30, 043
a Yearly totals are based on the number of notification letters to pilots
whose PRIA records were sent to carriers by FAA. b Yearly totals include
requests for NDR information by carriers to state motor vehicle agencies,
by carriers directly to NDR, and by pilots directly to NDR under the
Privacy Act when pilots indicated that they were requesting this
information as required by PRIA. Source: GAO analysis of FAA and NDR data
on PRIA requests.
Although disparities of this magnitude would seem to indicate some degree
of noncompliance with the requirement to request driver information from
NDR, FAA and NDR data cannot readily be compared. First, NDR does not
track its data by carrier or by pilot, as FAA does. Therefore, the two
agencies* data cannot be matched to verify that a carrier has requested
background checks on a pilot from both federal agencies. Second, NDR data
are, to some extent, understated, partly because NDR cannot always
identify requests from pilots for NDR information as PRIA requests and
partly because NDR did not include known PRIA requests made by pilots
under the Privacy Act in its PRIA database until 1999. 16 Although
requests from carriers for NDR information are readily identifiable as
PRIA
requests, carriers sometimes delegate their responsibility for obtaining
16 Under the Privacy Act, an individual may make a written, notarized
request directly to NDR for a file search to determine whether NDR has
provided the individual*s driver information records to a third party.
NDR information to pilot applicants, even though PRIA requires that a
carrier receive the records directly from NDR or the state agency. Pilots*
requests for NDR information* whether made directly to NDR under the
Privacy Act or to state motor vehicle agencies* are not identifiable as
PRIA requests unless the pilots specify as much. From 1999, when NDR began
tracking pilots* requests separately from other Privacy Act requests,
through 2001, pilots made 1,187 (2 percent) of 58, 627 requests to NDR for
background checks under PRIA.
Carriers* delegation of their responsibility for obtaining NDR information
to pilot applicants raises issues beyond how to account accurately for the
number of PRIA requests made for NDR information. First, PRIA directs
carriers to obtain the NDR information on each pilot with the pilot*s
consent. Although PRIA allows carriers to have a pilot applicant request
that either NDR or a state motor vehicle agency provide the NDR
information directly to the carrier, PRIA does not allow the pilot to
obtain the information and then provide it to the carrier. This practice,
which gives
the pilot custody of the information, potentially compromises the
reliability of the information. According to NDR officials, at least one
major Part 121 carrier requires pilot applicants to obtain NDR information
under the Privacy Act and bring it with them to an interview* a procedure
that violates PRIA. Reported Requests to Other The carriers responding to
our surveys reported receiving substantially
Carriers Fell Short of fewer requests for background checks each year than
did FAA and NDR.
Requests to FAA and NDR, From 1997 through 2000, the last year covered by
our surveys, the carriers but Records from Some reported receiving about
44, 000 requests, compared with about 91, 000 requests to FAA and about
63, 000 requests to NDR. Again, disparities of this Carriers Are Not
Required
magnitude would seem to indicate some degree of noncompliance, but our
analysis also identified other possible reasons for differences. First,
carriers estimated the number of requests they received each year, whereas
FAA and NDR tracked their requests electronically. Second, as previously
explained, our survey covered only those carriers that had made at least
one request to FAA for pilot records. Some carriers might have requested
records from other carriers or NDR, but not from FAA. Finally, under PRIA,
as amended, carriers do not need to request records from the military,
from employers for whom pilot applicants worked in jobs unrelated to
flying, or from certain types of aviation operators. Eighty- eight percent
of the Part 121 carriers and 46 percent of the Part 135 carriers we
surveyed reported
hiring at least some pilots with military flight experience in 2000. In
addition, many smaller Part 135 carriers may hire pilots whose recent
experience includes working for an aviation operator that is not required
to maintain the kinds of information on training and performance included
in PRIA records, such as a private flight school or an operator that
provides agricultural crop dusting, banner towing, travel by corporate
jet, or aerial surveying. Furthermore, PRIA requires only that carriers
make a *goodfaith*
attempt to obtain records from foreign employers or bankrupt carriers.
Even though there are several reasons why carriers may have reported
receiving fewer requests than FAA and NDR received, carriers* survey
responses pointed to greater noncompliance with the requirement to request
records from other carriers or employers than with the requirements to
request records from FAA or NDR. For example, 57 percent of the Part 121
carriers reported requesting records from other carriers for all or almost
all pilots they hired in 2000, compared with 97 percent for FAA and 95
percent for NDR. Similar percentages of the Part 135 carriers we surveyed
reported requesting records from each of the
three sources. (See fig. 4.)
Figure 4: Percentage of Carriers That Reported Requesting PRIA Records in
2000
Note 1: As discussed in chapter 1 and appendix II, we surveyed only those
carriers that had made at least one request to FAA for pilot background
checks. Note 2: Percentages for other carriers reflect those carriers that
reported requesting PRIA records for all or almost all of the pilots they
hired.
Source: GAO analysis of survey data from Part 121 and Part 135 carriers
that had requested at least one PRIA record from FAA.
Additional Evidence Two types of evidence we gathered suggest that some
carriers, especially Suggests That Recent
some Part 135 carriers, may not have complied fully with requirements to
Compliance by Some complete background checks on pilots they hired in
2000. First, our Carriers Is Not Complete analysis of hiring data gathered
by FAA inspectors showed that hundreds of pilots were hired by Part 135
carriers that either had not requested PRIA records from FAA or had
requested records for fewer pilots than they had hired. To better
understand why many Part 135 carriers had not requested
records, we asked FAA to have its inspectors determine how many pilots
were hired in 2000 by Part 135 carriers that operate interstate and
therefore are subject to PRIA*s requirements. Data generated by the
inspectors raised questions about the compliance of 227 (28 percent) of
the 798 Part 135
carriers for which the inspectors obtained information. These 227 carriers
had requested records for 318 pilots but had hired 1,078. While the
carriers that hired some of the remaining 760 pilots might have complied
with PRIA
if the pilots were not placed in service in 2000 or if the pilots* records
were requested at the end of 1999 or at the beginning of 2001, it is
unlikely that these circumstances applied to all 760 pilots. According to
FAA, its Office of Flight Standards Service has asked the regions
responsible for overseeing these 227 carriers to review their compliance
with PRIA.
Second, to obtain a snapshot of carriers* compliance with PRIA*s
requirements for obtaining background information, we asked our survey
respondents about the records they requested for pilots hired in 2000. A
few carriers self- reported significant noncompliance with PRIA*s
requirements for requesting records. Of the Part 121 carriers, 1 percent
reported requesting FAA records less than half the time for the pilots
hired in 2000, 3 percent reported requesting NDR information less than
half the
time for the pilots hired, and 6 percent reported requesting other
employers* records for half or fewer of the pilots hired. The percentages
for Part 135 carriers were generally comparable.
Carriers Said They PRIA requires FAA, NDR, and carriers to provide PRIA
records to a hiring Generally Receive carrier within 30 days of receiving
a written request. The act also requires
hiring carriers to receive the records from all three sources for each
pilot Records on Time from
applicant before making a final hiring decision* that is, before using the
FAA and NDR but Still pilot to fly passengers or cargo. Have Some Problems
According to industry representatives and carrier hiring officials we
Obtaining Records surveyed or interviewed, most carriers received PRIA
records from FAA
from Other Carriers and NDR, and, in the majority of instances, they
reported receiving the
records within 30 days, as required. However, in a few cases, carriers
reported never receiving the required records. Furthermore, carriers said
they sometimes needed more time to follow up with state motor vehicle
agencies on the initial NDR information they received. Carriers reported
more problems in receiving records on time from other carriers and, in a
few cases, reported never receiving the required information. Without
complete information, a carrier is not allowed to use a pilot to fly
passengers or cargo, and delays in receiving the required information can
be costly to both the carrier and the pilot.
FAA Has Largely Overcome During the first 6 months after PRIA was
implemented, FAA said it was not Initial Delays in Providing always able
to respond to requests for background checks within 30 days. PRIA Records
to Carriers
FAA said it did not have enough staff to keep up with the volume of
requests it received. In addition, the agency needed to gather the
required records* pilot*s flight certificates, medical certificates, and
enforcement histories* from three separate databases maintained in three
different offices. As a result, FAA*s responses sometimes took months,
delaying carriers* hiring of pilots.
To reduce the delays in responding to requests for records, Congress
amended PRIA and FAA modified its procedures. Noting that delays in
receiving records presented a particular burden to small aviation
businesses, Congress amended PRIA in December 1997 to provide relief to
the on- demand air carriers 17 by allowing them to use pilots to fly
passengers for up to 90 days before receiving their PRIA records. 18 In
the summer of 1997, FAA transferred the responsibility for responding to
PRIA requests from its Civil Aerospace Medical Institute to its Aviation
Data
Systems Branch in the Office of Flight Standards, which had more staff
available to respond to requests. In addition, in July 1998, FAA developed
a centralized database that is automatically updated each night with new
information from the three databases that contain FAA*s flight, medical,
and enforcement records. We observed FAA staff using this database and saw
that they can, within minutes, generate a response letter for a carrier
and a copy for a pilot.
Our review of FAA*s response times for the 27, 104 requests received in
2000 showed that FAA generally provided PRIA information in less than 2
work days after receiving a carrier*s request. According to FAA staff
responsible for responding to PRIA requests, delays can occur if
information such as a pilot*s name or certificate number is incorrect or
illegible. In these instances, the staff said, they usually call the
carrier to obtain the correct information so that they can process the
requests on time. They further noted that some carriers reduce response
times by transmitting requests to
FAA by fax or Express Mail. 17 On- demand carriers include carriers that
operate under Part 135 for compensation, including (1) operations as a
public charter with negotiated time and location of departure, (2)
scheduled operations with limited frequency of operations, and (3) small
all- cargo operations with a payload capacity of 7, 500 pounds or less.
18 Clarifications to the Pilot Records Improvement Act of 1996, H. Rpt.
105- 372, House of Representatives, October 31, 1997.
In responding to our surveys, carriers also indicated that FAA generally
provides records and provides them on time. Ninety percent of the Part 121
carriers reported receiving the required records from FAA for all or
almost all pilots hired in 2000. Of these carriers, 71 percent reported
receiving almost all records on time, and 4 percent reported receiving the
records on time less than half the time. Of the Part 135 carriers we
surveyed, 74 percent reported receiving almost all FAA records on time,
and 12 percent reported receiving these records on time less than half the
time.
Most Carriers Said They Initially, NDR processed carriers* PRIA requests
directly in Washington, Received NDR Information
D. C., because state motor vehicle agencies* computer systems were not yet
on Time, but Following Up set up to handle the requests electronically.
Until December 31, 1997, on Information Can Be Time carriers could submit
PRIA requests directly to NDR for processing.
Beginning in January 1998, state agencies largely assumed this Consuming
and responsibility, and in 2000, the state agencies processed 92 percent
of Burdensome
carriers* 22,201 requests, while NDR processed 8 percent on an emergency
basis. Six states now process over three- quarters of the requests for NDR
information, 19 including most of the requests for residents of four
states and the District of Columbia that do not process any requests
because computer testing has not yet been completed to ensure the
reliability of the NDR search process for those entities.
To gain perspective on recent NDR activity in response to carriers* PRIA
requests, we asked carriers whether they had received the NDR information
they had requested and whether they had received the information within 30
days. Those responding to our surveys generally reported receiving NDR
information from state motor vehicle agencies in response to their
requests. Specifically, 85 percent of the Part 121 carriers reported
receiving NDR information for all or almost all pilots hired in
2000, as did 77 percent of the Part 135 carriers. Smaller percentages of
carriers reported receiving the NDR information on time: 67 percent of the
Part 121 carriers and 69 percent of the Part 135 carriers reported
receiving all or almost all records on time. Furthermore, some carriers
reported problems with timeliness: 4 percent of the Part 121 carriers and
18 percent of the Part 135 carriers reported receiving the records on time
less than half the time.
19 The states are Florida, Hawaii, Ohio, Oklahoma, Texas, and Utah.
If a driver*s license has been revoked or suspended for violations, the
process of following up with the motor vehicle agency in each state where
violations occurred can take much longer, particularly if the NDR
information provided by a state motor vehicle agency does not include
identifiers, such as the driver*s Social Security number, height, weight,
and
eye color. Without such identifying information, the carrier must take
additional steps to determine whether the pilot applicant or someone else
committed the violation. Furthermore, when a state motor vehicle agency
fails to provide the NDR information required under PRIA, a carrier cannot
legally hire a pilot. The good- faith exception that Congress established
for instances when carriers cannot obtain PRIA information from foreign
carriers or from domestic carriers that have gone out of business does not
apply to instances when carriers cannot obtain NDR information.
Smaller Percentages of Over two- thirds of the carriers responding to our
surveys reported Hiring Carriers Reported
receiving the PRIA records required from other carriers for all or almost
all Receiving Records from
pilots hired in 2000, but the percentages that said they received these
Other Carriers Than from
records were smaller than the percentages that said they received the
records required from FAA and NDR. (See fig. 5.) Of the carriers that said
FAA and NDR they did not receive the required records from other carriers
for all or almost all pilots hired in 2000, 2 percent of the Part 121
carriers and 10 percent of the Part 135 carriers reported receiving the
records from other carriers for few or none of the pilots hired.
Figure 5: Percentage of Carriers Reporting the Receipt of PRIA Records in
2000
Source: GAO analysis of survey data from Part 121 and Part 135 carriers
that had requested at least one PRIA record from FAA.
The responses to our surveys also indicated that carriers had more
problems with receiving records on time from other carriers than from FAA
or NDR. The Part 121 carriers reported that they were more likely to
receive records within 30 days, as required, from major, regional, and
commuter carriers than from small cargo or on- demand carriers. The
information on timeliness reported by the Part 135 carriers was similar to
the information reported by the Part 121 carriers, although the Part 135
carriers reported more problems with the timeliness of records from large
cargo carriers than did the Part 121 carriers. Many of the carrier hiring
officials, aviation association officials, and pilots we interviewed
voiced concerns about problems in obtaining PRIA records on time or at all
from other carriers. Several of the carrier officials said they often need
to follow up with additional telephone calls and letters when these
records are not received within 30 days. Of the 400 comments about PRIA
that the Aircraft Owners and Pilots Association (AOPA) has received from
its members since PRIA*s implementation in February 1997, the most common
ones were that past employers did not send the requested records
to the hiring carrier at all or did not send them in a timely fashion and
that no one was enforcing the 30- day mandate. Several of the pilots we
interviewed also maintained that it took months to get current and former
carrier employers to forward PRIA records to prospective employers.
Delays in Providing PRIA Not providing PRIA records to hiring carriers or
providing them late can Records Can Negatively
adversely affect both carriers and pilots. In a few cases, carriers
reported Affect Carriers and Pilots that they never received the required
information. Hiring carriers are not allowed to use pilots to transport
passengers or cargo until all PRIA
records have been obtained and reviewed, except in the on- demand air
charter industry, which allows carriers to use pilots for up to 90 days
while completing background checks. Hiring officials at two carriers told
us they had to let pilots go after providing expensive training. One Part
121 carrier official told us that the carrier had waited over 5 months for
one pilot*s
records. In the interim, the carrier said it put this pilot through 70
days of training and then sent him back for more simulator training, since
it could not use him for transporting passengers or cargo. Until this
matter was settled, the carrier said it paid the pilot a weekly training
salary of $200 instead of a much higher salary as a crew member. The
carrier said it did
not want to release the pilot because he was good and because it had spent
more than $25,000 on his training. Although PRIA*s good- faith exception
covers instances when a hiring carrier cannot obtain records from a
bankrupt or foreign carrier, this exception does not apply when an
operating U. S. carrier fails to provide records.
Not providing a PRIA file or delays in providing it can also cost a pilot
an opportunity for career advancement to a larger carrier. With delays, a
pilot can lose a job offer or receive a lower seniority number, which in
turn limits job security, choice of flights, and pay. For example,
according to one pilot, delays by his former employer in forwarding his
PRIA file postponed his training by 2 months, caused him to receive a less
desirable seniority number, gave him less choice in assignments, and
delayed his promotion to captain by 4 months. He said this delay in
promotion alone cost him nearly $7, 500. See chapter 4 for our analysis of
how FAA could help to improve
compliance with PRIA*s requirements for providing pilot records within 30
days.
Air Carriers Have Not Consistently Followed PRIA*s Requirements for
Protecting Pilots* Chapt er 3
Rights Some carriers indicated that they are not aware of some of PRIA*s
requirements to protect pilots* rights. For example, many carriers said
they were unaware of requirements for notifying pilots and for giving them
opportunities to review and submit corrections to their records. In
addition, state motor vehicle agencies sometimes provided records to
carriers that they should not have provided. As a result, hiring carriers
sometimes received PRIA files that contained information that was outdated
or was not related to an individual*s performance as a pilot. While PRIA
gives pilots an opportunity to submit written comments to correct records
before final hiring decisions are made, this opportunity comes too late to
prevent hiring carriers from seeing inappropriate information that could
potentially jeopardize pilots* chances of being hired.
Some Carriers Said Carriers* reported awareness of PRIA*s requirements for
protecting pilots* They Are Unaware of
rights varied considerably. In general, carriers said they were more aware
of requirements that are applicable when a carrier is hiring than they
were PRIA*s Requirements
of requirements that are applicable when a carrier is responding to a PRIA
for Protecting Pilots* request. Nearly all of the Part 121 hiring carriers
we surveyed said they Rights
were aware of PRIA*s requirements to obtain a pilot*s consent before
seeking records from other carriers, NDR, and FAA and to keep those
records confidential, as shown in figure 6. The carriers were somewhat
less aware of requirements to limit access to those records and to use
them only
during the hiring process. They were least aware of the requirement to
give the pilot an opportunity to correct inaccuracies in the PRIA records
before making a final hiring decision. Specifically, 31 percent of the
Part 121 carriers said they were unaware of the requirement to give the
pilot an
opportunity to correct inaccuracies in the PRIA records before making a
final hiring decision, whereas 44 percent of the Part 135 carriers said
they were unaware of this requirement.
Figure 6: Part 121 Carriers* Reported Awareness of Seven of PRIA*s
Requirements for Carriers When Hiring Pilots
Source: GAO analysis of survey data from Part 121 carriers.
When responding to PRIA requests, as figure 7 shows, 88 percent of the
Part 121 carriers responding to our survey said they were aware of PRIA*s
requirement that, within 30 days of receiving a pilot*s written request,
they provide the pilot with a copy of the PRIA records that they sent to a
prospective employer. However, 80 percent of the Part 121 carriers were
unaware of a requirement that gives a pilot the right to review the PRIA
records kept by a current or former employer at any time. In addition,
about half of the carriers were unaware of two notification requirements
designed to let the pilot know that a prospective employer had requested
his or her records and to give the pilot an opportunity to review those
records for accuracy and completeness. Under these requirements, a
carrier must notify a pilot within 20 days of (1) a prospective employer*s
request for PRIA records and (2) the pilot*s right to request a copy of
the records that were sent. These notification requirements are especially
important if a pilot*s application and signed PRIA consent form have been
on file with a carrier in a pool of possible candidates. The Part 135
carriers that we surveyed indicated similar levels of awareness of these
provisions.
Figure 7: Part 121 Carriers* Reported Awareness of PRIA*s Requirements for
Carriers Responding to PRIA Requests
a This requirement allows a pilot to obtain a copy of the records that the
current or former employer actually sent to the hiring carrier. b In 1997,
Congress amended the law to require former employers, as well as current
employers, to allow a pilot to review PRIA records at any time and to
provide the opportunity to do so within 30 days of a written request.
Source: GAO analysis of survey data from Part 121 carriers.
According to AOPA officials and several of the pilots we interviewed, many
pilots as well as carriers were unaware of the PRIA provisions giving
pilots opportunities to review their records. AOPA found that one of the
most common questions raised by the 400 pilots who inquired about PRIA was
how to obtain copies of their records. Several of the pilots who contacted
us with concerns about their PRIA records also said they were uncertain
about how to obtain copies of their records from their current and former
employers. Some added that they had tried unsuccessfully to obtain their
records.
Some PRIA Files Several of the PRIA files that we reviewed contained
information that Contained
should have been excluded, and carrier officials and pilots we interviewed
also cited examples of inappropriate information in these files. To
protect Inappropriate pilots* rights, PRIA specifies what records should
and should not be
Information That included in pilot files. Although FAA met these criteria
in the records it Should Have Been forwarded, NDR and other carriers did
not consistently follow these
criteria. Excluded
Both carrier officials and pilots we interviewed told us of instances in
which outdated records were included in pilots* files. Officials at a Part
121 carrier explained that deleting older records can be difficult,
especially if the records are part of computerized training reports that
may cover much longer periods of time. How widespread the inclusion of
outdated records in PRIA files may be is unknown; however, this practice
raises concerns because there is no mechanism for a pilot to have them
deleted until after the hiring carrier has seen them.
Outdated driver information may also sometimes be included in pilot files.
According to the chief of NDR*s Driver Register and Traffic Records
Division, a number of states provide a driver*s complete record rather
than limit the information to 5 years. The Vice President of the Aviation
Services Department at AOPA also noted that the inclusion of old driving
information has been a problem with PRIA files. One pilot who contacted us
complained that his driving record still showed a violation from about 20
years earlier for having unopened beer in his car when he was 18. NDR
officials explained that if a pilot requests driver information directly
from
NDR or through a state motor vehicle agency without specifying that the
information is needed for PRIA, the information provided may include
information older than the 5 years required by this law.
Although an amendment to PRIA in April 2000 limits the records to be
provided by a former employer to those directly related to a pilot*s
performance as a pilot, we found limited evidence that at least three
carriers had forwarded unrelated records to hiring carriers. In reviewing
the PRIA files of the 27 pilots who contacted us, we found one file that
contained the pilot*s personal bankruptcy papers. Another file contained
copies of documents from a dispute between the pilot and the carrier about
unemployment compensation. A third file included court records of a
carrier*s suit against a pilot for failing to repay training funds but
excluded the judge*s ruling that the pilot did not have to repay those
funds. These court documents were unrelated to the pilot*s flying
abilities. About 29
percent of the Part 121 carriers we surveyed indicated a great need for
clarification of which records are related to an individual*s performance
as a pilot and thus should be included in the files forwarded to hiring
carriers. The Part 135 carriers we surveyed indicated a similar need for
clarification. Information unrelated to a pilot*s driving record is also
sometimes included in the files NDR and states send to hiring carriers,
according to the Chief of NDR*s Driver Register and Traffic Records
Division. For example, he said that some states have included information
on nonmoving violations, such
as parking tickets, as well as on tax liens, nonpayment of child support,
and unpaid library fines. Such information can appear in PRIA files
because NDR gives the states some flexibility in determining what
information they submit to its computerized registry. NDR requires the
states to submit the names of persons whose driver licenses have been
denied, canceled, revoked, or suspended for cause as well as of those who
have been convicted of certain serious traffic offenses, such as driving
while impaired by alcohol or other drugs. However, NDR also allows the
states to submit information on convictions and withdrawals of licenses
for other offenses.
While NDR limits the information provided in response to a PRIA request to
the most recent 5 years, it does not otherwise screen the information
provided. In contrast, when FAA reviews a pilot*s fitness to hold a
medical certificate to fly, it obtains driver information from NDR that is
screened to include only certain serious moving violations and drug- and
alcoholrelated convictions over a 3- year period. FAA must then obtain
detailed information about the pilot*s driving record from any states
where
violations occurred. Some of the PRIA files we reviewed included records
of disciplinary actions that were subsequently overturned. Although PRIA
requires carriers to include records of disciplinary actions that were not
overturned, carrier officials, aviation attorneys, and one pilot who
contacted us raised
concerns about including records of overturned disciplinary actions. For
example, the file for one pilot showed he was suspended briefly for
departing late, but did not show that his suspension was later overturned
and he was paid in full after providing copies of air traffic control
tapes showing that he had departed on time. But because a copy of the
final
ruling that cleared him was not included in his file, the prospective
employer did not hire him, according to the pilot. This example shows how
any reference in a pilot*s file to a past problem, even a problem that has
been resolved in the pilot*s favor, can be damaging to the pilot*s chances
of being hired.
In another case, one of the pilots who contacted us with concerns about
PRIA said that his current employer had provided inconsistent records to
carriers to which he had applied. Our review of his records sent to a
major carrier indicated that he had tested positive on a required drug or
alcohol test, while his records sent to a small Part 135 carrier indicated
that he had
submitted to and passed all such tests. In such a case, inaccurate
information could potentially cause a carrier to unfairly reject a
competent pilot whose record is clean or to unknowingly hire a pilot who
has tested
positive. One aviation attorney we interviewed also told us that carriers
have provided inconsistent PRIA records for the same pilot to different
hiring carriers.
The Opportunity for Though enacted to keep unsafe pilots from being hired
to fly commercial Pilots to Correct Their
flights, PRIA may have some unintended negative effects. While PRIA allows
pilots to review their records at any time, it does not require that
Records May Come they have an opportunity to submit written comments to
correct their Too Lat e records before a hiring carrier receives their
file. Thus, corrections, if submitted, may come too late to prevent the
hiring carrier from seeing
inaccuracies; information that should not, under PRIA, have been included
in the files; or disputed information presented only from the carrier*s
perspective. The timing of the opportunity to correct records can create
problems for both pilots and carriers. Several of the pilots we
interviewed said that after successfully completing interviews, simulator
testing, or other screening procedures, carriers declined to hire them
because of incorrect records in their PRIA records. Some of these pilots
said they were unaware of the
incorrect information in their PRIA records and had no opportunity to
correct it before the hiring carrier turned them down. The potential costs
to both the pilot and the hiring carrier are even greater if the pilot has
already
accepted a position with the carrier, begun training, and given up a
previous job before the PRIA records are reviewed. Eighty- two percent of
the Part 121 carriers and 73 percent of the Part 135 carriers we surveyed
reported that they do not have the PRIA records to review until after the
pilot has accepted a conditional job offer and/ or begun training. In
addition to the timing of the opportunity to correct records, PRIA does
not indicate, and FAA has provided no guidance on, how to submit
corrections to PRIA records. As a result, even when carrier officials
concur with a pilot and are willing to remove or correct a record, some
said they are unsure whether the act allows them to do so. Several carrier
officials
said they were unsure how to remove records that they believed were
unfair. For example, the president, attorney, and chief pilot for one Part
121 carrier fully concurred with a pilot that the record of a failed check
ride should be removed from the pilot*s file because the training manager
who had administered this and other check rides had subsequently been
fired for being sexist and racist. The carrier consulted with FAA and
aviation attorneys but could not determine whether it could remove the
questionable training record. Instead, the carrier said it included a
cover memorandum explaining why the training manager was fired, affirming
the
pilot*s skills, and describing an emergency evacuation in which the pilot
saved the lives of two other pilots.
Moreover, PRIA does not establish any procedures for arbitrating
disagreements between a pilot and a current or former employer over PRIA
records. Several of the pilots who contacted us described problems they
had experienced in getting explanations or rebuttals to specific records
included in their files. Six of these pilots knew of the incorrect
information but said that they had little success in removing or rebutting
disputed records. PRIA establishes no remedy for wrong or unjust entries
in a pilot*s records or for failing to provide an opportunity for record
correction, if the carrier obtained a release of liability.
According to a law review article, 20 several carrier officials and
private aviation attorneys we interviewed, and some of the pilots who
contacted us with concerns about the law, another unintended consequence
of PRIA is that it can be used in ways that can diminish safety.
Specifically, the weight 20 John J. Nance and Charles David Thompson, *The
Pilot Records Improvement Act of 1996: Unintended Consequences,* Journal
of Air Law and Commerce, Southern Methodist
University School of Law (Summer 2001).
that the act gives to records from current and former employers can be
used as leverage in disputes between pilots and carriers over safety
issues. According to the previously mentioned law review article,
disagreements over *how much safety is enough against the background of
economic competition,* can pit pilots against managers *who also happen to
hold the
trump card of the pilot*s job in their hands.* In these instances, the
article argues that pilots may feel compelled to subordinate their
concerns about safety to their employers* economic interests to avoid
having negative information placed in their PRIA files.
In addition, we found some limited indication that PRIA could be used in
ways that could potentially reduce aviation safety, rather than enhance it
as intended. Several of the pilots who contacted us said they had been
threatened with having negative records placed in their PRIA files if they
did not take actions that violated FAA*s safety regulations. Although we
could not corroborate them, largely because discussing them with the
carriers could have further jeopardized these pilots* careers, we raised
them with FAA because these allegations involve potentially serious safety
issues. For example, one pilot said he was pressured to fly an aircraft
with serious maintenance problems, including an inoperable radar and
autopilot, during bad weather. This pilot and another pilot who flew for
the same carrier also said they had been pressured to identify mechanical
problems informally on post- it notes instead of recording the problems in
the aircraft*s maintenance log, as FAA requires. We provided FAA with
information about the carriers involved that were still in business, but
FAA
was unable to substantiate the allegations, and the carriers denied them.
Finally, according to the previously cited law review article, the
inclusion of negative information in a PRIA file effectively negates the
pilot*s ability to quit and go elsewhere. Several of the pilots who
contacted us said they had been threatened with negative records in their
PRIA files if they did not repay the costs of their training before
leaving. Some carriers require that pilots sign training contracts and
remain with the carriers for a prescribed
period of months or years, after which time the cost of training is
considered paid in full. According to the pilots, these contracts make it
difficult to leave a carrier, especially if the carrier does not prorate
the cost of training, because if a pilot departs early, he or she will owe
all or a disproportionate amount of the total cost. Contract disputes
about training costs were included in several PRIA files that we reviewed.
For example, one pilot earning an annual salary of $15,000 said he quit
after being pressured to commit safety violations. He offered in writing
to repay a prorated portion of the $4,000 remaining on his training
contract, but the
carrier sued him. The judge ruled that the training costs did not have to
be repaid. Although the broken training contract was not related to the
pilot*s professional competence and the carrier lost the case, the carrier
included a record of the lawsuit in the pilot*s file without reference to
the judge*s ruling in the pilot*s favor. See chapter 4 for our analysis of
how FAA could help to improve carriers* awareness of PRIA*s requirements
for protecting pilots* rights and better inform pilots of their options
for obtaining, reviewing, and correcting their records.
FAA Oversight of PRIA Implementation Has
Chapt er 4
Been Limited FAA has taken limited steps to oversee PRIA implementation
and to monitor this program as part of its broader responsibility for
aviation safety. To promote compliance with PRIA, FAA developed some
guidance for carriers and its own staff, but the advisory circular that it
issued for carriers in 1997 was soon outdated. A revised circular, which
FAA produced in September 2001, addressed some of the issues on which
carriers had sought clarification. FAA*s guidance also includes a new form
for carriers that inappropriately (1) requires a pilot applicant to waive
the rights provided by PRIA to be notified about requests and (2) changes
the party PRIA makes responsible for notifying the pilot of a request for
records. Although FAA has periodically provided its own inspectors with
updated information on PRIA, it has not revised its handbooks or training
for operations inspectors to incorporate PRIA*s requirements. To date, few
inspections have identified problems with carriers* implementation of
PRIA, even though FAA*s inspectors at our request identified hundreds of
Part 135 carriers that had hired pilots but did not request PRIA records
from FAA. FAA has seldom initiated enforcement actions against carriers
for PRIA violations. FAA Has Specific
Congress gave FAA exclusive authority to oversee the implementation of
Responsibilities under PRIA by authorizing FAA to issue regulations to (1)
protect the personal privacy of the pilots whose records are disseminated
and the PRIA as Well as Broad
confidentiality of those records, (2) preclude the further dissemination
of Responsibility for PRIA records, and (3) ensure prompt compliance with
any request for Aviation Safety records. Congress gave FAA discretion in
deciding whether to use this authority to issue regulations. To date, FAA
has not used this authority. According to FAA*s Deputy Associate
Administrator for Regulation and
Certification, the agency views PRIA as self- implementing because it
places the responsibility for collecting pilot records on the carriers,
not on the government. In addition, FAA has not issued PRIA regulations
because it has allocated its regulatory resources to other priorities.
In addition to the specific responsibilities given to FAA by PRIA, FAA has
broad oversight responsibility and authority for aviation safety. This
broad responsibility and authority apply to PRIA as well as to other
aviation safety programs. Specifically, in carrying out its mission to
ensure a safe and efficient national air space system, FAA is responsible
for issuing
regulations and developing implementation guidance. FAA also performs
inspections to ensure compliance with federal statutes such as PRIA and
under FAA*s general civil penalty authority in 49 U. S. C. 46301 has the
authority to take enforcement action against violators.
FAA Has Developed FAA issued guidance for carriers in the form of an
advisory circular. FAA
Guidance on PRIA issued this circular in May 1997, 3 months after PRIA
went into effect, and
revised the circular in September 2001. The revised circular incorporates
information on the December 1997 and April 2000 amendments to PRIA, which
Congress enacted, in part, to clarify aspects of the law. For example, the
revised circular includes a copy of the law, as amended; provides sample
forms that hiring carriers may use in requesting pilot records; and
discusses each of the key changes to PRIA made in the 1997 and 2000
amendments. (See table 3.)
Revised Advisory Circular In our survey, which we sent to carriers before
FAA issued its revised Addresses Some Issues on advisory circular, we
asked which aspects of PRIA*s hiring requirements Which Carriers Sought
carriers thought needed further clarification. Hiring carriers we
contacted
Clarification had preliminarily identified 17 key issues that they thought
warranted
further clarification. However, a majority of the Part 121 and Part 135
carriers indicated little or no need for clarification on the majority of
these issues, including whether they were subject to PRIA, which records
they were required to maintain, how long they were required to maintain
the records, how they should store the records, who should be allowed to
see
the records, and whether the carriers could charge a fee for supplying the
records. In contrast, many carriers indicated a great or very great need
for clarification on how to proceed when the hiring carrier cannot obtain
requested records and how to handle situations involving disciplinary
actions taken against a pilot. (App. V presents complete information on
which of the 17 key issues carrier hiring officials view as most in need
of clarification.) FAA*s revised advisory circular addresses some, but not
all, of carriers* issues related to the need for clarification.
Many carriers said there was a great need for clarification on how to
proceed in four situations when they are unable to obtain records from
other carriers. These situations and the percentages of Part 121 carriers
identifying them as greatly needing clarification are shown in figure 8.
Similar percentages of the Part 135 carriers we surveyed expressed a great
need to clarify how to proceed in these four situations. FAA*s revised
circular explains how to proceed in two of these situations* when a hiring
carrier cannot obtain a pilot*s records from a carrier that has gone out
of business or from a foreign entity* both of which were outlined in
goodfaith exceptions in the 1997 and 2000 amendments, respectively.
However, neither PRIA, as amended, nor the revised advisory circular
offers guidance
on how carriers should proceed when they are unable to obtain records from
other carriers that are still in business or driving records from a state.
Figure 8: Percentage of Part 121 Carriers That Identified a Great or Very
Great Need for Clarification of How to Proceed in Certain Situations
Source: GAO analysis of survey data from Part 121 and Part 135 carriers
that had made at least one request to FAA for PRIA records.
Many carriers also sought clarification on handling situations involving
disciplinary actions taken against a pilot by another carrier. Of the Part
121 carriers, 43 percent identified a great or very great need to clarify
which
disciplinary actions are related to an individual*s performance as a pilot
and therefore should be provided to carriers interested in hiring their
current and former employees. In addition, 39 percent of the Part 121
carriers
identified a great or very great need to clarify how carriers should
handle pilot records when a disciplinary action is resolved through a
negotiated settlement. Similar percentages of Part 135 carriers sought
clarification on the handling of these situations. However, neither PRIA,
as amended, nor FAA*s revised advisory circular defines disciplinary
actions, specifies which ones should be considered relevant and documented
in PRIA records, or discusses how to remove records of disciplinary
actions that have been
resolved through a negotiated settlement. Resolving carriers* questions
about how to proceed when other carriers do not provide required records
and how to determine what information about disciplinary actions should be
provided to hiring carriers is important because such questions, if
unresolved, can delay or preclude final hiring decisions.
FAA*s Revised Circular FAA*s guidance to carriers on PRIA includes a new
sample form that Includes a Sample Form requires a pilot applicant to
waive certain rights provided by PRIA. The That Requires Pilot
form also changes the party responsible for notifying the pilot of a
request Applicants to Waive Some for records. In September 2001, FAA
revised its advisory circular on PRIA
and included the sample form for hiring carriers to use when requesting
Protections and Alters records from current and former employers. (App. VI
includes a copy of Notification Provisions
FAA Form 8060- 11, Air Carrier and Other Records Request (PRIA)* Pilot
Required in the Law Records Improvement Act of 1996.) Part III of the form
requires the pilot to waive PRIA*s requirement that the current or former
employer receiving the
request for records notify the pilot within 20 days of the request and of
the pilot*s right to receive a copy of the records. The form does,
however, provide information on the pilot*s right to receive a copy of the
records
within 30 days of requesting them in writing. FAA made these changes in
the form to simplify and expedite the hiring process, according to the
official in the Air Transportation Division who is responsible for
overseeing policy decisions related to PRIA. In addition to violating
provisions in the act, part III of form 8060- 11 is problematic for
several reasons and could reduce a pilot*s chances of knowing when records
are actually forwarded to hiring carriers and of receiving a copy of the
records. First, the form makes the hiring carrier responsible for
notifying a pilot of a request rather than the current or
former employer as PRIA specifies. 21 Shifting responsibility for
notifying the pilot does not follow the process outlined in the law, which
requires the current or former employer to provide this notification.
Second, as we learned in interviewing pilots and hiring officials, forms
completed at the time of application sometimes remain on file for months
or years before being activated and submitted to current and former
employers, particularly when the hiring carrier is a major carrier.
Officials in FAA*s Aviation Data Systems Branch confirmed that the pilot
often signs these forms months or even years before the hiring carrier
submits them. In such cases, a pilot might not know whether and when the
hiring carrier actually submits the request to the current and former
employer. Furthermore, the revised form no longer includes a place for the
pilot*s address, which
makes it more difficult for former employers to obtain correct mailing
information to notify the pilot of the hiring carrier*s request and to
provide a copy of the records to the pilot, if requested.
FAA Has Developed Some FAA has developed some additional guidance for its
own staff. For
Guidance on PRIA for Its example, the agency prepared draft guidance for
its staff before PRIA took Own Staff but Has Not effect in February 1997,
even though it did not issue the original advisory Incorporated the
Guidance circular until May 1997. In addition, FAA has used E- mails and
memorandums to its regional and field offices to further clarify PRIA*s
into Its Handbooks and
requirements. Finally, FAA has assigned responsibility for responding to
Training Classes
PRIA requests from carriers to staff in the Aviation Data Systems Branch
and primary responsibility for answering policy questions about PRIA to
the Air Transportation Division, both of which are within FAA*s Office of
Flight Standards.
FAA*s efforts to disseminate guidance on PRIA to its staff have not yet
extended to revisions of the handbook that its operations inspectors are
to use to monitor carriers* training and use of pilots. 22 Furthermore,
the agency has not yet incorporated information on PRIA into its training
classes for operations inspectors. FAA uses its handbooks and training
classes to familiarize inspectors with laws, regulations, and inspection
protocols and to enhance their oversight and monitoring of carriers*
compliance with aviation laws and regulations. Without such information,
21 49 U. S. C. Sec. 44936 (f)( 6).
22 Operations inspectors conduct inspections of such items as pilots*
certification and performance, flight crews* training, and in- flight
record keeping.
inspectors may be unaware of PRIA and amendments to the law. FAA officials
said they believe information on PRIA should be included in the handbooks
and training, but they are awaiting the publication of our report to
ensure that all relevant information is included. In the meantime,
inspectors have been addressing their questions about PRIA to staff in the
Aviation Data Systems Branch. On March 22, 2002, FAA activated a new Web
site with information about
PRIA for carriers and pilots. The site provides brief answers to
frequently asked questions about how PRIA works, which records must be
provided, and what protections are afforded to pilots under the law. It
also includes links to a copy of the law, to FAA*s advisory circular that
provides guidance on PRIA, and to forms used by carriers to request
records. As of May 1,
2002, FAA had not linked the PRIA Web site to the agency*s home site or to
the Web information that FAA maintains for carriers and pilots. Linking
these sites would enhance the accessibility of the PRIA information. In
the spring of 2000, FAA began drafting guidance on which penalties are
appropriate when carriers violate PRIA*s requirements, according to
attorneys in FAA*s Office of Chief Counsel. They said that this effort has
become part of a larger one to revise penalty guidance in the agency*s
enforcement handbook, which is being coordinated with other FAA offices.
However, this coordination stopped after September 11, 2001, because of
uncertainty about FAA*s future role in aviation and airport security.
These officials said the coordination would proceed once this issue is
resolved.
We reviewed the draft guidance that had been completed and determined that
it covers most PRIA provisions and should provide inspectors with a
clearer basis for identifying and, where appropriate, for taking
enforcement actions against carriers for violations of PRIA*s
requirements. The draft guidance proposes penalties when a carrier fails
to
obtain the pilot*s consent to release records,
provide the records within 30 days of a request,
provide a copy of the records to the pilot, and
provide the pilot with an opportunity to correct any inaccuracies in
those records before making a final hiring decision.
Several Factors May Several factors may explain why FAA*s operations
inspectors, who conduct Hamper FAA*s
many thousands of inspections on carriers each year, have noted few
problems with carriers* compliance with PRIA. First, information on PRIA
Operations Inspection is not incorporated into the inspection handbooks
and training classes, Ability to Monitor
consequently these inspectors have no reminders to check for compliance
Compliance with PRIA with PRIA. Second, FAA lacks the information needed
to assess compliance with PRIA*s requirements for requesting records
because PRIA does not require that this information be reported (see ch.
2). Thus FAA may lack evidence that carriers have obtained the required
records before making final hiring decisions because PRIA does not require
carriers to retain the records they have received.
As of July 3, 2001, FAA*s Air Transportation Oversight System (ATOS)
database, 23 which tracks inspections of the nation*s 10 major passenger
carriers, showed no entries related to PRIA. FAA*s older Program Reporting
and Tracking Subsystem database, which tracks some limited information on
the 10 major carriers, as well as the results of inspections on all other
carriers, contained 76 inspection entries related to PRIA since the law*s
implementation in 1997. Two of these entries identified possible
noncompliance with PRIA and led to the opening of enforcement cases,
while the remaining 74 noted that the inspectors had provided information
on PRIA to the carriers but did not identify any noncompliance. One
additional entry, dated June 15, 1999, identified noncompliance but did
not lead to the opening of an enforcement case. According to the entry, a
random inspection of the records of 169 pilots with a large Part 121
carrier revealed noncompliance with PRIA, which the inspector reported to
the carrier*s Vice President of Operations and to the responsible
Principal
Operations Inspector at FAA. Since PRIA*s implementation in February 1997,
FAA has initiated 10 enforcement cases against six carriers. In the 3 most
serious cases, which resulted in fines ranging from $2,500 to $30,000, the
carriers failed to request PRIA background checks for 12 pilots they hired
and, in 1 case, the carrier falsified documents related to providing PRIA
checks. The remaining 7 cases resulted either in warning letters or were
closed with no action.
23 In October 1998, FAA began using ATOS, a new approach to overseeing the
nation*s 10 largest passenger air carriers* Alaska, America West,
American, Continental, Delta, Northwest, Southwest, Trans World, United,
and US Airways. Trans World subsequently merged with American.
Although the number of inspection findings and enforcement actions could
be indicative of widespread compliance with the act, our analyses of
carriers* requests for PRIA records and of carriers* awareness of PRIA*s
requirements for protecting pilots* rights indicate that carriers are not
always requesting the required records, especially from other carriers,
and are not always sufficiently aware of the pilots* rights protections to
comply with them (see chs. 2 and 3). Alternatively, FAA inspectors may not
be
regularly reviewing carriers* compliance. Without information on PRIA in
their inspection handbooks and training classes, these inspectors have no
reminders to check for compliance with PRIA. According to FAA*s Deputy
Associate Administrator, Office of Regulation and Certification, FAA*s
monitoring focuses on a carrier*s processes and procedures for complying
with PRIA, not on checks of records for individual pilots. Although we
concur with the importance of checking carriers* processes and procedures
for complying with laws, FAA cannot determine whether a carrier actually
follows its processes and procedures without performing at least limited
spot checks. This system safety approach with compliance checks is the
basis for the new ATOS inspection system that FAA uses to oversee the
nation*s 10 major air carriers.
Regardless of whether FAA operations inspectors attempt to monitor
carriers* compliance with PRIA, they may not have sufficient evidence to
do so. Just as FAA lacks information needed to assess compliance with
PRIA*s requirements for requesting records because PRIA does not require
that this information be reported (see ch. 2), FAA also may lack evidence
that carriers have obtained the required records before making final
hiring decisions because PRIA does not require carriers to retain the
records they have received. According to an attorney from FAA*s Office of
Chief Counsel, nothing in the PRIA statute requires carriers to maintain
the pilot records they receive from FAA, NDR, or other carriers. The
statute requires carriers to maintain the records they generate on their
pilot employees for 5 years, but it does not require them to store or
maintain the PRIA records
they receive when they hire pilots. Without these records, he noted, it is
very difficult for FAA to determine a carrier*s compliance with PRIA.
According to another official in FAA*s Air Transportation Division,
carriers have an incentive to dispose of these records to avoid any
liability resulting from their hiring decisions. Nonetheless, he observed
that some carriers still keep these records, and he agreed that it would
be almost impossible to complete an enforcement action against a carrier
without them. Requiring carriers to maintain the PRIA records they receive
could, however, be costly, especially for smaller carriers, according to
the Deputy Associate Administrator, and these costs would not be warranted
by the
safety benefits achieved. According to FAA, it has not identified pilot
performance during past training events as a high- risk area because of
the extensive training, testing, and checking required for pilots. We
believe it is important for FAA to be able to enforce the law. As
previously discussed, FAA is responsible for overseeing PRIA*s
implementation and has the authority to issue regulations or establish
procedures for carriers to maintain the records needed for FAA to monitor
and enforce compliance with the act. FAA has not issued regulations on
PRIA because it believes that carriers, not the government, are
responsible for collecting PRIA information. Furthermore, FAA believes
that it should focus its regulatory resources on higher aviation- safety
priorities. FAA officials agreed, however, that it was important for
carriers to maintain records of background checks on pilots they hire to
enable both the
carriers and FAA to monitor PRIA*s implementation. Conclusions By making
information about pilots* qualifications, performance, and
training available to hiring carriers, PRIA improves carriers* ability to
screen pilots and may help keep unsafe pilots out of the cockpits of
commercial aircraft. However, FAA*s limited oversight of the act*s
implementation, together with carriers* incomplete compliance with the
requirements of the law, may have prevented PRIA from being as effective
or as protective of pilots* rights as it could be. For example:
Unresolved procedural issues* such as how to correct errors in pilot
records, especially before hiring carriers see inaccurate information; how
to remove inappropriate records; and how to handle disputes
between pilots and carriers* effectively limit pilots* rights. As
individuals, pilots have less power than carriers, and without procedures
for resolving these issues, they cannot compel carriers to correct or
remove inaccurate records or settle disputes. Moreover, even when carriers
are willing to make changes, they may not know how to do so. Inaccurate or
inappropriate information may jeopardize a pilot*s chances of being hired.
FAA has not taken advantage of its Web site to make information about
pilots* rights readily available. Because the act does not mandate when
pilots are to be given an opportunity to correct their records, except
that it come before the final hiring decision, many pilots do not seek to
correct their records until after the records have been sent to the hiring
carrier. It is critical that FAA do what it can to make pilots aware of
their
rights to review and correct the records maintained by their current
employer at any time. With knowledge of their rights, pilots can take
responsibility for reviewing the accuracy of their records before the
records are sent to hiring carriers.
The sample form that FAA designed for hiring carriers and included in
its revised guidance for carriers, though intended to streamline the
hiring process, weakens pilots* rights and inappropriately shifts the
responsibility for notifying pilots of requests for their records from
current or former employers to hiring carriers. If carriers follow the
procedures set forth in the sample form, they will not be in compliance
with PRIA*s notification provision, and pilots may not know when
records are sent to hiring carriers. Although FAA has updated its
information on PRIA for carriers, it has not yet included this information
in key guidance for its own staff. Until the agency incorporates its
guidance on the act into its inspector handbooks and provides its
inspectors with appropriate training, the inspectors may not be
sufficiently aware of PRIA*s provisions to review carriers* compliance. We
do not know whether the limited number of inspection findings related to
PRIA is indicative of widespread compliance, infrequent compliance
reviews, or a lack of evidence to determine compliance. However, there is
sufficient evidence* from the discrepancies in the number of records
requested from FAA, NDR, and
carriers; from the reviews of 798 Part 135 carriers conducted by FAA
inspectors at our request; and from carriers* responses to our survey
questions about their requests for records in 2000* to suggest that
noncompliance is occurring.
The number of enforcement actions taken is also difficult to evaluate,
given the number of inspection findings. However, FAA has said that it
cannot enforce compliance because carriers are not required to retain the
records that would demonstrate their compliance. We agree. Unless carriers
retain the records they receive on pilots they hire, FAA cannot monitor or
enforce their compliance with PRIA*s background check requirements. As the
agency with exclusive responsibility for overseeing
PRIA*s implementation, FAA has the authority and, we believe the
obligation, to ensure that carriers have a system that will allow the
carriers and FAA to check compliance with all PRIA requirements,
especially whether required pilot background checks have been completed
for pilots hired.
Recommendations for To assist FAA in overseeing the implementation of PRIA
and to enable FAA
Executive Action to determine whether carriers have conducted the required
background
checks on pilots before making final hiring decisions on pilots, we
recommend that the Secretary of Transportation direct the FAA
Administrator to
update FAA*s advisory circular on PRIA to (1) clarify which records to
include in PRIA files that are forwarded to hiring carriers and which
records to exclude and (2) have carriers put in place a system that will
allow the carriers and FAA to check compliance with all PRIA requirements,
especially whether required pilot background checks
have been completed for pilots hired;
incorporate information on PRIA*s Web site that informs pilots of their
rights, including the right to review and correct their records under
PRIA;
revise the Air Carrier and Other Records Request form (FAA Form 806011)
to conform with the law*s provisions for notification, review, and
correction of records by pilots; and
incorporate information on PRIA into the handbooks, inspection guidance,
and training for FAA*s operations inspectors.
Agency Comments We provided DOT with a copy of our draft report for review
and comment. In our draft report, we recommended that FAA develop a
regulation requiring that carriers maintain records of background checks
on the pilots they hire for as long as the pilots remain in their employ.
While FAA agreed that carriers need to maintain the records for the agency
to monitor and enforce their compliance with the law, FAA proposed a
change in its administrative guidance rather than a regulation to achieve
this goal. We agreed that such a change could accomplish the intent of our
initial
recommendation and revised the recommendation accordingly. FAA concurred
with all other recommendations in our draft report and suggested technical
changes that we incorporated in this report where appropriate.
Most Carriers Found PRIA Records Helpful but Were Divided on Whether They
Were
Chapt er 5
Worth the Cost Most carriers found PRIA records at least somewhat helpful,
but they were divided on whether the records were worth the cost. The
majority of the carriers favored changes that would make additional
information available. Nearly three- quarters of the Part 121 carriers and
about three- fifths of the Part 135 carriers that had made at least one
request to FAA for PRIA
information found PRIA records to be helpful in making their hiring
decisions. Both groups of carriers found information from other sources,
such as the job interview, the carrier*s flight evaluation of the pilot,
and the
results of the carrier*s training program, more helpful. Since PRIA*s
costs are difficult to determine, Part 121 and Part 135 carriers were
divided on whether the PRIA information they received in 2000 was worth
the cost. Substantial majorities of both Part 121 and Part 135 carriers
told us they would support changes to PRIA that would enable them to
obtain additional information (1) from FAA on aviation accidents and
incidents
and on open, pending, and reopened enforcement cases and (2) from the
Department of Defense on military pilots* histories. Carriers Generally
Seventy- three percent of the Part 121 carriers found PRIA records at
least Found PRIA Records
somewhat helpful in making hiring decisions, and 27 percent said these
records were not very helpful, as shown in figure 9. Among the Part 121
Helpful in Making carriers, those with more than 1,000 pilots were more
likely than smaller Hiring Decisions but
carriers to say that PRIA records were helpful in making hiring decisions,
Less Helpful than and 61 percent of these larger carriers rated PRIA as
very helpful. Information from Other Sources
Figure 9: Views of Part 121 Carriers on the Helpfulness of PRIA
Information in Making Hiring Decisions
Source: GAO analysis of survey data from Part 121 carriers.
Compared with Part 121 carriers, Part 135 carriers found PRIA less helpful
in making hiring decisions: 59 percent of the Part 135 carriers found PRIA
at least somewhat helpful, and 41 percent said that PRIA was not very
helpful. (See fig. 10.)
Figure 10: Views of Sampled Part 135 Carriers on the Helpfulness of PRIA
Information in Making Hiring Decisions
Source: GAO analysis of survey data from Part 135 carriers that had
requested at least one PRIA record from FAA.
The Part 121 carriers found PRIA more useful in encouraging pilots to be
honest about their background and experiences than did the Part 135
carriers we surveyed. Sixty- eight percent of the Part 121 carriers rated
PRIA as moderately or very useful in this regard, compared with 49 percent
of the Part 135 carriers. Because PRIA records allow carriers to verify
pilots* statements, receiving the records increases the likelihood that
carriers will detect false statements. Nonetheless, 11 percent of the Part
121 carriers and 25 percent of the Part 135 carriers indicated that PRIA
was not very useful in encouraging pilots to be honest. According to
carriers* responses to our surveys, PRIA information played a greater role
in decisions not to hire pilots for Part 121 carriers than for Part 135
carriers. In 2000, 43 percent of the Part 121 carriers said they decided
not to hire pilots because of PRIA information, compared with 9 percent of
the Part 135 carriers we surveyed. The Part 121 carriers said they decided
not to hire 156 pilots in 2000 because of PRIA information, while we
estimate that the far more numerous Part 135 carriers decided not to hire
162 pilots. About two- thirds of the Part 121 carriers that said they did
not hire a pilot because PRIA information indicated that the circumstances
surrounding the pilot*s departure from a previous employer and the pilot*s
training records were major or moderate factors that influenced their
decisions. About half of these carriers identified the pilot*s driving
records or enforcement history as a factor, as shown in figure 11. Similar
percentages of Part 135 carriers reported being influenced by the
circumstances surrounding a pilot*s departure and by a pilot*s training
records. Evidence of falsification, employers* records of comments and
evaluations, and driving records were, however, much less influential for
the few Part 135 carriers that did not hire pilots because of PRIA
information than they were for the Part 121 carriers, and such evidence
played a smaller role in their hiring decisions than did the pilot*s
enforcement history.
Figure 11: Extent to Which Part 121 Carriers Reported That PRIA Records
Were a Factor in Decisions Not to Hire a Pilot
Source: GAO analysis of survey data from Part 121 carriers.
Both the Part 121 carriers and the Part 135 carriers we surveyed reported
that they found some PRIA records more helpful in making their hiring
decisions than others. Specifically, as shown in figure 12, they found FAA
information on closed enforcement actions during the past 5 years the most
helpful and FAA*s verification of the pilot*s medical record and the
pilot*s NDR information the least helpful.
Figure 12: Views of Part 121 Carriers and Sampled Part 135 Carriers on the
Helpfulness of PRIA Records in Making Hiring Decisions
Source: GAO analysis of survey data from Part 121 carriers and Part 135
carriers that had requested at least one PRIA record from FAA.
According to the Part 121 carriers, the information not required by PRIA
was generally far more helpful than PRIA records in making final hiring
decisions. Virtually all of the Part 121 carriers reported that they found
the results of job interviews, their own training programs, evaluations of
a pilot*s flying skills, and recommendations from other pilots at least
somewhat helpful in making these decisions. (See fig. 13.) This seems
reasonable, given that most carriers make a conditional job offer to, and
begin training, a pilot on the basis of non- PRIA information and have
made
their hiring decision by the time they receive and review PRIA files.
According to our survey results, 82 percent of the Part 121 carriers had
PRIA records available for review after a pilot had accepted a conditional
job offer or begun training. Moreover, some carrier officials said, in
survey comments and interviews, that they view training and performance
records from other carriers as subjective. They said that PRIA information
rarely changes their hiring decision unless they see multiple problems in
a pilot*s
file.
Figure 13: Views of Part 121 Carriers and Sampled Part 135 Carriers on the
Helpfulness of Non- PRIA Information in Making Hiring Decisions
a Because few Part 135 carriers review military pilot logbooks, we
excluded this question from our survey of these carriers. Source: GAO
analysis of survey data from Part 121 and Part 135 carriers that had
requested at least one PRIA record from FAA.
Similarly, in making their final hiring decisions, the Part 135 carriers
that had requested PRIA files from FAA generally reported finding
information
not required by PRIA to be more helpful than PRIA records. At least 94
percent of these Part 135 carriers said they found the results of job
interviews, their own evaluations of a pilot*s flying skills, and
recommendations from other pilots at least somewhat helpful in making
these decisions. About 73 percent of the Part 135 carriers said they had
PRIA records available for review late in the hiring process* after a
pilot had accepted a conditional job offer or begun training.
Carriers Differed on Although the total costs of implementing PRIA are
difficult to estimate,
Whether PRIA Is Worth carriers bear the largest portion of these costs.
According to our survey
results, the Part 121 carriers spent substantially more, on average, than
the the Cost
Part 135 carriers to comply with PRIA in 2000, and the Part 121 carriers
were more likely to view their costs as justified by the usefulness of the
information received.
Costs of Implementing PRIA The costs of implementing PRIA* to carriers,
pilots, and federal and state Are Difficult to Determine
agencies* are difficult to determine. In December 2000, FAA estimated $5.
3 million in implementation costs, including the costs to carriers,
pilots, and the agency itself; however, this estimate did not include a
number of costs to these entities and individuals, and it did not include
the costs of providing and obtaining NDR information. For carriers, the
full costs of
implementing PRIA are difficult to determine because they often are not
tracked separately from other hiring and record- keeping costs. For FAA
and NDR, the costs are also difficult to determine because complete data
are not available.
FAA estimated that carriers, in requesting and responding to requests for
PRIA records, incurred $4.6 million, or about 86 percent, of the estimated
$5. 3 million in total implementation costs. This estimate covered the
costs of
staff time to obtain a pilot*s signatures on release forms, to request
the records, and to follow up on records that do not arrive within 30
days;
staff time to review and evaluate an applicant*s file once it is
received;
staff time needed to prepare, copy, review the contents of, and mail
PRIA records; and
the maintenance of records related to PRIA*s requirements. FAA*s
estimate did not include the fees that hiring carriers pay to background
investigation companies and to those carrier employers and state motor
vehicle agencies that charge a fee for providing records. About 46 percent
of the Part 121 carriers and about 26 percent of the Part 135 carriers
responding to our survey reported hiring background investigation
companies to obtain at least some PRIA records. Most carriers* 81 percent
of the Part 121 carriers and 94 percent of the Part 135 carriers we
surveyed* said they do not charge a fee for providing records. Two of the
six 24 state motor vehicle agencies that respond to the vast majority of
carriers* requests for NDR information charge for this service.
In responding to our survey, the Part 121 carriers indicated that they
spent an average of $7, 000 to comply with PRIA in 2000. The Part 135
carriers said they spent an average of $1,000 or less. The total costs for
individual Part 121 carriers ranged from $1, 000 or less to $100,001 to $1
million. The
total costs for individual Part 135 carriers ranged from $1, 000 or less
to $10,001 to $50,000. (For more detailed cost information, see app. VII.)
Carrier officials told us that the costs for PRIA are difficult to
distinguish from other hiring costs, partly because most carriers do not
have staff dedicated to carrying out PRIA requirements and use the same
staff to perform both PRIA and other responsibilities. In addition, the
fees that background investigation companies charge to obtain PRIA
information may not be billed separately from their fees for performing
other services that are not required by PRIA, such as consumer credit or
criminal records checks. For 2000, FAA estimated that pilots whose PRIA
files were requested incurred total costs of nearly $436,000, or about 8
percent of the estimated $5. 3 million total cost. This estimate did not
include the pilots* costs to obtain copies of their employment and
training records from carriers for
review and to obtain copies of their driving records. Complete data are
not available on the costs to FAA, NDR, and state motor vehicle agencies
of implementing PRIA. For fiscal year 2000, when FAA provided a more
complete estimate of its PRIA costs than it had developed
24 Florida and Texas charge for providing NDR information, while Hawaii,
Ohio, Oklahoma, and Utah do not.
in previous years, the agency estimated its own costs at about $312, 000,
or about 6 percent of the $5. 3 million total estimate. However, according
to staff in FAA*s Aviation Data Systems Branch, this estimate did not
include
about $40,000 that FAA spent in fiscal year 2000 for the initial
development and maintenance of its automated system for responding to PRIA
requests. NDR officials reported spending $318 to complete 17, 000
requests from carriers in 1999, but this figure did not include any
portion of the $1 million that NDR spends annually to maintain its
computer system or of the costs that NDR incurs to hand- process pilots*
requests for driver information under the Privacy Act. None of the six
state motor vehicle agencies that respond to most carriers* requests for
NDR information could identify the
costs of providing the information, according to responsible state
officials. Carriers Were Divided on
Compared with the Part 135 carriers we surveyed, the Part 121 carriers
Whether PRIA*s Costs Were were more persuaded that the PRIA information
they received was worth Justified
the cost, but even the Part 121 carriers were split in their views.
Specifically, 52 percent of the Part 121 carriers believed that their PRIA
costs in 2000 were justified by the usefulness of the information
received, while 48 percent did not. Conversely, nearly two- thirds of the
Part 135 carriers did not believe that their PRIA costs were justified,
whereas about one- third did.
Most Carriers Favored Substantial majorities of both Part 121 and Part 135
carriers told us they Changes That Would
would support changes to PRIA that would enable them to obtain additional
information from FAA on aviation accidents and incidents and Make
Additional on open, pending, and reopened enforcement cases. Carriers can
obtain Information Available
this information from FAA under a Freedom of Information Act (FOIA) under
PRIA
request, but pilots are not informed of FOIA requests and are not provided
copies of the FOIA files that are sent to potential employers. FOIA
records also have not undergone as much legal review as PRIA records. The
majority of Part 121 carriers also told us they would support changes to
PRIA that would enable them to obtain flight records from the military.
Such records are not available through FOIA requests.
Carriers Can Request More Currently, carriers can obtain more extensive
information on a pilot*s safety Safety Information on Pilots history from
FAA under a FOIA request than under a PRIA request. In under FOIA Than
under responding to a FOIA request, FAA can release information on all
open, PRIA closed, and pending enforcement cases from which the pilot*s
identity has not been expunged, even if those cases are more than 5 years
old. In responding to a PRIA request, however, FAA is precluded by the act
from
releasing any records more than 5 years old. In addition, as a matter of
law, FAA provides information only on those accidents and incidents that
have resulted in a legal enforcement action. Under PRIA, FAA is not
required to provide other records that it maintains on aviation accidents
and incidents as well as on open, pending, and reopened enforcement cases.
According to FAA*s analysis, nearly 20,000 more records were available in
response to FOIA requests than to PRIA requests as of January 10, 2002.
(See table 6.) These include 9,885 records of enforcement cases that have
been closed but from which the pilot*s name has not been expunged as well
as of open, pending, or reopened enforcement cases. The remaining records
that FAA could provide were of accidents and incidents.
Table 6: Records Releasable under PRIA and FOIA from PRIA*s Implementation
on February 6, 1997, through January 11, 2002
Records releasable Records releasable Information system under PRIA under
FOIA Difference
Accident/ Incident 0 9, 694 9,694 records Enforcement records 2, 312 12,
197 9, 885
Total 2, 312 21, 891 19, 579
Source: FAA analysis of information from the agency*s Accident/ Incident
Data System and Enforcement Information System.
According to an analysis done by staff in FAA*s Aviation Data Systems
Branch, fewer than one- quarter of the 1, 726 carriers that requested PRIA
records between February 6, 1997, when the law went into effect, and
January 11, 2002, requested additional safety information under FOIA. The
analysis concluded that the majority of carriers are unaware that they are
receiving incomplete safety records from FAA under PRIA. Additionally, the
report noted that, under FOIA, there are no requirements to notify a
pilot of a request for records, to obtain the pilot*s consent for the
release of those records, or to provide the pilot with a copy of the
records that were released.
FAA does not support for a variety of reasons a change in the law that
would provide carriers with more complete safety information on pilot
applicants if it released its records of accidents; incidents; and open,
pending, or reopened enforcement cases. According to FAA*s Office of Chief
Counsel, using the reports of accidents and incidents in FAA*s data system
to evaluate pilots* performance could be unfair because these reports may
not involve pilot error. Moreover, even if they do, pilots identified in
accident and incident reports do not receive the same due process
protections that pilots receive when they are subject to legal enforcement
actions. Additionally, enforcement actions that have not been closed have
not been fully reviewed by FAA, NTSB, and perhaps a U. S. Court of
Appeals. These cases could eventually be dropped or dismissed.
Carriers Favored Receiving Over three- quarters of the Part 121 carriers
and about two- thirds of the Part Additional Information in 135 carriers
we surveyed supported having FAA include additional
Response to PRIA Requests information on accidents and incidents and on
open, pending, and
reopened enforcement cases in response to PRIA requests. However, the
carriers were much less supportive of including enforcement information
over 5 years old. (See table 7.)
Table 7: Percentage of Carriers That Supported Including Additional FAA
Information in Response to PRIA Requests
Percentage of Part 135 Percentage of Part 121
carriers that had made Information carriers
PRIA requests to FAA
Accident/ Incident data 80 66 related to pilot error Open, pending, and 78
62
reopened enforcement cases
Enforcement data over 5 36 27 years old Source: GAO analysis of survey
data from Part 121 and Part 135 carriers that had made at least one
request to FAA for PRIA records.
Although Congress excluded military flight records from the sources of
PRIA information in April 2000, 62 percent of the Part 121 carriers and 56
percent of the Part 135 carriers we surveyed supported a change in the law
that would enable them to receive these records. Currently, carriers can
review a military pilot*s logbook to obtain information on the pilot*s
flight hours, types of equipment flown, and rate of progress in mastering
new aircraft as well as any flight- related disciplinary actions. While
substantial majorities of both Part 121 and Part 135 carriers that had
hired military pilots found the military logbook helpful in making their
hiring decision,
the carriers nevertheless favored receiving flight records directly from
the military.
Military records are important to carriers because they hire many pilots
with military flight experience. Eighty- eight percent of the Part 121
carriers reported hiring at least some pilots with military flight
experience in 2000, and the largest Part 121 carriers, with more than
1,000 pilots, reported that about 40 percent of the pilots they hired in
2000 had military experience. Forty- six percent of the Part 135 carriers
that had requested PRIA files from FAA hired pilots with military flying
experience in 2000.
Appendi xes Fatal Aviation Accidents That Involved Pilots with Prior
Safety Problems Were Cited in
Appendi x I
Passing PRIA Legislation National Transportation Safety Board (NTSB)
report Flight and Date
number location Fatalities Cause and pilot history
11/ 15/ 1987 NTSB/ AAR- 88- 09 a Continental Air 28 The plane crashed on
takeoff due to the captain*s failure to have it Carriers 1713; deiced a
second time after a delay before takeoff. This resulted in a Denver,
Colorado
loss of control during rapid takeoff rotation by the first officer. The
first officer had shown significant shortcomings during his training. The
carrier was unaware that a previous employer had discharged the first
officer for inability to pass a flight check ride.
1/ 19/ 1988 NTSB/ AAR- 94- 05 Trans- Colorado 9 The plane went below
minimum descent altitude then struck Air Carriers 2286 terrain. The
captain had used cocaine prior to this flight. The first
(Continental officer*s record prior to his employment with this carrier
and during Express); his training indicated deficiencies in performing
instrument Bayfield, Colorado
procedures. Records of both pilots revealed prior traffic violations and
accidents and a previous aircraft accident for the captain. The carrier
was unaware that both pilots had received warning letters from the Federal
Aviation Administration (FAA).
2/ 19/ 1988 NTSB/ AAR- 88- 16 Air Virginia, Inc. 12 The plane crashed
shortly after takeoff because of the pilots* failure (American Eagle); to
maintain a proper flight path because of the first officer*s Cary, North
inappropriate instrument scan, the captain*s inadequate monitoring
Carolina
of the flight, and the crew*s response to a perceived fault in the
airplane*s stall avoidance system. Company records showed instances of
substandard performance by the copilot, who was
flying the plane at the time of the accident. 10/ 28/ 89 NTSB/ AAR- 90- 05
a Aloha Island Air
20 The captain continued flight under visual flight rules at night into
1712; Molokai, instrument meteorological conditions that obscured rising
Hawaii
mountainous terrain. The captain*s FAA records showed one previous
incident attributed to a brake malfunction and the suspension of his
commercial pilot certificate for 180 days for not meeting required flight-
time requirements and tests. 4/ 22/ 92 NTSB/ AAR- 93- 01 a
TomyInternational 9 The captain decided to continue visual flight into
instrument 22 (Scenic Air
meteorological conditions that obscured rising mountainous terrain Tours);
and failed to properly use available navigational equipment to Maui,
Hawaii
remain clear of the Island of Maui. The carrier was unaware that the
captain had been dismissed by five previous carriers for misrepresentation
of qualifications and experience, failure to report for duty, disciplinary
action, poor training performance, and work performance below standards.
(Continued From Previous Page)
12/ 1/ 1993 NTSB/ AAR- 89- 01 Express II 5719; 18 An excessively steep
landing approach, a lack of proper crew Hibbing, coordination, and a loss
of altitude awareness contributed to the Minnesota
plane*s descending short of the runway at night. The carrier did not
adequately address previously identified deficiencies in the captain*s
airmanship and crew resource management. Deficiencies included multiple
check ride failures, difficulties during transition and upgrade training,
letters of complaint and reprimand for his behavior toward company
employees, allegation of sexual
harassment toward female employees, and a reputation among first officers
as an intimidating captain.
12/ 13/ 1994 NTSB/ AAR- 95- 07 a Flagship Air 15 The plane crashed short
of the runway during an instrumentlanding
Carriers approach. The captain improperly assumed that the engine
(American Eagle
had failed and subsequently failed to follow approved procedures 3379);
Morrisville, for engine failure, single- engine approach and go- around,
and stall North Carolina
recovery. The carrier did not identify, document, monitor, or remedy
deficiencies in the pilot*s performance and training at the previous
carrier. a NTSB reports that included recommendations for pilot background
checks. Source: GAO summary of accident report data from NTSB.
Appendi x II
Methodology This appendix provides additional information on the design
and implementation of our mail surveys of Part 121 and Part 135 carriers
on their experiences of hiring pilots under the Pilot Records Improvement
Act of 1996 (PRIA). It also discusses database analyses we performed for
our review; an electronic survey done by FAA of its principal operating
inspectors to obtain information on pilot hiring by some Part 135 carriers
in 2000; and interviews we conducted with pilots on their hiring
experiences,
especially their experiences with PRIA background checks. Mail Surveys of
To support our responses to the four research questions asked by the
Carriers
Subcommittee on Aviation, House Committee on Transportation and
Infrastructure, we conducted two separate nationwide mail surveys of Part
121 and Part 135 carriers from June through September, 2001. The surveys
provided data on carriers* compliance with PRIA, the types of information
carriers use in hiring pilots, the costs they have incurred, and their
awareness of the pilots* rights set forth in PRIA. In addition, the
surveys provided data on carriers* views on the need for clarifying some
of those rights, PRIA*s usefulness in the pilot- hiring process, FAA*s
oversight of compliance with the law, aspects of PRIA that require more
clarification or guidance, and ways of improving PRIA.
We obtained data from FAA on Part 121 carriers, Part 135 carriers, those
carriers that have dual certificates to operate as either Part 121 or Part
135 carriers, and those carriers that made requests to FAA for PRIA
records. FAA data from November 13, 2000, identified 120 Part 121, 23 Part
121/ 135, and 2,717 Part 135 carriers. Our review of FAA*s Civil Aviation
Registry found that 5 of these Part 121 carriers were no longer operating.
We were unable to identify all of the active Part 135 carriers at that
time because FAA did not maintain that information in its database. Our
analysis of FAA*s
PRIA request data identified individual carriers that had made at least
one request to FAA for PRIA records from July 1998, when FAA*s automated
system began tracking these requests by carrier, through April 30, 2001.
We used this information in creating our mailing lists for the two
surveys. We combined the lists of Part 121 carriers and of Part 121/ 135
carriers to create
a list of 124 carriers that had made at least one PRIA request to FAA. We
sent the Part 121 carrier survey to all 124 of these carriers. Of the 2,
717 Part 135 carriers, 1, 144 (39 percent) had made at least one PRIA
request to FAA. We selected a random sample of 350 of these carriers and
sent the Part 135 survey to them.
During pretesting, we found that we needed procedures to guarantee the
anonymity of survey respondents because of the sensitive nature of some
questions on carriers* awareness of and implementation of certain PRIA
requirements. To guarantee anonymity, we retained no means of identifying
the respondent on the survey booklet or the return envelope. This
procedure precluded our knowing the identity of any respondent for the
surveys mailed to us in Washington, D. C. The use of a separate return
postcard, which was to be detached from the survey by the respondent and
sent to our Seattle, Wash., office for follow- up, allowed us to track
which respondents did and did not mail back a survey response. The
response rates were 81 percent for the Part 121 survey and 75 percent for
the Part 135 survey. Tabulated copies of the surveys of Part 121 and Part
135
carriers appear in appendixes III and IV, respectively. We randomly
selected the sample used for this study on the basis of a probability
procedure. As a result, our sample is only one of a large number of
samples that we might have drawn from the total population of 1,144 Part
135 air carriers that had made at least one PRIA request to FAA. If
different samples had been taken from the same population, it is likely
that the results (i. e., the estimates) would be different. We therefore
express our
confidence in our particular sample*s results as 95 percent confidence
intervals* bounded by lower and upper confidence limits. These are
intervals that would contain the actual population values for 95 percent
of the samples we could have drawn. As a result, we can say we are 95
percent confident that each of the confidence intervals presented in this
report includes the true values in the study population.
The responses for the survey of Part 135 carriers involve sampling errors.
The sampling error (confidence limits) for all percentages (except those
shown for questions 22 and 25) does not exceed plus or minus 7 percentage
points. The confidence limits for the percentage estimates for question 22
are shown in parentheses in table 8. These sampling errors are shown
separately because the number of respondents is much smaller for this item
than for all other items; and therefore, the confidence intervals are
larger. The sampling error for all percentage estimates for question 25
does
not exceed plus or minus 10 percentage points. The confidence limits for
the median estimates for questions 6, 9, and 21 are shown in tables 9, 10,
and 11 respectively.
Table 8: Confidence Limits for the Percentage Estimates for Question 22
Percentage estimate (confidence limit) Major
Moderate Minor
Not a Reasons for termination reason reason reason reason Uncertain
a. FAA*s records showed that the pilot had falsified information 19%
6% 0%
69% 6% during the job application process. N= 16 (6%, 42%) (1%, 27%) (0%,
18%) (45%, 87%) (1%, 27%)
b. The employer*s records showed that the pilot had falsified 13% 0%
7% 67%
13% information during the job application process. N= 15 (3%, 37%) (0%,
19%) (1%, 29%) (42%, 86%) (3%, 37%)
c. The pilot*s FAA records showed enforcement actions against 27% 20%
0% 47%
7% the pilot that made the pilot unacceptable for our air carrier. (10%,
52%) (6%, 45%) (0%, 19%) (24%, 70%) (1%, 29%)
N= 15
d. The employer*s records of comments and evaluations, 7%
29% 29%
29% 7% including those by a check airman, raised concerns about
(1%, 31%) (11%, 55%) (11%, 55%) (11%, 55%) (1%, 31%) the pilot*s
competency. N= 14 e. The pilot*s training records showed a pattern of poor
29%
29% 7%
29% 7%
performance. N= 14 (11%, 55%) (11%, 55%) (1%, 31%) (11%, (1%, 31%)
55%) f. The pilot*s records included disciplinary actions that made
20% 27%
7% 40%
7% the pilot undesirable for employment. N= 15 (6%, 45%) (10%, 52%) (1%,
29%) (19%, 64%) (1%, 29%)
g. The records showed circumstances of the pilot*s departure 35% 29%
18% 12%
6% from the former job that raised concerns. N= 17 (17%, 59%) (13%, 53%)
(5%, 40%) (3%, 33%) (1%, 26%)
h. The pilot*s driving records raised concerns. N= 15 7% 27%
7% 53%
7% (1%, 29%) (10%, 52%) (1%, 29%) (30%, 76%) (1%, 29%)
i. You may list other reasons below. N= 18 6% of the respondents listed
one or more reasons. The 95% confidence interval for this estimate ranges
from 1% to 25%. Table 9: Confidence Limits for the Percentage Estimates
for Question 6 Median (95 percent confidence
N
limits)
Question 6 (total) 253 9% (7, 11) Question 6 x 2000 252 3% (2, 3) Question
6 x 1999 232 2% (2, 3) Question 6 x 1998 216 2% (2, 3) Question 6 x 1997
208 2% (2, 3)
Table 10: Confidence Limits for the Percentage Estimates for Question 9
Median N
(95 percent confidence limits)
Question 9 (total) 252 7% (5, 8) Question 9A (2000) 250 3% (2, 3) Question
9B (1999) 233 2% (2, 3) Question 9C (1998) 214 2% (1, 2) Question 9D
(1997) 200 1% (0, 2)
Table 11: Confidence Limits for the Percentage Estimates for Question 21
Median N (95 percent confidence limits)
Question 21 208 0% (0, 0)
Our two 20- page surveys were identical except for two questions. First,
during pretests, Part 121 carriers told us that responses to the question
on the number of new pilots hired from 1997 through 2000 could identify
certain major Part 121 carriers and might lead to their not completing our
survey. Because of concerns about maintaining anonymity for Part 121
carriers, we omitted the question from our survey of these carriers.
However, we included the question in our survey of Part 135 carriers
because they did not express concern about its effects on their anonymity
during pretesting. (See app. IV, question 6.) Second, for question 3 in
both surveys, on the relative helpfulness of non- PRIA information to an
air carrier*s hiring decisions, we did not include one item** The pilot*s
own record of military flying** in the Part 135 survey because we were
told that few Part 135 carriers hire military pilots.
Early in designing our surveys, we interviewed three carriers to help
determine the appropriate topics for the surveys. Next, we met with 14 air
carriers to pretest the surveys. We selected a wide variety of carriers
for these meetings, including cargo and passenger carriers; carriers
located around the nation; and small, medium, and large carriers. In the
pretests, a printed survey, which was similar in appearance to our final
product, was filled out by one or more representatives selected by each
carrier for their
knowledge of and work with the pilot background checks required by PRIA.
The carrier representative( s) filled out the questionnaire in the
presence of two GAO observers. The observers then interviewed the carrier
representative( s) to ensure that (1) the questions were readable and
clear, (2) the terms were precise, (3) the survey did not place an undue
burden on carriers that would discourage their participation, and (4) the
survey appeared independent and unbiased in its point of view. We revised
the final survey to reflect the results of the pretests. Besides
pretesting the surveys, we interviewed and obtained reviews of
them from industry trade representatives for small, medium, and large
carriers. These representatives included AOPA, the Airline Industrial
Relations Conference, the National Air Carrier Association, the National
Air Transportation Association, the National Business Aviation
Association,
and the Regional Airline Association. We also met with FAA officials
involved in implementing FAA*s PRIA requirements. We incorporated comments
from these reviews as appropriate. To increase our survey response rates,
we mailed a prenotification letter to the respondents 1 week before
mailing the surveys themselves. We mailed the Part 121 surveys on June 8,
2001, and the Part 135 surveys on June 21, 2001. We then mailed (1)
reminder postcards 1 week after mailing each of the surveys and (2)
reminder letters 10 days after mailing the reminder postcards to those
carriers that had not yet responded. To ensure a better response from the
Part 121 carriers, we telephoned about 40 carriers to
ensure that they had received the survey instead of mailing reminder
letters to them. Finally, 10 days after mailing the reminder letters, we
again mailed the surveys to those carriers that had not yet responded. We
received the last surveys included in our analysis on September 6, 2001.
We received responses to our surveys from 101 Part 121 carriers and 261
Part 135 carriers for response rates of 81 percent and 75 percent,
respectively. Table 12 summarizes the survey returns.
Table 12: Summary of Survey Returns for Carriers That Made PRIA Requests
to FAA Part 121 and Part 121/ 135 carriers Part 135 carriers
Initial population size 143 2, 717 Number of carriers that made at least
124 1, 144 one PRIA request to FAA Total sample size a 124 350
Surveys returned 101 261 Eligible 100 258 Not eligible 1 3 Surveys not
returned 23 89 Undeliverable 0 17 No response b 23 72
Response rate c 81% 75%
a Does not include surveys that were returned but not filled out. b
Includes surveys returned blank, surveys received after our deadline, and
surveys not received. c Equals the number of surveys returned divided by
the number mailed.
Source: GAO.
Database Analyses To determine whether carriers had complied with PRIA*s
requirements to request and review background information on pilots, we
analyzed data from three DOT databases. These include the Airline
Certification, NDR,
and PRIA databases. (See table 13.)
Table 13: Databases Used in GAO Analyses Office responsible for the
Database database Purpose of the database
Airline Certification FAA*s Office of Flight Provides information on the
Standards Service type of operation authorized
for the carrier. NDR NDR in DOT*s National
Tracks and maintains driver Highway Traffic Safety
traffic violation indicators Administration reported by the states and
territories to a national database.
PRIA Aviation Data Systems Tracks carriers* requests to Branch in FAA*s
Office of FAA and provides pilots* Flight Standards Service
certificate and medical information as well as any closed enforcement
actions for findings of violation.
Sources: FAA and the National Highway Traffic Safety Administration.
To assess the reliability of the database that FAA uses to respond to
carriers* PRIA requests, we interviewed officials from FAA*s Aviation Data
Systems Branch, which is responsible for the development, maintenance, and
operation of this database, and the branch*s contractors. We also obtained
data on PRIA requests to FAA from the initiation of the agency*s automated
tracking system in July 1998 through June 2001. For 1998 through early
April 2001, this system included about 79, 350 requests. We examined these
data for consistency and completeness. When we found
that the requesting carrier*s certificate designation or Part designation
was missing, we requested this information from FAA. In addition, FAA
determined for us whether a carrier had requested PRIA information
directly or through a third party. We tested the reliability of FAA*s data
at selected sites and performed our own electronic data testing. The data
elements that we selected for testing were, in our opinion, sufficiently
complete and consistent to fairly characterize the types and extent of the
PRIA requests to which FAA responded during the period of our review. We
did not independently review the validity of the three databases from
which
the PRIA database derives its data. Because the Airline Certification and
NDR databases contain information available only from these sources, we
were unable to verify the quality of their data. Using these databases, we
performed several analyses to determine which carriers are subject to PRIA
and how many requests each had made for
PRIA background checks. To identify those carriers that are air carriers
and are therefore required to conduct background checks on pilots under
PRIA, we analyzed FAA data on which Part 121 and Part 135 carriers have
certificates to fly interstate and are subject to PRIA. We analyzed trends
in the number of requests made by carriers from PRIA*s implementation in
February 1997 through April 2001. To determine the number of requests made
by each carrier, we analyzed data on requests made by carriers since
the initiation of FAA*s automated PRIA database in July 1998 through April
2001. FAA does not have automated data on requests by individual carriers
for the first year of PRIA*s implementation. We analyzed available
information on pilot hiring to gain insight into the extent to which Part
135 carriers have implemented PRIA by requesting background check
information from FAA for pilots hired in 2000. In April 2001, we briefed
FAA on the percentage of Part 135 carriers that had made
at least one request to FAA for PRIA information in 2000. Because only 39
percent had made at least one request, FAA, in April 2001, asked its
principal operations inspectors, who are responsible for overseeing Part
135 carriers, to provide information on how many pilots these carriers had
hired in 2000 and whether the carriers operated only intrastate and thus
were potentially not subject to PRIA. By June 1, 2001, FAA had received
responses from 83 inspectors responsible for overseeing 842 Part 135
carriers. FAA provided us with copies of their responses for analysis.
Using data from the inspectors* responses and the PRIA database, we
eliminated
those 44 carriers that operate only intrastate and compared data on the
number of pilots hired in 2000 by each of the remaining 798 carriers with
the number of PRIA requests made by that carrier that year.
To gain perspective on the safety histories of carrier pilots, we obtained
relevant accident reports from NTSB, reviewed a 1988 GAO report 25 on
pilot
hiring, and asked FAA to provide updated data on pilots qualified to fly
commercial aircraft. FAA provided updated data from its Civil Aviation
Registry, Accident and Incident Data System, and Enforcement Information
System databases, including (1) how many pilots are qualified to fly for
commercial carriers; (2) how many of these pilots have been involved in
aviation accidents or incidents; (3) how many have had their certificates
revoked or suspended or have received fines; and (4) how many 25 U. S.
General Accounting Office, Aviation Safety: Airlines Should Check Pilot
Applicants* Safety History, GAO/ RCED- 88- 154 (Washington, D. C.: Oct.
21, 1988).
enforcement cases that are open, pending, reopened, or expunged involved
these pilots.
We met with FAA program managers to discuss the results of our surveys and
database analyses and to obtain their insights on the findings. Pilot
Interviews To understand the perspectives of pilots involved in hiring
under PRIA, we interviewed a sample of 20 pilots at hiring fairs and
carriers. We also interviewed 27 pilots whom we identified as having
reported experiencing problems with their PRIA records because they had
contacted FAA,
congressional staff, or our office. Most of these 27 pilots provided
copies of the PRIA records prepared by their current or former employers
for our review and analysis.
Survey of Part 121s: Pilot Records
Appendi x II I Improvement Act United States General Accounting Office GAO
Survey of Part 121s: Pilot Records Improvement Act Introduction
Experiences with Pilot Records Improvement Act
The U. S. General Accounting Office ( GAO) is an 1. Under PRIA, air
carriers are currently required to agency of the legislative branch that
reviews federal
check a pilot s background by reviewing three programs for the U. S.
Congress. We are currently
types of records during the hiring process FAA surveying air carriers as
part of a study on federal
records, employers records, and vehicle driving requirements for hiring
pilots. We are asking all Part
records. Overall, how helpful is this PRIA 121 air carriers for
information on their experiences
information for making pilot hiring decisions that with the Pilot Records
Improvement Act ( PRIA) and
improve the safety of your air carrier s for their opinions on how the
Congress and the
operations? ( Check one. ) N= 98
Federal Aviation Administration ( FAA) might improve this process.
1. 18% Very helpful This survey is completely anonymous. There is no
identification of your com any on the questionnaire.
2. 18% Moderately helpful You are asked to return the attached postcard
separately after completing the questionnaire. The
3. 34% Somewhat helpful number on the postcard will let us know which
companies participated in our survey. There is no
4. 25% Not very helpful information that can link the postcard with your
questionnaire.
5. 2% Uncertain
Without your air carrier s response, we will not be 6. 2% Other ( Please
describe. )
able to accurately report to the Congress on how PRIA is working
nationwide. Please answer all the questions that apply to your air
carrier. Your participation is vital so that we can report to the Congress
on what works well and what could be improved.
It takes about 30 to 45 minutes to complete the questionnaire, depending
on the company s experiences. We made every effort to minimize the amount
of information requested. Your prompt participation will help us avoid
costly follow- up mailings. If you have any questions about our review or
this survey, please contact Nancy Boardman via our toll- free number at 1-
877- 312- 7705 or via e- mail at BoardmanN@ gao. gov.
If the envelope is missing, please return your survey to:
Ms. Nancy Boardman U. S. General Accounting Office 441 G Street NW, Room
2T23 Washington, DC 20548
Thank you very much for taking time to contribute Note: Percentages may
not add to 100 due to to this study.
rounding.
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
2. For the period from February 1997 through December 2000, please rate
the relative level of hel fulness for your air carrier s hiring decisions
of the types of PRIA information listed below. ( Check one for each row. )
Did not
Very Moderately
Somewhat Not very
receive
helpful helpful
helpful helpful
this
Uncertain
PRIA information
( 1) ( 2)
( 3) ( 4)
( 5)
( 6)
a. FAA s letter of verification for the 29% 17% 23% 30% 1%
pilot s medical certificate N= 9
b. FAA s letter of verification for the 29% 22% 24% 25% 1%
pilot s type rating N= 97
c. FAA s records of closed 37% 31% 17% 10% 4%
enforcement actions in the last 5 years N= 97
d. The pilot s driving records from the 15% 28% 26% 30% 1%
National Driver Register ( NDR)
N= 9
e. The pilot s records from previous 29% 22% 26% 24% 0% 0%
employers N= 97
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
3. For the period from February 1997 through December 2000, please rate
the relative level of hel fulness for your air carrier s hiring decisions
of the types of non- PRIA information listed below. ( Check one for each
row. )
Not Very
Moderately Somewhat
very
Did not
hel ful hel ful
hel ful hel ful
do this
Uncertain
Information from Non- PRIA sources
( 1) ( 2)
( 3) ( 4)
( 5)
( 6)
a. Job interview with the pilot N= 97 72% 20% 7% 1% 0% 0% b. Results of
our air carrier s evaluation of
54% 13% 5% 4% 21% 2% the pilot s flying in an aircraft N= 9
c. ( If you hire conditionally: ) Results of 43% 16% 3% 0% 31% 7%
our air carrier s training program N= 90
d. The pilot s logbook from nonmilitary 24% 33% 23% 12% 6% 2%
flying N= 97
e. Results of our pre- employment drug 39% 20% 12% 24% 3% 2%
tests N= 97
f. Recommendations from other pilots 44% 27% 20% 6% 2% 1%
N= 97
g. The pilot s own record of military flying 13% 29% 30% 16% 7% 4%
N= 97
h. You may describe others below. N= 0
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
4. Please rate the usefulness of PRIA to your air 6. How many pilots
worked for your air carrier as of
carrier, considering the extent to which it December 31, 2000? ( Check
one. ) N= 98
encourages pilots to be honest about their background and experiences. (
Check one. ) N= 98
1. 5% 10 or fewer 1. 36% Very useful
2. 19% 11 to 50 2. 32% Moderately useful
3. 15% 51 to 100 3. 20% Somewhat useful
4. 36% 101 to 500 4. 11% Not very useful
5. 6% 501 to 1,000 5. 0% Uncertain
6. 18% Over 1,000 6. 1% Other ( Please describe. )
7. 0% Other ( Please describe. )
5. Of the PRIA records you received from pilots employers in calendar year
2000, how many contained the level of detail and candid evaluation that
your air carrier needed for hiring decisions?
( Check one. ) N= 98
1. 1% Does not apply: No PRIA records received from employers in 2000
2. 6% All of the records 3. 17% Almost all 4. 12% More than half 5. 15%
About half 6. 15% Less than half 7. 25% Few/ None of the records 8. 5%
Uncertain 9. 2% Other ( Please describe. )
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
7. Please rate the helpfulness of each of the following for helping you
understand the requirements of PRIA. ( Check one for each row. )
Very Moderately
Somewhat Not very
Do not
helpful helpful
helpful helpful
use
Uncertain
( 1) ( 2)
( 3) ( 4)
( 5)
( 6)
a. The FAA principal operations 23% 11% 17% 20% 19% 8%
inspector ( POI) for our air carrier
N= 98
b. The FAA Oklahoma City office 13% 12% 20% 16% 32% 6%
N= 97
c. FAA regional offices N= 98 3% 11% 16% 20% 42% 7% d. FAA headquarters N=
96 2% 8% 11% 23% 49% 6% e. The FAA Advisory Circular for PRIA
18% 32% 31% 6% 10% 3%
N= 98
f. Our trade association ( ATA, Air Con, 25% 20% 15% 6% 28% 5%
AOPA, HAI, NATA, NACA, NBAA, RAA, etc. ) N= 98
g. Our air carrier s legal counsel N= 97 21% 15% 17% 6% 36% 4% h. You may
list other helpful sources below. N= 0
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
Providing PRIA information to other air carriers
8. For each calendar year from 1997 through 2000, please estimate the
number of PRIA requests received about your current or former pilots from
prospective employers. Please report the number of requests rather than
the number of pilots for whom you received requests. ( Enter number. If
none, enter 0. ) Number of PRIA
Calendar requests received by
year your air carrier
a. 2000 N= 91 Range: 0 950 Median: 30 b. 1999 N= 86 Range: 0 1000
Median: 24 c. 1998 N= 74 Range: 0 800
Median: 20 d. 1997 N= 67 Range: 0 300
Median 6 9. What fee, if any, does your air carrier currently
charge to provide a pilot s PRIA information to other air carriers? (
Check one. ) N= 98
1. 81% Do not charge a fee
2. 0% Copying costs depend on amount copied
3. 18% Standard amount per request 4. 1% Other ( Please describe. )
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
10. 11. 12. 1. 2. a. b. a. b. PRIA information you requested in 2000
Did your air carrier hire any new pilots during calendar year 2000? (
Check one. ) 98% Yes
13. What percentage of your air carrier s pilots hired 14. Of the ilots
you hired in calendar year 2000, for
during calendar 2000 had experience as a military how many did you request
PRIA records from
pilot? ( Check one. ) N= 95
their previous employers? Reminder: You may not have requested this
information from 1. 12% None
employers such as the military, Part 91 operators, etc. ( Check one. ) N=
9
2. 32% 1% to 10% 1. 56% All pilots 3. 14% 11% to 20%
2. 27% Almost all 4. 14% 21% to 30%
3. 6% More than half 5. 5% 31% to 40%
4. 3% About half 6. 4% 41% to 50%
5. 5% Under half 7. 9% 51% to 60%
6. 1% Few/ None of pilots 8. 3% 61% to 70%
7. 1% Uncertain
9. 0% 71% to 80% 8. 0% Other ( Please describe. )
10. 0% 81% to 90% 11. 0% 91% to 95% 12. 1% 96% to 100% 13. 6% Uncertain
15. Of the pilots you hired in calendar year 2000, for 14. 0% Other (
Please describe. )
how many did you actually receive any records from their previous
employers? Reminder: You may not have received this information from
employers such as foreign carriers, bankrupt carriers, the military, Part
91 o erators, etc.
( Check one. ) N= 9
1. 18% All pilots 2. 50% Almost all 3. 17% More than half 4. 7% About half
5. 4% Under half 6. 2% Few/ None of pilots 7. 1% Uncertain
8. 1% Other ( Please describe. )
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
16. During calendar year 2000, how many FAA 17. During calendar year 2000,
for how many
responses to your air carrier s PRIA requests did National Driver Register
( NDR) requests did your
you receive within 30 days? ( Check one. ) N= 95
air carrier receive the response within 30 days of your initial request? (
Check one. ) N= 95
PRIA requests to FAA include the pilot s medical 1. 1% Does not apply: Did
not receive any
certificate, airman s certificates and ratings, and
NDR information in calendar year
enforcement history.
2000
PRIA requests to FAA exclude FOIA requests for accident and incident data
and additional
2. 26% All responses received in 30 days enforcement information.
3. 37% Almost all 1. 0% Does not apply: Did not receive any
FAA i formation i calendar year 2000
4. 18% More than half 2. 29% All responses received in 30 days
5. 8% About half 3. 39% Almost all
6. 2% Under half 4. 17% More than half
7. 2% Few/ None 5. 7% About half
8. 2% Uncertain
6. 3% Under half 9. 3% Other ( Please describe. )
7. 1% Few/ None 8. 3% Uncertain
9. 0% Other ( Please describe. )
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
18. During calendar year 2000, how many of the PRIA responses from the
types of employers listed below did your air carrier receive within 30
days? Requests to the pilot s employers would include records of training,
proficiency, or other records from the places where the applicant has
worked as a pilot. ( Check one for each row. )
How many requests received within 30 days?
( Check one for each type of employer. )
Did not
More
make
Almost than
About Under
Few/
Type of employer
requests
All all
half half
half None
( 1)
( 2) ( 3)
( 4) ( 5)
( 6) ( 7)
a. Major passenger air carrier 35% 18% 29% 6% 3% 4% 3%
N= 88
b. Regional passenger air carrier 16% 18% 41% 10% 8% 3% 3%
N= 88
c. Commuter passenger air 12% 13% 44% 16% 7% 3% 5%
carrier N= 8
d. On- demand ( non- scheduled) 12% 9% 27% 20% 11% 13% 7%
air carrier N= 89
e. Large cargo air carrier 16% 12% 36% 20% 6% 3% 6%
( Part 121) N= 88
f. Small cargo air carrier 8% 10% 29% 15% 8% 19% 10%
( Part 135) N= 8 g. Please describe others below. N= 96 ( 1% gave
comments)
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
Experiences in hiring pilots
19. At what point in the hiring process does your air carrier usually have
the PRIA records available for review? ( Check one. ) N= 94
1. 2% Before deciding to interview a candidate
2. 4% After deciding to interview a candidate
3. 11% Before extending a ( conditional) job offer
4. 32% After pilot accepts a ( conditional) job offer
5. 50% During our pilot training program 6. 1% Other ( Please describe. )
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
20. Because of PRIA information you received , how many pilots did your
air carrier decide not to hire during calendar year 2000? ( Enter number.
If none, enter 0. ) N= 93
_ _ _ _ _ _ 156_ _ _ _ _ _ _ _ _ _ pilots in 2000
If your answer to Question 20 is 0, please skip to Question 22.
21. Please indicate to what extent the following information obtained
under PRIA requests influenced your air carrier s decision to terminate
from training or not to hire these pilots in calendar year 2000. ( Check
one for each row. )
Major Moderate
Minor Not a
reason reason
reason reason
Uncertain
( 1) ( 2)
( 3) ( 4)
( 5)
a. FAA s records showed that the pilot had falsified 44% 11% 0% 36% 8%
information during the job application process.
N= 3
b. The employer s records showed that the pilot had 43% 13% 5% 35% 3%
falsified information during the job application process. N= 37
c. The pilot s FAA records showed enforcement 25% 25% 14% 36% 0%
actions against the pilot that made the pilot unacceptable for our air
carrier. N= 3
d. The employer s records of comments and 26% 36% 13% 26% 0%
evaluations, including those by a check airman, raised concerns about the
pilot s competency.
N= 39
e. The pilot s training records showed a pattern of 35% 30% 7% 25% 2%
poor performance. N= 40
f. The pilot s records included disciplinary actions 28% 28% 3% 39% 3%
that made the pilot undesirable for em loyment.
N= 3
g. The records showed circumstances of the pilot s 25% 39% 8% 22% 6%
departure from the former job that raised concerns. N= 3
h. The pilot s driving records raised concerns. 38% 13% 13% 35% 0%
N= 37 i. You may list other reasons below. N= 40 ( 2% gave comments)
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
22. 23. 24. 1. 3. 4. 5. 6. 7. 1. 2. 1. 2. 3. 4. 5. 6. 7. PRIA does not
require the military to provide pilot records to air carriers. When your
air carrier hires pilots with military flying experience, what impact does
this exclusion have on your air carrier s ability to assess the quality of
those pilots? ( Check one. ) recently
2. N= 94
61% Yes
27. We are aware that the PRIA law ( 49 USC 44936) went into effect
without any implementing regulations and that it has been amended several
times. For this reason, we would appreciate your help in finding out
whether air carriers are aware of some of the details of this law. Please
indicate whether or not your air carrier is aware of each PRIA requirement
below. ( Check one for each row. )
Reminder: Your answers to this question, or any other, cannot be
associated with your air carrier because of our survey s procedures for
ensuring anonymity.
Aware of requirement?
( Check one for each row. )
Yes No
( 1) ( 2)
PRIA requirements for air carriers hiring pilots
a. The pilot must sign a consent form for FAA records to be released to
the 98% 2%
air carrier. N= 98
b. The pilot must sign a consent form for records to be released from the
99% 1%
employers where the applicant has worked as a pilot of a civilian or
public aircraft. N= 98
c. The pilot must sign a consent form for the release of driving records.
99% 1%
N= 98
d. The air carrier must give the pilot an opportunity to submit written
69% 31%
comments to correct any inaccuracies in the PRIA records before making a
final hiring decision. N= 97
e. Air carriers must restrict their use of a pilot s PRIA records to
decisions 80% 20%
made in the hiring process. N= 97
f. The air carrier must keep PRIA records confidential to protect a pilot
s 96% 4%
privacy. N= 98
g. The air carrier must ensure that only the group involved in the hiring
90% 10%
process sees the pilot s PRIA records and that they do not share the
information with any other individuals. N= 98
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
Aware of requirement?
( Check one for each row. )
Yes No
( 1) ( 2)
Requirements for responding to PRIA requests from other air carriers
a. The air carrier must provide copies of the pilot s flight records (
training, 98% 2%
proficiency, professional competence, drug and alcohol tests, etc. ) .
N= 97
b. The air carrier must provide the pilot s records within 30 days of 98%
2%
receiving a PRIA request from another air carrier. N= 98
c. The air carrier must notify the pilot in writing within 20 days that
the 45% 55%
pilot s records were requested. N= 97
d. The air carrier must notify the pilot in writing within 20 days that
the 53% 47%
pilot can make a written request for a copy of the records being furnished
to the potential employer. N= 97
e. If a pilot makes a written request to see the records being sent to a
88% 12%
potential employer, the air carrier must provide a co y of the records
within 30 days. N= 98
f. The air carrier must maintain appropriate pilot records for 5 years in
97% 3%
order to respond to PRIA requests for the pilots you employ or have
employed. ( Such records cover training, proficiency, professional
competence, and the results of drug and alcohol tests. ) N= 98
g. When responding to PRIA requests, air carriers should send records no
84% 16%
more than 5 years old. N= 98 Other PRIA requirements for air carriers
a. When a pilot makes a written request to review the PRIA records kept
20% 80%
on the pilot by a current or previous employer, the air carrier must allow
the pilot to review the records within 30 days. N= 98
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
28. How do you rate the need for clarification of the following issues
relating to federal requirements for hiring pilots? ( Check one for each
row. )
Need for clarification
Very Little or
Some Moderate
Great great
no need need
need need
need
Uncertain
( 1) ( 2)
( 3) ( 4)
( 5) ( 6)
a. Whether our air carrier is subject to PRIA 83% 6% 7% 1% 2% 0%
requirements N= 97
b. Which records we must request from former 62% 16% 15% 5% 1% 0%
employers N= 97
c. How our air carrier should proceed when a 15% 14% 22% 25% 24% 0%
pilot s employer does not provide the records we request N= 97
d. Who is responsible for providing employer 23% 15% 29% 16% 11% 5%
training records when a third party conducts the training N= 98
e. How our air carrier should proceed when a 18% 12% 25% 21% 22% 0%
pilot s employer is no longer in business N= 98
f. How our air carrier should proceed if a pilot s 21% 16% 16% 21% 24% 0%
employer is located in a foreign country N= 98
g. What our air carrier should do if a state does not 18% 21% 25% 16% 18%
0%
provide the driving records we request N= 98
h. How long we should keep the PRIA 21% 15% 31% 16% 16% 0%
information on a pilot we do not hire N= 97
i. How long we should keep the PRIA 41% 16% 16% 13% 13% 0%
information on a pilot we do hire N= 98
j. How long records should be maintained once a 51% 14% 20% 8% 6% 0%
pilot has left our air carrier s employment
N= 97
k. Which disciplinary actions are related to the 16% 14% 26% 21% 23% 0%
individual s performance as a pilot and therefore should be provided to
air carriers interested in hiring our current or former pilots
N= 97
l. Which pilot records are related to the 34% 18% 19% 13% 15% 0%
individual s performance as a pilot and therefore should be provided to
air carriers interested in hiring our current or former pilots
N= 98
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
Need for clarification
Very Little or
Some Moderate
Great great
no need need
need need
need
Uncertain
( 1) ( 2)
( 3) ( 4)
( 5) ( 6)
m. Whether the pilot s PRIA records must be 29% 20% 24% 16% 9% 1%
stored separately from our air carrier s current employment records N= 98
n. Which people are allowed to see the PRIA 50% 20% 15% 8% 6% 0%
records as part of the hiring process N= 98
o. What we should do if a pilot challenges one of 17% 22% 29% 19% 12% 0%
the records in the pilot s PRIA files N= 98
p. How air carriers should handle pilot records 21% 20% 21% 15% 24% 0%
when a disciplinary action is resolved through a negotiated settlement N=
97
q. Whether our air carrier is allowed to charge a 59% 15% 13% 4% 8% 0%
fee for providing PRIA records N= 98 r. You may list other PRIA areas that
need clarification below. N= 98 ( 8% gave comments)
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
29. How do you rate the following proposals for changes to federal
regulations, activities, and laws relating to pilot hiring? ( Check one
for each row. )
Strongly Generally
Generally Strongly
support support
Neutral oppose
oppose
Uncertain
( 1) ( 2)
( 3) ( 4)
( 5) ( 6)
a. Eliminate PRIA requirements for 30% 15% 23% 20% 9% 2%
air carriers to conduct a National Driver Register search. N= 98
b. Have FAA include the driving 42% 23% 21% 5% 5% 3%
information from its medical files when responding to air carriers PRIA
requests. N= 98
c. Strengthen enforcement of the 31% 28% 26% 5% 8% 2%
requirement that air carriers must provide pilot records within 30 days.
N= 98
d. Provide more specific guidance 31% 37% 28% 2% 2% 1%
on which types of pilot records should be provided to a prospective
employer. N= 98
e. Revise the PRIA Advisory 46% 30% 22% 1% 0% 1%
Circular so that it is easier to understand. N= 98
f. Create an FAA Web site with 56% 24% 11% 2% 4% 2%
PRIA contacts for all air carriers.
N= 98
g. Change the law to require Part 91 16% 20% 27% 15% 17% 4%
employers to maintain PRIA records for the pilots they employ. N= 97
h. Change the law so that a pilot s 45% 34% 12% 2% 5% 2%
PRIA records from FAA include records of accidents and incidents caused by
pilot error. N= 98
i. Change the law so that a pilot s 47% 30% 15% 3% 3% 2%
PRIA records from FAA include open, reopened, and pending enforcement
cases. N= 98
j. Change the law so that any PRIA 17% 17% 34% 14% 14% 3%
records provided by FAA include enforcement cases more than 5 years old.
N= 98
k. Update Part 121 regulations to 25% 31% 24% 5% 10% 4% As noted in
chapter 1, footnote 9, data results from our surveys of Part 121 and Part
135 carriers are reported differently for the body of our report and for
the two survey appendixes.
30. Please add any comments you wish on the issues in this survey or on
other matters related to the Pilot Records Improvement Act ( PRIA) . N= 98
( 34% gave comments)
Thank you very much for participating in our survey.
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
Survey of Part 135s: Pilot Records
Appendi x V I Improvement Act United States General Accounting Office GAO
Survey of Part 135s: Pilot Records Improvement Act Introduction
Experiences with Pilot Records Improvement Act
The U. S. General Accounting Office ( GAO) is an 1. Under PRIA, air
carriers are currently required to agency of the legislative branch that
reviews federal
check a pilot s background by reviewing three programs for the U. S.
Congress. We are currently
types of records during the hiring process FAA surveying air carriers as
part of a study on federal
records, employers records, and vehicle driving requirements for hiring
pilots. We are asking a
records. Overall, how helpful is this PRIA random sample of Part 135 air
carriers for information
information for making pilot hiring decisions that on their experiences
with the Pilot Records
improve the safety of your air carrier s Improvement Act ( PRIA) and for
their opinions on
operations? ( Check one. ) N= 25
how the Congress and the Federal Aviation Administration ( FAA) might
improve this process.
1. 11% Very helpful This survey is completely anonymous. There is no
identification of your com any on the questionnaire.
2. 13% Moderately helpful You are asked to return the attached ostcard
separately after completing the questionnaire. The
3. 33% Somewhat helpful number on the postcard will let us know which
companies participated in our survey. There is no
4. 39% Not very helpful information that can link the postcard with your
questionnaire.
5. 3% Uncertain
Without your air carrier s response, we will not be 6. > 1% Other ( Please
specify. )
able to accurately report to the Congress on how PRIA is working
nationwide. Please answer all the questions that apply to your air
carrier. Your participation is vital so that we can report to the Congress
on what works well and what could be improved.
It takes about 30 to 45 minutes to complete the questionnaire, depending
on the company s experiences. We made every effort to minimize the amount
of information requested. Your prompt participation will help us avoid
costly follow- up mailings. If you have any questions about our review or
this survey, please contact Nancy Boardman via our toll- free number at 1-
877- 312- 7705 or via e- mail at BoardmanN@ gao. gov.
If the envelope is missing, please return your survey to:
Ms. Nancy Boardman U. S. General Accounting Office 441 G Street NW, Room
2T23 Washington, DC 20548
Thank you very much for taking time to contribute Note: Percentages may
not add to 100 due to to this study.
rounding.
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
2. For the period from February 1997 through December 2000, please rate
the relative level of hel fulness for your air carrier s hiring decisions
of the types of PRIA information listed below. ( Check one for each row. )
Did not PRIA information Very
Moderately Somewhat
Not very
receive
helpful helpful
helpful helpful
this
Uncertain
( 1) ( 2)
( 3) ( 4)
( 5)
( 6)
a. FAA s letter of verification for the 20% 17% 22% 38% 2%
pilot s medical certificate N= 247
b. FAA s letter of verification for the 22% 17% 24% 34% 2%
pilot s type rating N= 247
c. FAA s records of closed enforcement 28% 20% 28% 22% 2%
actions in the last 5 years N= 247
d. The pilot s driving records from the 18% 19% 25% 36% 2%
National Driver Register ( NDR)
N= 247
e. The pilot s records from previous 15% 19% 28% 34% > 1% 2%
employers N= 253
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
3. For the period from February 1997 through December 2000, please rate
the relative level of hel fulness for your air carrier s hiring decisions
of the types of non- PRIA information listed below. ( Check one for each
row. )
Not Very
Moderately Somewhat
very
Did not
hel ful hel ful
hel ful hel ful
do this
Uncertain
Information from Non- PRIA sources
( 1) ( 2)
( 3) ( 4)
( 5)
( 6)
a. Job interview with the pilot N= 254 68% 18% 7% 4% 1% > 1% b. Results of
our air carrier s evaluation of
53% 15% 14% 5% 11% 1% the pilot s flying in an aircraft N= 253
c. ( If you hire conditionally: ) Results of 31% 14% 12% 7% 34% 3%
our air carrier s training program N= 22
d. The pilot s logbook from nonmilitary 18% 26% 36% 15% 4% > 1%
flying N= 252
e. Results of our pre- employment drug 38% 14% 21% 24% > 1% 2%
tests N= 253
f. Recommendations from other pilots 55% 25% 13% 4% 3% > 1%
N= 253 g. You may describe others below. N= 258 ( 2% gave comments)
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
4. Please rate the usefulness of PRIA to your air 6. For each of the years
below, please estimate the
carrier, considering the extent to which it number of new pilots hired by
your air carrier.
encourages pilots to be honest about their
( Enter number for each row. If none, enter 0. )
background and experiences. ( Check one. ) N= 25
If your air carrier started its business after 1. 21% Very useful
February 1997, please give the year it started. N= 28 1997 4%
% 2. 25% Moderately useful
_ _ _ _ _ _ _ _ _ _ 1998 36% % ( Year) 1999 32%
% 3. 25% Somewhat useful
2000 29% % 4. 24% Not very useful 5. 4% Uncertain
Calendar Number of
year pilots hired
6. > 1% Other ( Please describe. )
2000 Range: 0 200 Median: : 3 1999 Range: 0 200 Median: : 2 1998 Range: 0
110 Median: : 2 1997 Range: 0 110 Median: : 2 5. Of the PRIA records you
received from pilots
employers in calendar year 2000, how many contained the level of detail
and candid evaluation
7. How many pilots worked for your air carrier as of that your air carrier
needed for hiring decisions?
December 31, 2000? ( Check one. ) N= 257
( Check one. ) N= 255
1. 63% 10 or fewer 1. 12% Does not apply: No PRIA records
received from employers in 2000
2. 31% 11 to 50 2. 5% All of the records
3. 4% 51 to 100 3. 13% Almost all
4. > 1% 101 to 500 4. 6% More than half
5. > 1% 501 to 1,000 5. 11% About half
6. 0% Over 1,000 6. 12% Less than half
7. > 1% Other ( Please describe. )
7. 34% Few/ None of the records 8. 5% Uncertain
9. 1% Other ( Please describe. )
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
8. Please rate the helpfulness of each of the following for helping you
understand the requirements of PRIA. ( Check one for each row. )
Very Moderately
Somewhat Not very
Do not
helpful helpful
helpful helpful
use
Uncertain
( 1) ( 2)
( 3) ( 4)
( 5)
( 6)
a. The FAA principal operations 24% 13% 22% 25% 13% 2%
inspector ( POI) for our air carrier
N= 254
b. The FAA Oklahoma City office 6% 13% 14% 28% 36% 4%
N= 253
c. FAA regional offices N= 253 7% 13% 13% 26% 38% 3% d. FAA headquarters
N= 247 3% 8% 10% 26% 47% 6% e. The FAA Advisory Circular for PRIA
11% 32% 32% 13% 10% 2%
N= 252
f. Our trade association ( ATA, Air Con, 30% 22% 15% 9% 24% 1%
AOPA, HAI, NATA, NACA, NBAA, RAA, etc. ) N= 253
g. Our air carrier s legal counsel N= 251 3% 8% 8% 12% 65% 5% h. You may
list other helpful sources below. N= 0
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
Providing PRIA information to other air carriers
9. For each calendar year from 1997 through 2000, please estimate the
number of PRIA requests received about your current or former pilots from
prospective employers. Please report the number of requests rather than
the number of pilots for whom you received requests. ( Enter number. If
none, enter 0. ) Number of
Calendar PRIA requests
year received by
your air carrier
a. 2000 N= 250 Range: 0 - 156 b. 1999 N= 239 Range: 0 156 c. 1998 N= 225
Range: 0 156 d. 1997 N= 216 Range: 0 - 156
10. What fee, if any, does your air carrier currently charge to provide a
pilot s PRIA information to other air carriers? ( Check one. ) N= 251
1. 94% Do not charge a fee
2. > 1% Copying costs depends on amount copied
3. 5% Standard amount per request 4. > 1% Other ( Please describe. )
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
11. 12. 13. 1. 2. a. b. a. b. PRIA information you requested in 2000
Did your air carrier hire any new pilots during calendar year 2000? (
Check one. ) 83% Yes
14. What percentage of your air carrier s pilots hired 15. Of the pilots
you hired in calendar year 2000, for
during calendar 2000 had experience as a military how many did you request
PRIA records from
pilot? ( Check one. ) N= 212
their previous employers? Reminder: You may not have requested this
information from 1. 53% None
employers such as the military, Part 91 operators, etc. ( Check one. ) N=
212
2. 19% 1% to 10% 1. 64% All pilots 3. 5% 11% to 20%
2. 18% Almost all 4. 3% 21% to 30%
3. 4% More than half 5. 4% 31% to 40%
4. 2% About half 6. 2% 41% to 50%
5. 2% Under half 7. > 1% 51% to 60%
6. 7% Few/ None of pilots 8. > 1% 61% to 70%
7. 2% Uncertain
9. > 1% 71% to 80% 8. 0% Other ( Please describe. )
10. 3% 81% to 90% 11. > 1% 91% to 95% 12. 5% 96% to 100% 13. 2% Uncertain
16. Of the pilots you hired in calendar year 2000, for 14. 0% Other (
Please describe. )
how many did you actually receive any records from their previous
employers? Reminder: You may not have received this information from
employers such as foreign carriers, bankrupt carriers, the military, Part
91 o erators, etc.
( Check one. ) N= 212
1. 34% All pilots 2. 32% Almost all 3. 9% More than half 4. 7% About half
5. 5% Under half 6. 10% Few/ None of pilots 7. 2% Uncertain
8. 0% Other ( Please describe. )
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
17. During calendar year 2000, how many FAA 18. During calendar year 2000,
for how many
responses to your air carrier s PRIA requests did National Driver Register
( NDR) requests did your
you receive within 30 days? ( Check one. ) N= 211
air carrier receive the response within 30 days of your initial request? (
Check one. ) N= 211
PRIA requests to FAA include the pilot s medical 1. 5% Does not apply: Did
not receive any
certificate, airman s certificates and ratings, and
NDR information in calendar year
enforcement history.
2000
PRIA requests to FAA exclude FOIA requests for accident and incident data
and additional
2. 38% All responses received in 30 days enforcement information.
3. 25% Almost all 1. 4% Does not apply: Did not receive any
FAA i formation i calendar year 2000
4. 4% More than half 2. 37% All responses received in 30 days
5. 7% About half 3. 29% Almost all
6. 7% Under half 4. 7% More than half
7. 10% Few/ None 5. 5% About half
8. 3% Uncertain
6. 3% Under half 9. 1% Other ( Please describe. )
7. 8% Few/ None 8. 5% Uncertain
9. > 1% Other ( Please describe. )
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
19. During calendar year 2000, how many of the PRIA responses from the
types of employers listed below did your air carrier receive within 30
days? Requests to the pilot s employers would include records of training,
proficiency, or other records from the places where the applicant has
worked as a pilot. ( Check one for each row. )
How many requests received within 30 days?
( Check one for each type of employer. )
Did not
More
make
Almost than
About Under
Few/
Type of employer
requests
All all
half half
half None
( 1)
( 2) ( 3)
( 4) ( 5)
( 6) ( 7)
a. Major passenger air carrier 78% 8% 4% 3% 2% > 1% 4%
N= 182
b. Regional passenger air carrier 73% 7% 7% 4% 2% 1% 4%
N= 177
c. Commuter passenger air 66% 11% 8% 4% 4% 1% 5%
carrier N= 183
d. On- demand ( non- scheduled) 16% 29% 22% 9% 12% 6% 6%
air carrier N= 197
e. Large cargo air carrier 79% 6% 4% 4% 1% 1% 5%
( Part 121) N= 178
f. Small cargo air carrier 46% 14% 18% 6% 7% 3% 6%
( Part 135) N= 190 g. Please describe others below. N= 214 ( 3% gave
comments)
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
Experiences in hiring pilots
20. At what point in the hiring process does your air carrier usually have
the PRIA records available for review? ( Check one. ) N= 212
1. > 1% Before deciding to interview a candidate 2. 5% After deciding to
interview a candidate 3. 16% Before extending a ( conditional) job offer
4. 31% After pilot accepts a ( conditional) job offer 5. 42% During our
pilot training program 6. 5% Other ( Please describe. )
7. 1% Other: After job offer As noted in chapter 1, footnote 9, data
results from our surveys of Part 121 and Part 135 carriers are reported
differently for the body of our report and for the two survey appendixes.
21. Because of PRIA information you received , how many pilots did your
air carrier decide not to hire during calendar year 2000? ( Enter number.
If none, enter 0. ) N= 208
_ _ _ _ _ _ 36_ _ _ _ _ _ _ _ _ _ _ pilots in 2000
If your answer to Question 21 is 0, please skip to Question 23.
22. Please indicate to what extent the following information obtained
under PRIA requests influenced your air carrier s decision to terminate
from training or not to hire these pilots in calendar year 2000. ( Check
one for each row. )
Major Moderate
Minor Not a
reason reason
reason reason
Uncertain
( 1) ( 2)
( 3) ( 4)
( 5)
a. FAA s records showed that the pilot had falsified 19% 6% 0% 69% 6%
information during the job application process.
N= 1
b. The employer s records showed that the pilot had 13% 0% 7% 67% 13%
falsified information during the job application process. N= 15
c. The pilot s FAA records showed enforcement 27% 20% 0% 47% 7%
actions against the pilot that made the pilot unacceptable for our air
carrier. N= 15
d. The employer s records of comments and 7% 29% 29% 29% 7%
evaluations, including those by a check airman, raised concerns about the
pilot s competency. N= 14
e. The pilot s training records showed a pattern of poor 29% 29% 7% 29% 7%
performance. N= 14
f. The pilot s records included disciplinary actions that 20% 27% 7% 40%
7%
made the pilot undesirable for employment. N= 15
g. The records showed circumstances of the pilot s 35% 29% 18% 12% 6%
departure from the former job that raised concerns.
N= 17
h. The pilot s driving records raised concerns. N= 15 7% 27% 7% 53% 7%
i. You may list other reasons below. N= 18 ( 6% gave comments)
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
23. 24. 25. 1. 2. 3. 4. 5. 6. 7. 1. 2. 1. 2. 3. 4. 5. 6. 7. PRIA does not
require the military to provide pilot records to air carriers. When your
air carrier hires pilots with military flying experience, what impact does
this exclusion have on your air carrier s ability to assess the quality of
those pilots? ( Check one. ) 36% No impact
3% Uncertain
N= 211
28% Yes
28. We are aware that the PRIA law ( 49 USC 44936) went into effect
without any implementing regulations and that it has been amended several
times. For this reason, we would appreciate your help in finding out
whether air carriers are aware of some of the details of this law. Please
indicate whether or not your air carrier is aware of each PRIA requirement
below. ( Check one for each row. )
Reminder: Your answers to this question, or any other, cannot be
associated with your air carrier because of our survey s procedures for
ensuring anonymity.
Aware of requirement?
( Check one for each row. )
Yes No
( 1) ( 2)
PRIA requirements for air carriers hiring pilots
a. The pilot must sign a consent form for FAA records to be released to
the 98% 2%
air carrier. N= 254
b. The pilot must sign a consent form for records to be released from the
98% 2%
employers where the applicant has worked as a pilot of a civilian or
public aircraft. N= 255
c. The pilot must sign a consent form for the release of driving records.
94% 6%
N= 255
d. The air carrier must give the pilot an opportunity to submit written
56% 44%
comments to correct any inaccuracies in the PRIA records before making a
final hiring decision. N= 255
e. Air carriers must restrict their use of a pilot s PRIA records to
decisions 75% 25%
made in the hiring process. N= 255
f. The air carrier must keep PRIA records confidential to protect a pilot
s 95% 5%
privacy. N= 255
g. The air carrier must ensure that only the group involved in the hiring
87% 12%
process sees the pilot s PRIA records and that they do not share the
information with any other individuals. N= 255
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
Aware of requirement?
( Check one for each row. )
Yes No
( 1) ( 2)
Requirements for responding to PRIA requests from other air carriers
a. The air carrier must provide copies of the pilot s flight records (
training, 90% 9%
proficiency, professional competence, drug and alcohol tests, etc. ) .
N= 253
b. The air carrier must provide the pilot s records within 30 days of 91%
9%
receiving a PRIA request from another air carrier. N= 254
c. The air carrier must notify the pilot in writing within 20 days that
the 36% 64%
pilot s records were requested. N= 253
d. The air carrier must notify the pilot in writing within 20 days that
the 47% 53%
pilot can make a written request for a copy of the records being furnished
to the potential employer. N= 251
e. If a pilot makes a written request to see the records being sent to a
73% 27%
potential employer, the air carrier must provide a co y of the records
within 30 days. N= 253
f. The air carrier must maintain appropriate pilot records for 5 years in
85% 15%
order to respond to PRIA requests for the pilots you employ or have
employed. ( Such records cover training, proficiency, professional
competence, and the results of drug and alcohol tests. ) N= 253
g. When responding to PRIA requests, air carriers should send records no
69% 31%
more than 5 years old. N= 253 Other PRIA requirements for air carriers
a. When a pilot makes a written request to review the PRIA records kept
65% 35%
on the pilot by a current or previous employer, the air carrier must allow
the pilot to review the records within 30 days. N= 252
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
29. How do you rate the need for clarification of the following issues
relating to federal requirements for hiring pilots? ( Check one for each
row. )
Need for clarification
Very Little or
Some Moderate
Great great
no need need
Need need
need
Uncertain
( 1) ( 2)
( 3) ( 4)
( 5) ( 6)
a. Whether our air carrier is subject to PRIA 63% 14% 9% 7% 5% 2%
requirements N= 252
b. Which records we must request from former 43% 16% 17% 15% 8% 2%
employers N= 254
c. How our air carrier should proceed when a 12% 15% 30% 24% 17% 2%
pilot s employer does not provide the records we request N= 254
d. Who is responsible for providing employer 23% 17% 24% 20% 10% 6%
training records when a third party conducts the training N= 254
e. How our air carrier should proceed when a 13% 15% 28% 23% 17% 4%
pilot s employer is no longer in business N= 254
f. How our air carrier should proceed if a pilot s 21% 11% 25% 21% 15% 8%
employer is located in a foreign country N= 252
g. What our air carrier should do if a state does not 15% 15% 25% 22% 17%
6%
provide the driving records we request N= 252
h. How long we should keep the PRIA 16% 12% 27% 23% 16% 6%
information on a pilot we do not hire N= 254
i. How long we should keep the PRIA 34% 15% 20% 17% 11% 3%
information on a pilot we do hire N= 254
j. How long records should be maintained once a 49% 12% 17% 13% 7% 2%
pilot has left our air carrier s employment
N= 253
k. Which disciplinary actions are related to the 18% 15% 24% 22% 17% 3%
individual s performance as a pilot and therefore should be provided to
air carriers interested in hiring our current or former pilots
N= 254
l. Which pilot records are related to the 24% 17% 22% 20% 13% 3%
individual s performance as a pilot and therefore should be rovided to air
carriers interested in hiring our current or former pilots
N= 253
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
Need for clarification
Very Little or
Some Moderate
Great great
no need need
Need need
need
Uncertain
( 1) ( 2)
( 3) ( 4)
( 5) ( 6)
m. Whether the pilot s PRIA records must be 26% 22% 23% 16% 10% 3%
stored separately from our air carrier s current employment records N= 254
n. Which people are allowed to see the PRIA 41% 21% 19% 11% 5% 3%
records as part of the hiring process N= 254
o. What we should do if a pilot challenges one of 15% 20% 30% 19% 12% 4%
the records in the pilot s PRIA files N= 253
p. How air carriers should handle pilot records 15% 16% 30% 19% 14% 6%
when a disciplinary action is resolved through a negotiated settlement N=
254
q. Whether our air carrier is allowed to charge a 32% 14% 24% 13% 13% 4%
fee for providing PRIA records N= 254 r. You may list other PRIA areas
that need clarification below. N= 258 ( 2% gave comments)
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
30. How do you rate the following proposals for changes to federal
regulations, activities, and laws relating to pilot hiring? ( Check one
for each row. )
Strongly Generally
Generally Strongly
support support
Neutral oppose
oppose
Uncertain
( 1) ( 2)
( 3) ( 4)
( 5) ( 6)
a. Eliminate PRIA requirements for 39% 19% 19% 13% 9% 2%
air carriers to conduct a National Driver Register search. N= 250
b. Have FAA include the driving 39% 23% 18% 10% 8% 2%
information from its medical files when responding to air carriers PRIA
requests. N= 251
c. Strengthen enforcement of the 13% 19% 36% 16% 15% 1%
requirement that air carriers must provide pilot records within 30 days.
N= 253
d. Provide more specific guidance on 36% 37% 20% 4% 3% > 1%
which types of pilot records should be provided to a prospective employer.
N= 253
e. Revise the PRIA Advisory Circular 50% 31% 15% 1% > 1% 2%
so that it is easier to understand.
N= 252
f. Create an FAA Web site with PRIA 49% 23% 18% 5% 4% > 1%
contacts for all air carriers. N= 252
g. Change the law to require Part 91 19% 13% 17% 15% 35% 2%
employers to maintain PRIA records for the pilots they employ.
N= 253
h. Change the law so that a pilot s 37% 28% 17% 7% 9% 1%
PRIA records from FAA include records of accidents and incidents caused by
pilot error. N= 253
i. Change the law so that a pilot s 31% 30% 20% 5% 11% 2%
PRIA records from FAA include open, reopened, and pending enforcement
cases. N= 253
j. Change the law so that any PRIA 12% 14% 26% 20% 27% > 1%
records provided by FAA include enforcement cases more than 5 years old.
N= 251
k. Update Part 121 regulations to 16% 18% 43% 5% 9% 9%
reflect PRIA requirements. N= 251
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
Strongly Generally
Generally Strongly
support support
Neutral oppose
oppose
Uncertain
( 1) ( 2)
( 3) ( 4)
( 5) ( 6)
l. Update Part 135 regulations to 20% 31% 25% 9% 13% 1%
reflect PRIA requirements. N= 253
m. Provide more guidance on how to 17% 32% 33% 9% 7% 1%
safeguard paper files containing a pilot s PRIA records. N= 253
n. Provide more guidance on how to 20% 29% 35% 8% 8% 1%
safeguard any electronic files used for a pilot s PRIA records. N= 251
o. Eliminate fees for PRIA requests 35% 19% 26% 9% 9% 2%
between air carriers. N= 252
p. Set a maximum fee for PRIA 29% 27% 25% 5% 10% 4%
requests between air carriers.
N= 252
q. Require the military to provide a 32% 22% 26% 5% 11% 2%
pilot s flight records. N= 253 r. Please list any other suggestions below.
N= 258 ( 7% gave comments)
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
31. Please add any comments you wish on the issues in this survey or on
other matters related to the Pilot Records Improvement Act ( PRIA) . N=
258 ( 24% gave comments)
Thank you very much for participating in our survey.
As noted in chapter 1, footnote 9, data results from our surveys of Part
121 and Part 135 carriers are reported differently for the body of our
report and for the two survey appendixes.
Appendi x V
Chart on Items Needing Clarification by FAA Source: GAO analysis of survey
data from Part 121 carriers.
Appendi x VI Overview of FAA Form 8060- 11
Air Carriers* Costs to Comply with PRIA in
Appendi x VII
2000 Part 135 carriers that requested PRIA files Part 121 carriers from
FAA Cost Carriers Percentage Carriers Percentage
$0 0 0 17 7 $1 - $1, 000 15 16 164 65 $1, 001 - $5,000 18 20 51 20 $5, 001
- $10, 000 18 20 10 4 $10,001 - $50,000 20 22 9 4 $50,001 - $100,000 12 13
0 0 $100, 001 - $1 million 8 9 0 0
Total 91 100 251 100
Source: GAO analyses of survey data from Part 121 and Part 135 carriers
that had requested PRIA files from FAA.
Appendi x VI II
GAO Contacts and Staff Acknowledgments GAO Contacts Gerald L. Dillingham,
Ph. D. (202) 512- 3650 Tammy Conquest (202) 512- 5234 Bonnie A. Beckett,
Ph. D. (202) 512- 6525
Staff In addition to those named above, Alan Belkin, Nancy Boardman,
Jeanine
Acknowledgments Brady, Stephen Brown, Elizabeth Eisenstadt, Fran
Featherston, Curtis Groves, David Hooper, Julian King, and Colleen
Phillips made significant
contributions to this report.
(390000)
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GAO United States General Accounting Office
Why GAO Did This Study
In 1996, Congress enacted the Pilot Records Improvement Act to keep unsafe
pilots out of the cockpits of commercial aircraft. GAO did this study to
determine (1) whether air carriers have complied with the act by
requesting and receiving key documents about pilots* qualifications,
performance, and training from the Federal Aviation Administration (FAA),
the National Driver Register (NDR), and other carriers and whether these
documents have been provided on time; (2) whether carriers are aware of
requirements for protecting pilots* rights; (3) what FAA has done to
oversee compliance with the act; and (4) whether carriers believe the act
has helped them make pilot- hiring decisions.
August 2002 AVIATION SAFETY Better Guidance and Training Needed on
Providing Files on Pilots* Background Information
This is a test for developing highlights for a GAO report. The full
report, including GAO's objectives, scope, methodology, and analysis, is
available at www. gao. gov/ cgi- bin/ getrpt? GAO- 02- 722. For additional
information about the report, contact Gerald L. Dillingham at (202) 512-
3650. To provide comments on this test highlights, contact Keith Fultz
(202- 512- 3200) or e- mail HighlightsTest@ gao. gov.
Highlights of GAO- 02- 722, a report to the Chairman and Ranking
Democratic Member, Subcommittee on Aviation, House Committee on
Transportation and Infrastructure.
What GAO Recommends
To promote greater awareness of and compliance with the act, GAO
recommends that the Secretary of Transportation direct the FAA
Administrator to develop clarifying guidance for carriers on the contents
of pilot records and on retaining the files of pilots hired, post
information on pilots* rights on FAA*s Web site, and incorporate the act*s
requirements into FAA inspectors* training and handbooks.
FAA agreed with GAO*s recommendations.
United States General Accounting Office
What GAO Found
GAO found, from analyzing FAA and NDR databases and from surveying air
carriers that had made at least one request to FAA for pilot records, that
compliance has increased since the act took effect in 1997, but
noncompliance is also occurring. For example, hiring carriers requested
and received records less often from other carriers than from FAA and NDR,
and other carriers provided records with more delays than the agencies.
(See figure below.) Until they receive the required records, hiring
carriers are not allowed to use pilots to fly passengers or cargo.
Carriers are not always aware of the act*s requirements for protecting
pilots* rights, especially of those for notifying pilots of requests for
their records and for allowing them to review and submit written
corrections before final hiring decisions are made. Pilots also lacked
awareness that they could request copies of their records from current as
well as former employers. However, if the records are inaccurate, the
opportunity for pilots to submit corrections does not come until after
hiring carriers have already received the records.
To oversee compliance with the act, FAA developed guidance but was slow to
update it after the act was amended and has not included information on
the act in the agency*s training or handbooks for inspectors. As a result,
carriers and pilots lack awareness of some provisions, and FAA inspectors
are not prepared or prompted to review compliance. FAA*s ability to
enforce compliance is limited because carriers are not required to retain
the files on pilots hired that FAA needs to monitor and enforce
compliance.
While finding pilot records helpful, carriers found them less helpful than
information from other sources, such as job interviews, flight
evaluations, and training programs. The carriers were divided in their
opinions on whether the records were worth the cost.
Percentage of Carriers Requesting and Receiving Pilot Records in 2000
Source: GAO analysis of survey responses from larger (Part 121) carriers.
G A O Accountability Integrity Reliability
Highlights
Page i GAO- 02- 722 Aviation Safety
Contents
Contents
Page ii GAO- 02- 722 Aviation Safety
Contents
Page iii GAO- 02- 722 Aviation Safety
Contents
Page iv GAO- 02- 722 Aviation Safety
United States General Accounting Office Washington, D. C. 20548
Page 1 GAO- 02- 722 Aviation Safety
A
August 30, 2002 Lett er
The Honorable John L. Mica Chairman The Honorable William O. Lipinski
Ranking Democratic Member Subcommittee on Aviation Committee on
Transportation and Infrastructure House of Representatives
In response to your request, this report discusses the implementation of
the Pilot Records Improvement Act of 1996. This report contains
recommendations to the Secretary of Transportation.
Unless you publicly announce its contents earlier, we plan no further
distribution of this report until 30 days from the date of this letter. At
that time, we will send copies to interested congressional committees; the
Secretary of Transportation; and the Administrator, Federal Aviation
Administration. We will also make copies available to others upon request.
In addition, this report will be available at no charge on the GAO Web
site at http:// www. gao. gov.
Please call me at (202) 512- 3650 if you or your staff have any questions
concerning this report. Major contributors to this report are listed in
appendix VIII. Gerald L. Dillingham, Ph. D. Director, Physical
Infrastructure Issues
Page 2 GAO- 02- 722 Aviation Safety
Executive Summary Page 3 GAO- 02- 722 Aviation Safety
Executive Summary Page 4 GAO- 02- 722 Aviation Safety
Executive Summary Page 5 GAO- 02- 722 Aviation Safety
Executive Summary Page 6 GAO- 02- 722 Aviation Safety
Executive Summary Page 7 GAO- 02- 722 Aviation Safety
Executive Summary Page 8 GAO- 02- 722 Aviation Safety
Page 9 GAO- 02- 722 Aviation Safety
Chapter 1
Chapter 1 Introduction
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Chapter 1 Introduction
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Chapter 1 Introduction
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Chapter 1 Introduction
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Chapter 1 Introduction
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Chapter 1 Introduction
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Chapter 1 Introduction
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Chapter 1 Introduction
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Page 21 GAO- 02- 722 Aviation Safety
Chapter 2
Chapter 2 Actions to Comply with Background Check Requirements Are
Increasing, but Compliance Is Not Always Complete or Timely
Page 22 GAO- 02- 722 Aviation Safety
Chapter 2 Actions to Comply with Background Check Requirements Are
Increasing, but Compliance Is Not Always Complete or Timely
Page 23 GAO- 02- 722 Aviation Safety
Chapter 2 Actions to Comply with Background Check Requirements Are
Increasing, but Compliance Is Not Always Complete or Timely
Page 24 GAO- 02- 722 Aviation Safety
Chapter 2 Actions to Comply with Background Check Requirements Are
Increasing, but Compliance Is Not Always Complete or Timely
Page 25 GAO- 02- 722 Aviation Safety
Chapter 2 Actions to Comply with Background Check Requirements Are
Increasing, but Compliance Is Not Always Complete or Timely
Page 26 GAO- 02- 722 Aviation Safety
Chapter 2 Actions to Comply with Background Check Requirements Are
Increasing, but Compliance Is Not Always Complete or Timely
Page 27 GAO- 02- 722 Aviation Safety
Chapter 2 Actions to Comply with Background Check Requirements Are
Increasing, but Compliance Is Not Always Complete or Timely
Page 28 GAO- 02- 722 Aviation Safety
Chapter 2 Actions to Comply with Background Check Requirements Are
Increasing, but Compliance Is Not Always Complete or Timely
Page 29 GAO- 02- 722 Aviation Safety
Chapter 2 Actions to Comply with Background Check Requirements Are
Increasing, but Compliance Is Not Always Complete or Timely
Page 30 GAO- 02- 722 Aviation Safety
Chapter 2 Actions to Comply with Background Check Requirements Are
Increasing, but Compliance Is Not Always Complete or Timely
Page 31 GAO- 02- 722 Aviation Safety
Chapter 2 Actions to Comply with Background Check Requirements Are
Increasing, but Compliance Is Not Always Complete or Timely
Page 32 GAO- 02- 722 Aviation Safety
Chapter 2 Actions to Comply with Background Check Requirements Are
Increasing, but Compliance Is Not Always Complete or Timely
Page 33 GAO- 02- 722 Aviation Safety
Chapter 2 Actions to Comply with Background Check Requirements Are
Increasing, but Compliance Is Not Always Complete or Timely
Page 34 GAO- 02- 722 Aviation Safety
Chapter 2 Actions to Comply with Background Check Requirements Are
Increasing, but Compliance Is Not Always Complete or Timely
Page 35 GAO- 02- 722 Aviation Safety
Chapter 2 Actions to Comply with Background Check Requirements Are
Increasing, but Compliance Is Not Always Complete or Timely
Page 36 GAO- 02- 722 Aviation Safety
Chapter 2 Actions to Comply with Background Check Requirements Are
Increasing, but Compliance Is Not Always Complete or Timely
Page 37 GAO- 02- 722 Aviation Safety
Page 38 GAO- 02- 722 Aviation Safety
Chapter 3
Chapter 3 Air Carriers Have Not Consistently Followed PRIA*s Requirements
for Protecting Pilots* Rights
Page 39 GAO- 02- 722 Aviation Safety
Chapter 3 Air Carriers Have Not Consistently Followed PRIA*s Requirements
for Protecting Pilots* Rights
Page 40 GAO- 02- 722 Aviation Safety
Chapter 3 Air Carriers Have Not Consistently Followed PRIA*s Requirements
for Protecting Pilots* Rights
Page 41 GAO- 02- 722 Aviation Safety
Chapter 3 Air Carriers Have Not Consistently Followed PRIA*s Requirements
for Protecting Pilots* Rights
Page 42 GAO- 02- 722 Aviation Safety
Chapter 3 Air Carriers Have Not Consistently Followed PRIA*s Requirements
for Protecting Pilots* Rights
Page 43 GAO- 02- 722 Aviation Safety
Chapter 3 Air Carriers Have Not Consistently Followed PRIA*s Requirements
for Protecting Pilots* Rights
Page 44 GAO- 02- 722 Aviation Safety
Chapter 3 Air Carriers Have Not Consistently Followed PRIA*s Requirements
for Protecting Pilots* Rights
Page 45 GAO- 02- 722 Aviation Safety
Chapter 3 Air Carriers Have Not Consistently Followed PRIA*s Requirements
for Protecting Pilots* Rights
Page 46 GAO- 02- 722 Aviation Safety
Page 47 GAO- 02- 722 Aviation Safety
Chapter 4
Chapter 4 FAA Oversight of PRIA Implementation Has Been Limited
Page 48 GAO- 02- 722 Aviation Safety
Chapter 4 FAA Oversight of PRIA Implementation Has Been Limited
Page 49 GAO- 02- 722 Aviation Safety
Chapter 4 FAA Oversight of PRIA Implementation Has Been Limited
Page 50 GAO- 02- 722 Aviation Safety
Chapter 4 FAA Oversight of PRIA Implementation Has Been Limited
Page 51 GAO- 02- 722 Aviation Safety
Chapter 4 FAA Oversight of PRIA Implementation Has Been Limited
Page 52 GAO- 02- 722 Aviation Safety
Chapter 4 FAA Oversight of PRIA Implementation Has Been Limited
Page 53 GAO- 02- 722 Aviation Safety
Chapter 4 FAA Oversight of PRIA Implementation Has Been Limited
Page 54 GAO- 02- 722 Aviation Safety
Chapter 4 FAA Oversight of PRIA Implementation Has Been Limited
Page 55 GAO- 02- 722 Aviation Safety
Chapter 4 FAA Oversight of PRIA Implementation Has Been Limited
Page 56 GAO- 02- 722 Aviation Safety
Chapter 4 FAA Oversight of PRIA Implementation Has Been Limited
Page 57 GAO- 02- 722 Aviation Safety
Page 58 GAO- 02- 722 Aviation Safety
Chapter 5
Chapter 5 Most Carriers Found PRIA Records Helpful but Were Divided on
Whether They Were Worth the Cost
Page 59 GAO- 02- 722 Aviation Safety
Chapter 5 Most Carriers Found PRIA Records Helpful but Were Divided on
Whether They Were Worth the Cost
Page 60 GAO- 02- 722 Aviation Safety
Chapter 5 Most Carriers Found PRIA Records Helpful but Were Divided on
Whether They Were Worth the Cost
Page 61 GAO- 02- 722 Aviation Safety
Chapter 5 Most Carriers Found PRIA Records Helpful but Were Divided on
Whether They Were Worth the Cost
Page 62 GAO- 02- 722 Aviation Safety
Chapter 5 Most Carriers Found PRIA Records Helpful but Were Divided on
Whether They Were Worth the Cost
Page 63 GAO- 02- 722 Aviation Safety
Chapter 5 Most Carriers Found PRIA Records Helpful but Were Divided on
Whether They Were Worth the Cost
Page 64 GAO- 02- 722 Aviation Safety
Chapter 5 Most Carriers Found PRIA Records Helpful but Were Divided on
Whether They Were Worth the Cost
Page 65 GAO- 02- 722 Aviation Safety
Chapter 5 Most Carriers Found PRIA Records Helpful but Were Divided on
Whether They Were Worth the Cost
Page 66 GAO- 02- 722 Aviation Safety
Chapter 5 Most Carriers Found PRIA Records Helpful but Were Divided on
Whether They Were Worth the Cost
Page 67 GAO- 02- 722 Aviation Safety
Chapter 5 Most Carriers Found PRIA Records Helpful but Were Divided on
Whether They Were Worth the Cost
Page 68 GAO- 02- 722 Aviation Safety
Chapter 5 Most Carriers Found PRIA Records Helpful but Were Divided on
Whether They Were Worth the Cost
Page 69 GAO- 02- 722 Aviation Safety
Chapter 5 Most Carriers Found PRIA Records Helpful but Were Divided on
Whether They Were Worth the Cost
Page 70 GAO- 02- 722 Aviation Safety
Page 71 GAO- 02- 722 Aviation Safety
Appendix I
Appendix I Fatal Aviation Accidents That Involved Pilots with Prior Safety
Problems Were Cited in Passing PRIA Legislation
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Appendix II
Appendix II Methodology
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Appendix II Methodology
Page 75 GAO- 02- 722 Aviation Safety
Appendix II Methodology
Page 76 GAO- 02- 722 Aviation Safety
Appendix II Methodology
Page 77 GAO- 02- 722 Aviation Safety
Appendix II Methodology
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Appendix II Methodology
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Appendix II Methodology
Page 80 GAO- 02- 722 Aviation Safety
Appendix II Methodology
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Appendix III
Page 83 GAO- 02- 722 Aviation Safety
Appendix III Survey of Part 121s: Pilot Records Improvement Act
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Appendix III Survey of Part 121s: Pilot Records Improvement Act
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Appendix III Survey of Part 121s: Pilot Records Improvement Act
Page 86 GAO- 02- 722 Aviation Safety
Appendix III Survey of Part 121s: Pilot Records Improvement Act
Page 87 GAO- 02- 722 Aviation Safety
Appendix III Survey of Part 121s: Pilot Records Improvement Act
Page 88 GAO- 02- 722 Aviation Safety
Appendix III Survey of Part 121s: Pilot Records Improvement Act
Page 89 GAO- 02- 722 Aviation Safety
Appendix III Survey of Part 121s: Pilot Records Improvement Act
Page 90 GAO- 02- 722 Aviation Safety
Appendix III Survey of Part 121s: Pilot Records Improvement Act
Page 91 GAO- 02- 722 Aviation Safety
Appendix III Survey of Part 121s: Pilot Records Improvement Act
Page 92 GAO- 02- 722 Aviation Safety
Appendix III Survey of Part 121s: Pilot Records Improvement Act
Page 93 GAO- 02- 722 Aviation Safety
Appendix III Survey of Part 121s: Pilot Records Improvement Act
Page 94 GAO- 02- 722 Aviation Safety
Appendix III Survey of Part 121s: Pilot Records Improvement Act
Page 95 GAO- 02- 722 Aviation Safety
Appendix III Survey of Part 121s: Pilot Records Improvement Act
Page 96 GAO- 02- 722 Aviation Safety
Appendix III Survey of Part 121s: Pilot Records Improvement Act
Page 97 GAO- 02- 722 Aviation Safety
Appendix III Survey of Part 121s: Pilot Records Improvement Act
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Appendix III Survey of Part 121s: Pilot Records Improvement Act
Page 99 GAO- 02- 722 Aviation Safety
Appendix III Survey of Part 121s: Pilot Records Improvement Act
Page 100 GAO- 02- 722 Aviation Safety
Page 101 GAO- 02- 722 Aviation Safety
Appendix IV
Appendix IV Survey of Part 135s: Pilot Records Improvement Act
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Appendix IV Survey of Part 135s: Pilot Records Improvement Act
Page 103 GAO- 02- 722 Aviation Safety
Appendix IV Survey of Part 135s: Pilot Records Improvement Act
Page 104 GAO- 02- 722 Aviation Safety
Appendix IV Survey of Part 135s: Pilot Records Improvement Act
Page 105 GAO- 02- 722 Aviation Safety
Appendix IV Survey of Part 135s: Pilot Records Improvement Act
Page 106 GAO- 02- 722 Aviation Safety
Appendix IV Survey of Part 135s: Pilot Records Improvement Act
Page 107 GAO- 02- 722 Aviation Safety
Appendix IV Survey of Part 135s: Pilot Records Improvement Act
Page 108 GAO- 02- 722 Aviation Safety
Appendix IV Survey of Part 135s: Pilot Records Improvement Act
Page 109 GAO- 02- 722 Aviation Safety
Appendix IV Survey of Part 135s: Pilot Records Improvement Act
Page 110 GAO- 02- 722 Aviation Safety
Appendix IV Survey of Part 135s: Pilot Records Improvement Act
Page 111 GAO- 02- 722 Aviation Safety
Appendix IV Survey of Part 135s: Pilot Records Improvement Act
Page 112 GAO- 02- 722 Aviation Safety
Appendix IV Survey of Part 135s: Pilot Records Improvement Act
Page 113 GAO- 02- 722 Aviation Safety
Appendix IV Survey of Part 135s: Pilot Records Improvement Act
Page 114 GAO- 02- 722 Aviation Safety
Appendix IV Survey of Part 135s: Pilot Records Improvement Act
Page 115 GAO- 02- 722 Aviation Safety
Appendix IV Survey of Part 135s: Pilot Records Improvement Act
Page 116 GAO- 02- 722 Aviation Safety
Appendix IV Survey of Part 135s: Pilot Records Improvement Act
Page 117 GAO- 02- 722 Aviation Safety
Appendix IV Survey of Part 135s: Pilot Records Improvement Act
Page 118 GAO- 02- 722 Aviation Safety
Appendix IV Survey of Part 135s: Pilot Records Improvement Act
Page 119 GAO- 02- 722 Aviation Safety
Appendix IV Survey of Part 135s: Pilot Records Improvement Act
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Page 121 GAO- 02- 722 Aviation Safety
Appendix V
Page 122 GAO- 02- 722 Aviation Safety
Appendix VI
Appendix VI Overview of FAA Form 8060- 11
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Appendix VI Overview of FAA Form 8060- 11
Page 124 GAO- 02- 722 Aviation Safety
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Appendix VII
Page 126 GAO- 02- 722 Aviation Safety
Appendix VIII
United States General Accounting Office Washington, D. C. 20548- 0001
Official Business Penalty for Private Use $300
Address Service Requested Presorted Standard
Postage & Fees Paid GAO Permit No. GI00
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