AC Tempplate, V. 9 58B 00

User Manual: 58B

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U.S. Department
of Transportation
Federal Aviation
Administration
Advisory
Circular
Subject: Voluntary Disclosure Reporting
Program Date: 4/29/09
Initiated by: AFS-230
AC No: 00-58B
Change:
1. PURPOSE. This advisory circular (AC) provides information and guidance material that
may be used by a certificate holder, qualified fractional ownership programs (as defined in
paragraph 4e), or a Production Approval Holder (PAH) operating under Title 14 of the Code of
Federal Regulations (14 CFR) when voluntarily disclosing to the Federal Aviation
Administration (FAA) apparent violations of those FAA regulations listed in paragraph 3. The
procedures and practices outlined in this AC can be applied to the maintenance, flight operations,
anti-drug and alcohol misuse prevention programs, and to the manufacturing functions of the
PAH’s organization. The procedures and practices outlined in this AC cannot be applied to those
persons who are required to report failures, malfunctions, and defects under 14 CFR part 21,
§ 21.3 and who do not make those reports in the timeframe required by the regulations.
2. CANCELLATION. AC 00-58A, Voluntary Disclosure Reporting Program, dated
September 8, 2006; Notice 8900.39, Requiring Appropriate 14 CFR Part 119 Corporate Officer
and FAA Office Manager Signatures for Voluntary Disclosure Reporting Program (VDRP),
dated 5/1/2008; and InFO 08021, New Guidance for Sign-off by Part 119 Designated
Management Personnel for Voluntary Disclosure Reporting Program (VDRP) Submissions,
dated 5/1/2008 are cancelled.
3. RELATED CFR REGULATIONS. Title 14 CFR parts 21, 39, 119, 121, 125, 133, 135,
137, 141, 142, 145, 147 and, for qualified fractional ownership programs operating under
part 91 subpart K, those portions of part 91 pertaining directly to the duties and responsibilities
of the program manager, as defined in part 91 subpart K or management specifications
(MSpecs).
a. Voluntary Disclosure for Violations of Title 49 of the Code of Federal Regulations
(49 CFR) Part 175. Voluntary disclosure of 49 CFR part 175 (HAZMAT) violations should be
accomplished in accordance with current edition AC 121-37, Voluntary Disclosure Reporting
Program—Hazardous Materials.
b. Voluntary Disclosure of Violations of Anti-Drug and Alcohol Misuse Prevention
Program Regulations under 14 CFR. Voluntary disclosure for violations of anti-drug and
alcohol misuse prevention program regulations must be reported to the Drug Abatement Division
Manager, AAM-800, 800 Independence Avenue S.W., Washington, D.C. 20591. Reports will be
processed in accordance with directions from that office.
AC 00-58B 4/29/09
Page 2 Par 3
c. Violation Exceptions. Except as specified in paragraph 12, the VDRP does not apply to
violations by individual airmen.
4. KEY TERMS. The following key terms and phrases are defined to ensure a standard
interpretation and understanding of the FAA’s voluntary disclosure policy:
a. Evidence. For the purpose of voluntary disclosure, evidence should generally be in the
form of written documentation or reports that support a certificate holder’s, qualified fractional
ownership programs, or PAH’s analysis of the disclosed apparent violation and the resulting
elements of the proposed comprehensive fix. Evidence generally comes from the following four
elements:
(1) Documents or manuals reviewed.
(2) Equipment examined.
(3) Activities observed.
(4) Interview data.
b. Comprehensive Fix. A comprehensive fix is an action, or actions, proposed by the
certificate holder, qualified fractional ownership program, or PAH, and accepted by the principal
inspector (PI), to preclude recurrence of the apparent violation that has been voluntarily
disclosed under this program. A schedule of the dates and events encompassed by the
comprehensive fix must be established and included in a letter of correction.
c. Satisfactory Fix. A satisfactory fix is a comprehensive fix in which all corrective
measures have been completed on schedule and are satisfactory to the FAA.
d. Principal Inspector (PI). Under the VDRP, PI refers to the appropriate maintenance,
avionics, operations inspector, or other designated FAA official of the program office
responsible for oversight of the area of noncompliance involved in the disclosure.
e. Fractional Ownership Programs. Fractional ownership programs are defined in part 91
subpart K and the associated MSpecs. Participation in the VDRP by a fractional ownership
program is limited by the following:
(1) Only program managers authorized in accordance with part 91 subpart K and
MSpecs, may participate in the VDRP.
(2) Voluntary disclosures of apparent violations by a fractional ownership program may
only be submitted by the program manager, or an authorized representative.
(3) Voluntary disclosures by fractional ownership programs are limited to apparent
violations pertaining directly to the duties and responsibilities of the program manager, as
defined in part 91 subpart K and the MSpecs.
4/29/09 AC 00-58B
f. Regulated Entity (RE). A regulated entity is any certificate holder, fractional ownership
program, or PAH, authorized to submit voluntary disclosures under the VDRP.
5. BACKGROUND. Civil penalties, under the FAA’s enforcement program, have always been
considered a means to promote compliance with the FAA’s regulations, not an end in
themselves. In addition to the deterrence achieved by the appropriate use of civil penalties, the
public interest is also served by positive incentives to promote and achieve compliance. Indeed,
the FAA believes that aviation safety is well served by incentives for certificate holders,
qualified fractional ownership programs, and PAHs to identify and correct their own instances of
noncompliance and to invest more resources in efforts to preclude their recurrence. The FAA’s
policy of forgoing civil penalty actions when one of these entities detects violations, promptly
discloses the violations to the FAA, and takes prompt corrective action to ensure that the same or
similar violations do not recur is designed to encourage compliance with the FAA’s regulations,
foster safe operating practices, and promote the development of Internal Evaluation Programs
(IEPs).
6. DISCUSSION.
a. IEPs. Certificate holders, qualified fractional ownership programs, and PAHs are
encouraged, but not required, to develop IEPs that continually monitor company policies and
procedures and ensure that the highest level of safety and security compliance is maintained.
They may voluntarily disclose apparent violations of 14 CFR covered by this program in
accordance with the procedures in this AC even though an internal evaluation program has not
been established. Guidance on IEPs is contained in the current edition of AC 120-59A, Air
Carrier Internal Evaluation Programs.
b. Three Appendices. This AC is divided into the main body which addresses issues
common to all REs utilizing the VDRP, and three appendices, with each appendix addressing
application of the VDRP to differing groups of REs. This separation by appendices is necessary
due to differences in the applicable procedures. The groups and their respective appendices are
as follows:
(1) Appendix 1 is applicable to air carriers certificated under 14 CFR part 119 and
operating under 14 CFR parts 121 and 135. All of the entities assigned to Appendix 1 will utilize
the Web-based VDRP system.
(2) Appendix 2 is applicable to those other REs authorized to utilize the Web-based
VDRP system who are not air carriers. Those other REs will be listed on the VDRP Home Page
at: http://av-info.faa.gov/vdrp.
(3) Appendix 3 is applicable to those remaining REs who are not yet authorized to utilize
the Web-based VDRP system, but may still participate in the VDRP through the legacy paper-
based program.
7. VOLUNTARY DISCLOSURE POLICY.
a. Violation Sharing. The FAA believes that the open sharing of apparent violations and a
cooperative as well as an advisory approach to solving problems will enhance and promote
Par 4 Page 3
AC 00-58B 4/29/09
aviation safety. Certificate holders, qualified fractional ownership programs, and PAHs will
receive a letter of correction in lieu of civil penalty action for covered instances of
noncompliance that are voluntarily disclosed to the FAA in accordance with the procedures set
forth in this AC.
b. Violation Evaluation. In evaluating whether an apparent violation is covered by this
policy, the FAA will ensure that the following five conditions are met:
(1) The certificate holder, qualified fractional ownership program, or PAH has notified
the FAA of the apparent violation immediately after detecting it and before the Agency has
learned of it by other means.
(2) The apparent violation was inadvertent.
(3) The apparent violation does not indicate a lack, or reasonable question, of
qualification of the certificate holder, qualified fractional ownership program, or PAH.
(4) Immediate action, satisfactory to the FAA, was taken upon discovery to terminate the
conduct that resulted in the apparent violation.
(5) The certificate holder, qualified fractional ownership program, or PAH has developed
or is developing a comprehensive fix and schedule of implementation satisfactory to the FAA.
The comprehensive fix includes a followup self-audit to ensure that the action taken corrects the
noncompliance. This self-audit is in addition to any audits conducted by the FAA.
8. LEGAL ENFORCEMENT ACTION. Except as specified in the subparagraphs a. and b.
below, the FAA ordinarily will not forgo legal enforcement action if the certificate holder,
fractional ownership program, or PAH informs the FAA of the apparent violation during, or in
anticipation of, an FAA investigation/inspection or in association with an accident or incident.
a. Exceptions-Aviation Safety Action Program (ASAP) Report. If the FAA has learned
of an apparent violation by a certificate holder, fractional ownership program, or PAH from an
ASAP report as described in the current edition of AC 120-66, Aviation Safety Action Program
(ASAP), a voluntary disclosure can still be accepted by the FAA, even though the FAA has
already learned of the violation from the ASAP.
b. Exceptions-Joint Audit. Similarly, if a regulated entity voluntarily agrees to conduct a
joint audit (inspection) with the FAA during which an apparent violation is discovered either by
the company or FAA members of the audit (inspection) team, the FAA may accept a voluntary
disclosure submitted by the company, even though the FAA has already learned of the apparent
violation during the course of the joint audit (inspection).
9. REPEATED VIOLATION. If a repeated violation occurs, notwithstanding the fact that a
comprehensive fix was satisfactorily completed and followed, the procedures outlined in this AC
may apply to the disclosure of the repeated violation. Upon consideration of the facts and
circumstances surrounding the repeated violation, the FAA will determine on a case-by-case
basis whether a repeated violation will be covered under this policy. REs and PIs are encouraged
to evaluate the systemic issues and circumstances surrounding each apparent violation. This is
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4/29/09 AC 00-58B
particularly important when citing a common regulation. Depending upon the specific
circumstances associated with the event, citations of a common regulation may not necessarily
be indicative of a common systemic failure.
10. CLOSED CASE: CONDITIONS FOR REOPENING. If, following FAA closure of the
investigative package resulting from a voluntary disclosure, the same or similar violations are
discovered to have occurred prior to submission of the associated voluntary disclosure, the FAA
does not reopen the case unless it determines that the pertinent regulated entity failed to comply
with all the elements of the comprehensive fix agreed upon by the FAA and the entity.
11. DISPUTE RESOLUTION. When disputes occur regarding the acceptance of a proposed
comprehensive fix, or a modification thereto before the fix is considered satisfactory, the PI and
the pertinent regulated entity may request that the issue be resolved at the next level of
management within the FAA. This procedure will provide for an independent assessment of the
areas in disagreement.
12. SEPARATE ACTIONS AGAINST AIRMEN OR OTHER INDIVIDUAL AGENTS.
a. Voluntary Disclosure Application. The voluntary disclosure policy applies to individual
airmen or other agents of an employing certificate holder, fractional ownership program, or PAH
only when all of the following occur:
(1) The apparent violation involves a deficiency of the employing entity’s practices or
procedures that causes the employing certificate holder, fractional ownership program, or PAH
to be in violation of a covered violation of an FAA regulation.
(2) The airman or other agent of the employing entity, while acting on behalf of the
employing entity, inadvertently violates the FAA’s regulations as a direct result of a deficiency
of the employing entity that causes the employing entity to be in violation of the regulations.
(The voluntary disclosure policy does not apply to the airman or other agent when his or her
apparent violation is the result of actions unrelated to the employing entity’s deficiency).
(3) The airman or other agent immediately makes the report of his or her apparent
violation to the employing entity.
(4) The employing certificate holder, fractional ownership program, or PAH immediately
notifies the FAA of both the airman or other agent’s apparent violation and the apparent
deficiency in its practice or procedures.
b. Procedures if Conditions are Met. When all the aforementioned conditions are met, a
separate EIR is opened for the individual and closed with no more than administrative action in
accordance with the current edition of FAA Order 2150.3, Compliance and Enforcement
Program.
c. Procedures if Conditions Are Not Met. If all the aforementioned conditions are not
met, the PI will review all facts associated with the case and determine what action is appropriate
for individual airmen or other agents of the employing entity.
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AC 00-58B 4/29/09
d. Application of this Provision. This provision does not apply to matters concerning
qualifications to hold an airman certificate.
e. Special Provisions. Special provisions exist for apparent violations by certificate holders,
fractional ownership programs, or a PAH, when a voluntary disclosure is made based on
information in an ASAP report. In such cases, the FAA may, at its sole discretion, accept the
corrective action recommended by an ASAP event review committee (ERC) for an accepted
ASAP report as the comprehensive fix for the voluntary disclosure. This is acceptable when the
following conditions all apply (even when an apparent employee qualification or competency
issue is involved):
(1) The FAA determines that the violation is due entirely to the actions of the
employee(s) and not to a systematic or procedural deficiency of the company.
(2) The employee completes the corrective action recommended by the ASAP ERC to
the satisfaction of the FAA.
13. APPLICABILITY OF THE FREEDOM OF INFORMATION ACT (FOIA) TO SELF-
DISCLOSURE RECORDS. Records submitted to the FAA for review pursuant to this
voluntary self-disclosure program, including information submitted using the Web-based VDRP
tool (Appendix 1), are protected from release to the public in accordance with the provisions of
part 193 and FAA Order 8000.89, Designation of Voluntary Disclosure Reporting Program
(VDRP) Information as Protected from Public Disclosure under 14 CFR Part 193.
ORIGINAL SIGNED by
John M. Allen
Director, Flight Standards Service
Page 6 Par 12
4/29/09 AC-0058B
Appendix 1
APPENDIX 1. VOLUNTARY DISCLOSURE REPORTING PROGRAM (VDRP) FOR
AIR CARRIERS
Users authorized under this Appendix must be certificated under Title 14 of the Code of Federal
Regulations (14 CFR) part 119 for operations under 14 CFR part 121 and/or part 135.
1. ACCESS TO THE VDRP WEB-BASED SYSTEM. Access to the Web-based system
requires assignment of a login identification and a password, which are obtained via the
following means:
a. Air Carrier Representatives. Users named by an air carrier to represent the company on
voluntary disclosure issues, will be added to the VDRP Web-based system by a principal
inspector (PI) assigned certificate responsibilities for that air carrier. Each authorized
representative will be issued a unique login identification and password for access to the system.
Refer to VDRP User Guide at: https://av-info.faa.gov/VDRP/UserGuide.pdf or, contact VDRP
Help Desk at (866) 285-4942 for additional information.
b. Federal Aviation Administration (FAA) Personnel Access. FAA personnel may obtain
access to the system via one of the following means:
(1) PIs are automatically added to the VDRP system when the automated Operations
Safety System (OPSS) recognizes the individual as a PI assigned to that regulated entity.
(2) FAA personnel not assigned as a PI who require access to the system will be added to
the system by a PI, utilizing the “Add User” functionality.
c. VDRP System Guidance. The VDRP User Guide may be found in the VDRP User
Guide which can be accessed at: https://av-info.faa.gov/VDRP/UserGuide.pdf. Additional
assistance may be obtained via telephone from the VDRP Help Desk at (866) 285-4942.
2. THE SIX STAGES OF THE VDRP. The Web-based VDRP employs a six stage process.
Responsibility for each such stage is assigned either to the air carrier or the FAA, as described
below. Except as specified in this AC, the voluntary disclosure policy applies only when
notification of an apparent violation is made to the FAA by the certificate holder, immediately
after the apparent violation has been discovered by that regulated entity, and before the FAA
learns of the apparent violation by some other means.
a. Air Carrier Requirements. Air Carriers certificated under part 119 are required to
utilize the Web-based VDRP system for submitting voluntary disclosures to the FAA.
b. Disclosure Notification. Notification of a disclosure to the FAA will normally be made
via the Web-based system, unless extenuating circumstances prevent initial notification using
that venue.
c. Web-based VDRP System Provisions. The Web-based VDRP system contains
provisions for indicating that the notification process was initiated via another media. When
acceptable to the PI, initial notice of a voluntary disclosure may be submitted orally, via a written
hardcopy, or by electronic copy, provided the air carrier enters the initial notification data via the
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AC 00-58B 4/29/09
Appendix 1
Web-based VDRP system within 72 hours of the original notification. Compliance with the
10 or 30-day limit for submission of the written report, as described in Stage III below, will be
based on the date of the original notification, regardless of the submission means or media.
3. STAGE I: NOTIFICATION BY THE CERTIFICATE HOLDER OF AN APPARENT
VIOLATION. When the certificate holder notifies the FAA of an apparent violation, contact
must be made with, or directed to, the appropriate PI. The notification requirement is
automatically met when the disclosure is submitted via the Web-based VDRP system as all PI’s
for that certificate are notified when a disclosure is submitted. However, if the certificate holder
submits the initial notification via alternative media, as authorized in paragraph 4 below, the
disclosure must be submitted to the appropriate PI. It is FAA policy that initial notification
should be accomplished on a timely basis, ordinarily within 24 hours of the discovery of the
apparent violation. However, an inspector may accept disclosures that exceed the 24 hour policy
when the inspector determines that a later submission is justified based on the specific
circumstances, and in view of those circumstances, the submission is still considered timely. For
example, a voluntary disclosure based on a company violation revealed in an Aviation Safety
Action Program (ASAP) report may require more that 24 hours from the submission of that
ASAP report in order for the responsible company entity to become aware of the information in
the report and to initiate a voluntary disclosure. The FAA retains sole discretion in determining
whether a voluntary disclosure received later than 24 hours after discovery of the violation is
timely. The certificate holder should therefore not delay notification for any reason, and should
address, to the maximum extent possible, the following items:
a. Brief Description of Apparent Violation. A brief description of the apparent violation,
including an estimate of the duration of time that it remained undetected, as well as how and
when it was discovered.
b. Verification of Cease of Noncompliance. Verification that noncompliance ceased after
it was identified.
c. Brief Description of Immediate Action. A brief description of the immediate action
taken after the apparent violation was identified, the immediate action taken to terminate the
conduct that resulted in the apparent violation, and the person responsible for taking the
immediate action.
d. Verification of Evaluation. Verification that an evaluation is underway to determine:
• If there are any systemic problems, and
• The corrective steps necessary to prevent the apparent violation from recurring.
e. Identification of Responsible Person. Identification of the person responsible for
preparing the comprehensive fix.
f. Acknowledgement of a Written Report. Acknowledgment that a written report will be
provided to the PI within 10 working-days
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4/29/09 AC 00-58B
Appendix 1
g. Initial Notification Submission by Management Officials. The initial notification of a
voluntary disclosure must be submitted by one of the management officials specified in part 119,
§ 119.65, or § 119.69, as appropriate, or in accordance with paragraph 3h below.
h. Initial Notification Submission by Authorized Employees. The initial notification can
be submitted by an employee authorized by the airline to accomplish initial notification as long
as that employee includes a letter signed by one of the management officials specified in
§ 119.65 or § 119.69, as appropriate. That letter must stipulate that:
• The corporate official is aware of the disclosure,
• The company took immediate action to cease the violation, and
• The company has developed, or is developing, a proposed comprehensive fix for
FAA consideration to prevent future reoccurrences of the violation, as provided by
this AC.
NOTE: The Web-based VDRP allows upload of documents (photos, text
documents, letters, etc.) by the regulated entity in Stages I and III and upload
by the FAA in Stages II, III, IV, V and VI, to enable the attachment of
whatever documents may be required to support their submissions.
4. STAGE II: FAA RESPONSE TO CERTIFICATE HOLDER. The PI will review the
Web-based submission from the air carrier and respond in a timely manner. If the original
submission from the regulated entity was made via an alternative media (e.g., telephone, etc.),
the PI may respond via an alternative means, but must also respond to the subsequent Web-based
submission by the air carrier.
a. PI Review. The PI’s review of the disclosure shall, to the extent possible, confirm the
submission meets the following requirements:
(1) The air carrier has notified the FAA of the apparent violation immediately after
detecting it and before the Agency has learned of it by other means.
(2) The apparent violation was inadvertent.
(3) The apparent violation does not indicate a lack, or reasonable question, of
qualification of the air carrier.
(4) Immediate action, satisfactory to the FAA, was taken upon discovery to terminate the
conduct that resulted in the apparent violation.
(5) The air carrier certificate holder has developed, or is developing, a comprehensive fix
and schedule of implementation satisfactory to the FAA. The comprehensive fix includes a
followup self-audit to ensure that the action taken corrects the noncompliance. This self-audit is
in addition to any audits conducted by the FAA.
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AC 00-58B 4/29/09
Appendix 1
(6) The initial notification of a voluntary disclosure was submitted by one of the
management officials specified in § 119.65 or § 119.69, as appropriate; or, the initial notification
was submitted by an employee authorized by the airline to accomplish initial notification and
includes a letter which meets the requirements set forth in paragraph 3h of this appendix.
b. PI Completion of the Review. Once the PI completes the review of the voluntary
disclosure submission, he/she makes a determination to accept the disclosure, return it for
editing, or find it invalid.
(1) Acceptance: If the PI elects to accept the disclosure, the inspector completes the
required Stage II entries in the Web-based VDRP and submits his/her input. Upon submission by
the PI, the VDRP system will alert the Office Manager, via email, that the file is awaiting his or
her review.
(2) Return for Edit: If the PI finds the disclosure does not contain sufficient information
to accept the disclosure, the PI has the option of returning the disclosure to the RE for editing.
Upon selection of the “send back” button and submission by the PI, the VDRP system notifies
the RE of the determination via email and returns the case to Stage I, pending resubmission by
the RE.
(3) Rejection/Invalid: If the PI finds the disclosure does not meet the requirements set
forth in this Advisory Circular for acceptance, or it has been determined that no violation
occurred, the PI selects “No” in response to the question, “Is this a valid self-disclosure?”. Upon
submission by the PI, the RE is notified of that determination by email. When found to be
invalid, the case does not advance and is not assigned an EIR number.
c. Office Manager Review of PI Determination. The Office Manager will review the PI’s
determination to accept the voluntary disclosure.
(1) If the Office Manager indicates concurrence with the PI’s acceptance determination
and selects, “Submit,” Stage II is concluded and the record will advance into Stage III, which
triggers automated email notification of the RE of the acceptance. It also triggers the VDRP
system to open an Enforcement Investigative Report (EIR), with automatic assignment of an EIR
number to the report.
(2) If the Office Manager indicates nonconcurrence with the PI’s acceptance
determination, the case will be referred back to the PI for reconsideration with whatever
comments have been entered by the Office Manager. The case will not advance to Stage III until
the Office Manager submits concurrence with the PI’s determination.
NOTE: If, at any time subsequent to acceptance of the disclosure, the FAA
becomes aware that the disclosure did not meet the requirements set forth
for acceptance under the VDRP, the acceptance may be withdrawn. In such
cases, as well in those cases where it is subsequently determined that a
violation did not occur, the web-based system provides the option of
“rescinding” a case, which closes the file without action within the VDRP. If
the certificate holding office has sufficient evidence to proceed with
enforcement action, independent of the materials provided by the air carrier
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Appendix 1
Page 5
as part of its submission under VDRP, enforcement action should be initiated
in accordance with the procedures set forth in the current edition of FAA
Order 2150.3.
5. STAGE III: WRITTEN REPORT OF THE AIR CARRIER’S APPARENT
VIOLATION.
a. Written Report. The written report should be submitted by the air carrier, to the PI, via
the web-based VDRP system, within 10 working-days from the date the disclosure was
submitted to the FAA. This report must contain a detailed description of the proposed
comprehensive fix, outlining the planned corrective steps, the responsibilities for implementing
those corrective steps, and a time schedule for completion of the fix. If a proposed
comprehensive fix is not fully developed within 10 working-days from the date the disclosure
was submitted to the FAA, the regulated entity should provide at least an overview of its
comprehensive fix plans in a written report submitted within 10 working-days after the initial
notification to the FAA was made. In any event, a detailed description of the comprehensive fix
should be submitted to the FAA within 30 calendar-days after initial notification.
b. Required Input. The VDRP web-based system requires the input of the following
information in the Written Report Stage:
(1) A list of the specific FAA regulations that may have been violated.
(2) A description of the apparent violation, including the duration of time it remained
undetected, as well as how and when it was detected.
(3) A description of the immediate action taken to terminate the conduct that resulted in
the apparent violation, including when it was taken, and who was responsible for taking the
action.
(4) An explanation that shows the apparent violation was inadvertent.
(5) Evidence that demonstrates the seriousness of the apparent violation and the regulated
entity’s analysis of that evidence.
(6) Completion of a Risk Assessment Matrix to aid in evaluating the significance of the
event.
(7) A detailed description of the proposed comprehensive fix, outlining the planned
corrective steps, the responsibilities for implementing those corrective steps, and a time schedule
for completion of the fix and the subsequent self-audit.
(8) Identification of the company official(s) responsible for monitoring the
implementation and completion of the comprehensive fix and the self-audit.
6. STAGE IV: WRITTEN REPORT REVIEW BY THE FAA. The FAA works with the
certificate holder to ensure that the regulated entity has identified any root causes and systemic
issues which led to the apparent violation. In this stage, the PI is also tasked with completing a
AC 00-58B 4/29/09
Appendix 1
Risk Assessment Matrix to aid in evaluating the significance of the event and the proposed
comprehensive fix. This collaboration helps to ensure that the corrective actions contained in the
comprehensive fix are acceptable to the FAA.
NOTE: Should investigation of the apparent violation result in the
determination that no violation has occurred, the EIR may be closed by
rescinding the file and providing an explanation in the provided comment
box. When submitted, the user is provided a warning that submitting this
action (rescinding the file) will close the case and terminate the investigation.
If the inspector confirms the rescission, the case is closed in VDRP on that
date and will close in EIS ten (10) days later, with the original date of closure
recorded in EIS. The ten day delay is provided to enable the FAA to re-open
the file within that ten day “window” if deemed necessary.
7. STAGE V: IMPLEMENTATION OF A COMPREHENSIVE FIX AND FAA
SURVEILLANCE.
a. Implementation Period. During the implementation period, the FAA and the pertinent
regulated entity should continue to work together. The FAA may advise and assist the entity in
correcting any identified systemic problems. Changes will be made to the proposed
comprehensive fix when the need is identified. Upon determining that the initial implementation
of the proposed comprehensive fix is satisfactory, the PI may issue a letter of correction in
Stage V. Alternatively, the PI may elect instead to issue the letter of correction in Stage VI, if
deemed appropriate. If the letter of correction is issued in Stage V, and subsequent changes are
made to the Comprehensive Fix, the PI shall issue and upload a revised letter of correction in
Stage VI which reflects the letter of correction as implemented.
b. Corrective Steps. The FAA monitors the implementation of the corrective steps.
Throughout the implementation period, the FAA assesses the pertinent regulated entity’s
corrective efforts and top management’s awareness of these efforts. If, during this period, the
FAA determines that the steps taken by the entity are not those documented in the
comprehensive fix and acceptable corrective action by the RE is not forthcoming, the letter of
correction may be rescinded, and appropriate legal enforcement action initiated.
8. STAGE VI: INSPECTOR SIGNOFF. At the conclusion of the implementation period, the
PI and the certificate-holding Office Manager will make a final assessment. Consultation with
regional specialists, legal counsel, or other FAA personnel may be accomplished when deemed
appropriate by the PI or the Office Manager.
a. Stage VI Completion. If all elements of the comprehensive fix have been satisfactorily
accomplished, including the Air Carrier’s self-audit, the PI will submit the required entries in the
Web-based system for Stage VI completion.
b. Stage VI Submission. Upon Stage VI submission by the PI, the VDRP system will
notify the Office Manager via email that the file is awaiting the manager’s review. The Office
Manager will then log into the VDRP system, review the VDRP file, and assess the adequacy of
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Appendix 1
Page 7 (and 8)
the Comprehensive Fix and it’s implementation. The Office Manager must decide whether to
concur with the PI’s determination that the Comprehensive Fix was satisfactorily accomplished.
(1) If the Office Manager concurs with the PI’s determination, Stage VI is concluded
upon submission of the manager’s concurrence (Selection of the, “Submit” button signals
concurrence), and the VDRP system will automatically generate the Form 2150-5 as well as
close the associated EIR record in the Enforcement Information System (EIS).
(2) If the Office Manager wishes to indicate nonconcurrence with the PI’s determination,
the Office Manager will offer any comments in the comment area provided for that purpose. The
Manager will then select the, “Return”, button. Upon selection of the “Return” button, the case
will be referred back to the PI for reconsideration with whatever comments were entered by the
Office Manager. The case will not advance out of Stage VI until it is re-submitted by the PI and
the Office Manager submits his/her concurrence.
4/29/09 AC 00-58B
Appendix 2
APPENDIX 2. VOLUNTARY DISCLOSURE REPORTING PROGRAM (VDRP) FOR
REGULATED ENTITIES, OTHER THAN AIR CARRIERS, AUTHORIZED TO
UTILIZE THE WEB-BASED VDRP
This Appendix is directed to those regulated entities (RE), other than air carriers, which are
required to utilize the Web-based VDRP system. A list of those entities may be found on the
VDRP home page at: https://av-info.faa.gov/vdrp.
1. ACCESS TO THE VDRP WEB-BASED SYSTEM. Access to the Web-based system
requires assignment of a login identification and a password, which are obtained via the
following means:
a. RE Representatives. Representatives named by the RE to represent the company on
voluntary disclosure issues will be added to the VDRP Web-based system by a principal
inspector (PI) assigned certificate responsibilities for that RE. Each authorized representative
will be issued a unique login identification and password for access to the system. Refer to
VDRP User Guide at: https://av-info.faa.gov/VDRP/UserGuide.pdf or, contact VDRP Help Desk
at (866) 285-4942 for additional information.
b. Federal Aviation Administration (FAA) Personnel Access. FAA personnel may obtain
access to the system via one of the following means:
(1) PIs are automatically added to the VDRP system when the automated Operations
Safety System (OPSS) recognizes the individual as a PI assigned to that RE.
(2) FAA personnel not assigned as a PI who require access to the system will be added to
the system by a PI, utilizing the “Add User” functionality.
c. VDRP System Guidance. The VDRP User Guide may be accessed and downloaded at:
https://av-info.faa.gov/VDRP/UserGuide.pdf. Additional assistance may be obtained via
telephone from the VDRP Help Desk at (866) 285-4942.
2. THE SIX STAGES OF THE VDRP. The Web-based VDRP employs a six-stage process.
Responsibility for each such stage is assigned either to the RE or the FAA, as described below.
Except as specified in this AC, the voluntary disclosure policy applies only when notification of
an apparent violation is made to the FAA by the RE, immediately after the apparent violation has
been discovered by that entity, and before the FAA learns of the apparent violation by some
other means.
a. RE Requirements. Those REs to which this appendix applies, are required to utilize the
Web-based VDRP system for submitting voluntary disclosures to the FAA.
b. Disclosure Notification. Notification of a disclosure to the FAA will normally be made
via the Web-based system, unless extenuating circumstances prevent initial notification using
that venue.
c. Web-based VDRP System Provisions. The Web-based VDRP system contains
provisions for indicating that the notification process was initiated via another media. When
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acceptable to the PI, initial notice of a voluntary disclosure may be submitted orally, via a written
hardcopy, or by electronic copy provided the RE enters the initial notification data via the Web-
based VDRP system within 72 hours of the original notification. Compliance with the 10-
or 30-day limit for submission of the written report, as described in Stage III below, will be
based on the date of the original notification, regardless of the submission means or media.
3. STAGE I: NOTIFICATION TO THE FAA OF AN APPARENT VIOLATION. When
the certificate holder notifies the FAA of an apparent violation, contact must be made with, or
directed to, the appropriate PI. The notification requirement is automatically met when the
disclosure is submitted via the Web-based VDRP system as all PI’s for that certificate are
notified when a disclosure is submitted. However, if the certificate holder submits the initial
notification via alternative media, as authorized in paragraph 4 below, the disclosure must be
submitted to the appropriate PI. It is FAA policy that initial notification should be accomplished
on a timely basis, ordinarily within 24 hours of the discovery of the apparent violation. However,
an inspector may accept disclosures that exceed the 24 hour policy when the inspector
determines that a later submission is justified based on the specific circumstances, and in view of
those circumstances, the submission is still considered timely. For example, a voluntary
disclosure based on a company violation revealed in an Aviation Safety Action Program (ASAP)
report may require more that 24 hours from the submission of that ASAP report in order for the
responsible company entity to become aware of the information in the report and to initiate a
voluntary disclosure. The FAA retains sole discretion in determining whether a voluntary
disclosure received later than 24 hours after discovery of the violation is timely. The certificate
holder should therefore not delay notification for any reason, and should address, to the
maximum extent possible, the following items:
a. Brief Description of Apparent Violation. A brief description of the apparent violation,
including an estimate of the duration of time that it remained undetected, as well as how and
when it was discovered.
b. Verification of Cease of Noncompliance. Verification that noncompliance ceased after
it was identified.
c. Brief Description of Immediate Action. A brief description of the immediate action
taken after the apparent violation was identified, the immediate action taken to terminate the
conduct that resulted in the apparent violation, and the person responsible for taking the
immediate action.
d. Verification of Evaluation. Verification that an evaluation is underway to determine:
• If there are any systemic problems, and
• The corrective steps necessary to prevent the apparent violation from recurring.
e. Identification of Person Responsible for Preparation. Identification of the person
responsible for preparing the comprehensive fix.
f. Acknowledgement of a Written Report. Acknowledgment that a written report will be
provided to the PI within 10 working-days.
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NOTE: The Web-based VDRP allows upload of documents (photos, text
documents, letters, etc.) by the RE at Stage I and Stage III and upload by the
FAA in Stages II, III, IV, V and VI, to enable the attachment of whatever
documents may be required to support their submissions.
4. STAGE II: FAA RESPONSE TO THE RE. The PI will review the Web-based submission
from the RE and respond in a timely manner. If the original submission from the RE was made
via an alternative media (e.g., telephone etc.), the PI may respond via an alternative means, but
must also respond to the subsequent Web-based submission by the RE.
a. PI Review. The PI’s review of the disclosure shall, to the extent possible, confirm the
submission meets the following requirements:
(1) The RE has notified the FAA of the apparent violation immediately after detecting it
and before the Agency has learned of it by other means.
(2) The apparent violation was inadvertent.
(3) The apparent violation does not indicate a lack, or reasonable question, of
qualification of the RE.
(4) Immediate action, satisfactory to the FAA, was taken upon discovery to terminate the
conduct that resulted in the apparent violation.
(5) The RE has developed, or is developing, a comprehensive fix and schedule of
implementation satisfactory to the FAA. The comprehensive fix includes a followup self-audit to
ensure that the action taken corrects the noncompliance. This self-audit is in addition to any
audits conducted by the FAA.
b. PI Completion of the Review.
(1) Once the PI completes the review of the voluntary disclosure submission, he/she
makes a determination to accept the disclosure, return it for editing, or find it invalid.
(a) Acceptance: If the PI elects to accept the disclosure, the inspector completes the
required Stage II entries in the Web-based VDRP and submits his/her input.
(b) Return for Edit: If the PI finds the disclosure does not contain sufficient
information to accept the disclosure, the PI has the option of returning the disclosure to the RE
for editing. Upon selection of the “send back” button and submission by the PI, the VDRP
system notifies the RE of the determination via email and returns the case to Stage I, pending
resubmission by the RE.
(c) Rejection/Invalid: If the PI finds the disclosure does not meet the requirements set
forth in this AC for acceptance, or it has been determined that no violation occurred, the PI
selects “No” in response to the question, “Is this a valid self-disclosure?”. Upon submission by
the PI, the regulated entity is notified of that determination by e-mail. When found to be invalid,
the case does not advance and is not assigned an EIR number.
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NOTE: If, at any time subsequent to acceptance of the disclosure, the FAA
becomes aware that the disclosure did not meet the requirements set forth
for acceptance under the VDRP, the acceptance may be withdrawn. In such
cases, as well in those cases where it is subsequently determined that a
violation did not occur, the Web-based system provides the option of
“rescinding” a case, which closes the file without action within the VDRP. If
the certificate holding office has sufficient evidence to proceed with
enforcement action, independent of the materials provided by the RE as part
of its submission under VDRP, enforcement action should be initiated in
accordance with the procedures set forth in the current edition of FAA
Order 2150.3.
5. STAGE III: WRITTEN REPORT OF RE’S APPARENT VIOLATION.
a. Written Report. The written report should be submitted by the RE, to the PI, via the
Web-based VDRP system, within 10 working-days of the date disclosure was submitted to the
FAA. This report must contain a detailed description of the proposed comprehensive fix,
outlining the planned corrective steps, the responsibilities for implementing those corrective
steps, and a time schedule for completion of the fix. If a proposed comprehensive fix is not fully
developed within 10 working-days, the pertinent RE should provide at least an overview of its
comprehensive fix plans in a written report submitted within 10 working-days after the initial
notification was made. In any event, a detailed description of the comprehensive fix should be
submitted within 30 calendar-days after initial notification.
b. Required Input. The VDRP Web-based system requires the input of the following
information in the Written Report Stage:
(1) A list of the specific FAA regulations that may have been violated.
(2) A description of the apparent violation, including the duration of time it remained
undetected, as well as how and when it was detected.
(3) A description of the immediate action taken to terminate the conduct that resulted in
the apparent violation, including when it was taken, and who was responsible for taking the
action.
(4) An explanation that shows the apparent violation was inadvertent.
(5) Evidence that demonstrates the seriousness of the apparent violation and the RE’s
analysis of that evidence.
(6) Completion of a Risk Assessment Matrix to aid in evaluating the significance of the
event.
(7) A detailed description of the proposed comprehensive fix, outlining the planned
corrective steps, the responsibilities for implementing those corrective steps, and a time schedule
for completion of the fix and the subsequent self-audit.
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(8) Identification of the company official(s) responsible for monitoring the
implementation and completion of the comprehensive fix and the self-audit.
6. STAGE IV: WRITTEN REPORT REVIEW BY THE FAA. The FAA works with the
certificate holder to ensure that the RE has identified any root causes and systemic issues which
led to the apparent violation. In this stage, the PI is also tasked with completing a Risk
Assessment Matrix to aid in evaluating the significance of the event and the proposed
comprehensive fix. This collaboration helps to ensure that the corrective actions contained in the
comprehensive fix are acceptable to the FAA.
NOTE: Should investigation of the apparent violation result in the
determination that no violation has occurred, the EIR may be closed by
rescinding the file and providing an explanation in the provided comment
box. When submitted, the user is provided a warning that submitting this
action (rescinding the file) will close the case and terminate the investigation.
If the inspector confirms the rescission, the case is closed in VDRP that date
and will close in EIS 10 (ten) days later, with the original date of closure
recorded in EIS. The 10-day delay is provided to enable the FAA to re-open
the file within that 10-day “window” if deemed necessary.
7. STAGE V: IMPLEMENTATION OF A COMPREHENSIVE FIX AND FAA
SURVEILLANCE.
a. Implementation Period. During the implementation period, the FAA and the pertinent
RE should continue to work together. The FAA may advise and assist the entity in correcting any
identified systemic problems. Changes will be made to the proposed comprehensive fix when the
need is identified. Upon determining that the initial implementation of the proposed
comprehensive fix is satisfactory, the PI may issue a letter of correction in Stage V.
Alternatively, the PI may elect instead to issue the letter of correction in Stage VI, if deemed
appropriate. If the letter of correction is issued in Stage V, and subsequent changes are made to
the Comprehensive Fix, the PI shall issue and upload a revised letter of correction in Stage VI
which reflects the letter of correction as implemented.
b. Corrective Steps. The FAA monitors the implementation of the corrective steps.
Throughout the implementation period, the FAA assesses the pertinent RE’s corrective efforts
and top management’s awareness of these efforts. If, during this period, the FAA determines that
the steps taken by the entity are not those documented in the comprehensive fix and acceptable
corrective action by the RE is not forthcoming, the letter of correction may be rescinded, and
appropriate legal enforcement action initiated.
8. STAGE VI: INSPECTOR SIGNOFF.
a. Conclusion. At the conclusion of the implementation period, the PI makes a final
assessment. If all elements of the comprehensive fix, including the RE’s self-audit, have been
adequately accomplished, the PI finds the fix satisfactory and closes the case. The case remains
subject to reopening in the event that the agreed upon actions, outlined in the comprehensive fix,
are not completed to the satisfaction of the FAA.
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Page 6
b. PI Authority to Close the Case. The PI has the authority to close the case. Consultation
with regional specialists, legal counsel, or other FAA personnel may be accomplished when
deemed appropriate by the PI.
4/29/09 AC 00-58B
Appendix 3
APPENDIX 3. VOLUNTARY DISCLOSURE REPORTING PROGRAM (VDRP) FOR
REGULATED ENTITIES (RE) NOT AUTHORIZED TO UTILIZE THE WEB-BASED
VDRP SYSTEM
1. APPLICABILITY. All REs NOT authorized to utilize the VDRP Web-based system will
utilize the guidance contained in this Appendix for submission of Voluntary Disclosures. A list
of authorized users of the Web-based system may be found at: https://av-info.faa.gov/vdrp.
2. THE SIX STAGES OF THE VDRP. The VDRP employs a six stage process.
Responsibility for each such stage is assigned either to the RE or the FAA, as described below.
Except as specified in this AC, the voluntary disclosure policy applies only when notification of
an apparent violation is made to the FAA by the RE, immediately after the apparent violation has
been discovered by that entity, and before the FAA learns of the apparent violation by some
other means.
3. STAGE I: NOTIFICATION TO THE FAA OF AN APPARENT VIOLATION. When
the RE notifies the FAA of an apparent violation, contact must be made with, or directed to, the
appropriate principal inspector (PI). When acceptable to the PI, initial notice of a voluntary
disclosure may be submitted orally, via written hardcopy, or by electronic means. It is FAA
policy that initial notification should be accomplished on a timely basis, ordinarily within
24 hours of the discovery of the apparent violation. However, an inspector may accept
disclosures that exceed the 24 hour-policy when the inspector determines that a later submission
is justified based on the specific circumstances, and in view of those circumstances, the
submission is still considered timely. For example, a voluntary disclosure based on a company
violation revealed in an Aviation Safety Action Program (ASAP) report may require more that
24 hours from the submission of that ASAP report in order for the responsible company entity to
become aware of the information in the report and to initiate a voluntary disclosure. The FAA
retains sole discretion in determining whether a voluntary disclosure received later than 24 hours
after discovery of the violation is timely. The certificate holder should therefore not delay
notification for any reason, and should address, to the maximum extent possible, the following
items with the PI:
a. Brief Description of Apparent Violation. A brief description of the apparent violation,
including an estimate of the duration of time that it remained undetected, as well as how and
when it was discovered.
b. Verification of Cease of Noncompliance. Verification that noncompliance ceased after
it was identified.
c. Brief Description of Immediate Action. A brief description of the immediate action
taken after the apparent violation was identified, the immediate action taken to terminate the
conduct that resulted in the apparent violation, and the person responsible for taking the
immediate action.
d. Verification of Evaluation. Verification that an evaluation is underway to determine:
(1) If there are any systemic problems.
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AC 00-58B 4/29/09
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(2) The corrective steps necessary to prevent the apparent violation from recurring.
e. Identification of Responsible Person. Identification of the person responsible for
preparing the comprehensive fix.
f. Acknowledgement of a Written Report. Acknowledgment that a written report will be
provided to the PI within 10 working-days.
4. STAGE II: FAA RESPONSE TO CERTIFICATE HOLDER. The PI responds with a
written acknowledgment of the entity’s initial notification. This acknowledgment includes the
request for a written report and is sent in lieu of a letter of investigation; provided the written
report is completed in accordance with the VDRP set forth in this AC. The PI will open an
Enforcement Investigative Report (EIR) that will be closed out with a letter of correction
following satisfactory development and implementation of a comprehensive fix as provided by
schedule of implementation agreed upon by the FAA and the entity. The PI’s review of the
disclosure shall, to the extent possible, confirm the submission meets the following requirements:
a. The FAA was Notified. The RE has notified the FAA of the apparent violation
immediately after detecting it and before the Agency has learned of it by other means.
b. The Violation was Inadvertent. The apparent violation was inadvertent.
c. The Violation Does Not Reflect a Lack of RE Qualification. The apparent violation
does not indicate a lack, or reasonable question, of qualification of the RE.
d. FAA Approved Immediate Action was Taken. Immediate action, satisfactory to the
FAA, was taken upon discovery to terminate the conduct that resulted in the apparent violation.
e. The RE Has, or Is, Developing a Comprehensive Fix. The RE has developed, or is
developing, a comprehensive fix and schedule of implementation satisfactory to the FAA. The
comprehensive fix includes a followup self-audit to ensure that the action taken corrects the
noncompliance. This self-audit is in addition to any audits conducted by the FAA.
5. STAGE III: WRITTEN REPORT OF THE RE’S APPARENT VIOLATION.
a. Written Report Specifications. The written report should be provided to the PI by the
RE within 10 working-days after the initial notification was made. This report must contain a
detailed description of the proposed comprehensive fix, outlining the planned corrective steps,
the responsibilities for implementing those corrective steps, and a time schedule for completion
of the fix. If a proposed comprehensive fix is not fully developed within 10 working-days, the
pertinent RE should provide at least an overview of its comprehensive fix plans in a written
report submitted within 10 working-days after the initial notification was made. In any event, a
detailed description of the comprehensive fix should be submitted within 30 calendar-days after
initial notification. The written report should include the following information:
(1) A list of the specific FAA regulations that may have been violated.
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Page 3
(2) A description of the apparent violation, including the duration of time it remained
undetected, as well as how and when it was detected.
(3) A description of the immediate action taken to terminate the conduct that resulted in
the apparent violation, including when it was taken, and who was responsible for taking the
action.
(4) An explanation that shows the apparent violation was inadvertent.
(5) Evidence that demonstrates the seriousness of the apparent violation and the RE’s
analysis of that evidence.
(6) A detailed description of the proposed comprehensive fix, outlining the planned
corrective steps, the responsibilities for implementing those corrective steps, and a time schedule
for completion of the fix and a self-audit following implementation of the corrective action(s). If
a proposed comprehensive fix is not fully developed within 10 working-days, the pertinent RE
should provide at least an overview of its comprehensive fix plans in a written report submitted
within 10 working-days after the initial notification was made. In any event, a detailed
description of the comprehensive fix should be submitted within 30 calendar-days after initial
notification.
(7) Identification of the company official(s) responsible for monitoring the
implementation and completion of the comprehensive fix and the self-audit.
b. Sample Written Report Format. The following sample is only a suggested format to be
followed when preparing the written report that will be submitted to the FAA. While a RE
should include at least all the elements specified below, the structure of the written report can be
modified by the RE to fit its particular needs.
(1) General.
(2) Date.
(3) Certificate type or equivalent.
(4) Pertinent RE number or equivalent.
(5) Company name.
(6) Company address.
(7) Company official filing report.
• Name,
• Position,
• Telephone number, and
AC 00-58B 4/29/09
Appendix 3
• E-mail address.
(8) Description of Apparent Violation.
(9) Applicable 14 CFR part(s).
(10) Date apparent violation was discovered.
(11) Location of discovery.
(12) Company official who discovered the apparent violation.
• Name,
• Position,
• Telephone number, and
• E-mail address.
(13) Date and time of initial notification to the FAA.
(14) Name of FAA official notified PI.
(15) Company official responsible for immediate action.
• Name,
• Position,
• Telephone number, and
• E-mail address.
(16) Duration of time apparent violation remained undetected—hours, cycles, or days.
c. Summary of Apparent Violation. The summary should be a brief statement that
describes the nature of the apparent violation and identifies the specific aircraft, engines,
appliances, facilities, checkpoint, gate, cargo, and/or individuals associated with the apparent
violation.
d. Immediate Action.
(1) When immediate action was taken.
(2) Description of immediate action. This description should outline the immediate steps
that were taken to cease the violative action.
(3) Company official responsible for immediate action.
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• Name,
• Position,
• Telephone number, and
• E-mail address.
e. Analysis.
(1) Summary of evidence. This summary should describe the scope of the apparent
violation and explain how it was detected. In addition, conclusions reached regarding possible or
probable systemic deficiencies (i.e., who, what, when, why, and how the noncompliance
occurred) should be described.
(2) Reasons why the apparent violation was inadvertent.
(3) Supporting documentation. The evidence associated with the apparent violation
should be attached. This evidence should include a statement regarding how the RE determined
the extent of the apparent violation.
f. Comprehensive Fix Proposal. The proposed long term corrective steps to be taken by
the RE to preclude recurrence of the apparent violation should be listed in this section. Each
corrective step should identify the individual or department responsible for implementing and
completing the corrective step as well as the time allotted for completion of each corrective step.
Examples of types of questions or issues that a comprehensive fix proposal should address are as
follows:
(1) Does the apparent violation involve equipment, facilities, or individuals beyond those
addressed in the initial notification and for which immediate action was taken?
(2) Are procedural or organizational changes necessary?
(3) How will it be determined whether any procedural or organizational changes are
effective?
(4) What procedures will be developed to ensure that the affected area is periodically
reviewed in the future so that concerns can be identified before a violation occurs?
(5) Who will be responsible for performing periodic reviews?
(6) To whom in the RE’s organization will the results of those periodic reviews be
reported, and how they will be documented?
(7) A schedule for completion of a self-audit by the RE following implementation of the
comprehensive fix to verify the action taken corrects the noncompliance. This self-audit is in
addition to any audits conducted by the FAA and identification of the individual(s) responsible
for conduct of the self-audit.
AC 00-58B 4/29/09
Appendix 3
g. Responsibility for Monitoring Implementation of the Comprehensive Fix.
(1) Name.
(2) Position.
(3) Telephone number.
(4) E-mail address.
h. FAA Acceptance (to be completed by the FAA).
(1) Name.
(2) Position (PI).
(3) Date.
(4) Office.
6. STAGE IV: WRITTEN REPORT REVIEW BY THE FAA. The FAA works with the
certificate holder to ensure that the RE has identified any root causes and systemic issues which
led to the apparent violation. This collaboration helps to ensure that the corrective actions
contained in the comprehensive fix are acceptable to the FAA.
7. STAGE V: IMPLEMENTATION OF THE COMPREHENSIVE FIX AND FAA
SURVEILLANCE.
a. Continued FAA and RE Cooperation. During the implementation period, the FAA and
the pertinent RE should continue to work together. The FAA may advise and assist the entity in
correcting any identified systemic problems. Changes will be made to the proposed
comprehensive fix when the need is identified. Upon determining that the initial implementation
of the proposed comprehensive fix is satisfactory, the PI may issue a letter of correction in
Stage V. If the letter of correction is issued in Stage V, and subsequent changes are made to the
Comprehensive Fix, the PI shall issue an amendment to the letter of correction which reflects the
corrective action, as implemented.
b. The FAA’s Monitoring of Corrective Step Implementation. The FAA monitors the
implementation of the corrective steps. Throughout the implementation period, the FAA assesses
the pertinent RE’s corrective efforts and top management’s awareness of these efforts. If, during
this period, the FAA determines that the steps taken by the entity are not those documented in the
comprehensive fix and acceptable corrective action by the RE is not forthcoming, the letter of
correction may be rescinded, and appropriate legal enforcement action initiated.
8. STAGE VI: INSPECTOR SIGNOFF.
a. Conclusion. At the conclusion of the implementation period, the PI makes a final
assessment. If all elements of the comprehensive fix have been adequately accomplished,
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Page 7 (and 8)
including a satisfactory self-audit by the RE, the PI finds the fix satisfactory and closes the case.
The case remains subject to reopening in the event that the agreed upon actions, outlined in the
comprehensive fix, are not completed to the satisfaction of the FAA. A statement of followup
investigation, confirming that the comprehensive fix was satisfactorily implemented and
completed, is prepared to complete the FAA’s investigative package.
b. PI Authority. The PI has the authority to close the case. Consultation with regional
specialists, legal counsel, or other FAA personnel may be accomplished when deemed
appropriate by the PI.

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