Expansion of Aviation Safety Action Program (ASAP) to Support Corporate Safety Management Systems

U.S. DEPARTMENT OF TRANSPORTATION N 8900.765

NOTICE

FEDERAL AVIATION ADMINISTRATION Effective Date: 1/15/26 National Policy Cancellation Date: 1/15/27 SUBJ: Expansion of Aviation Safety Action Program (ASAP) to Support Corporate Safety Management Systems 1. Purpose of This Notice. This notice provides guidance related to the Corporate-Aviation Safety Action Program (C-ASAP). This notice gives instruction and guidance to allow corporations with eligible entities to establish a C-ASAP for their corporate Safety Management Systems (SMS). A C-ASAP meets the requirement for a Title 14 of the Code of Federal Regulations (14 CFR) § 5.71 Safety Assurance (SA) confidential reporting system.

2. Audience. The primary audience for this notice includes SA division managers, Office Managers (OM), and principal inspectors (PI) who have oversight responsibility for operators certificated under 14 CFR for operations under 14 CFR part 91, 121, 125, 133, 135, 137, 141, 142, 145, or 147, or a fractional ownership program as defined in 14 CFR part 91 subpart K (part 91K). The secondary audience includes all other Flight Standards (FS) personnel with Aviation Safety Action Program (ASAP) responsibilities.

3. Where You Can Find This Notice. You can find this notice on the MyFAA employee website at https://employees.faa.gov/tools_resources/orders_notices and the Dynamic Regulatory System (DRS) at https://drs.faa.gov . Operators and the public can find this notice on the Federal Aviation Administration’s (FAA) website at https://www.faa.gov/regulations_policies/orders_no tices and DRS.

4. Background. In 2015, the FAA published 14 CFR part 5, which mandated that 14 CFR part 121 certificate holders (CH) or applicants implement an SMS. This regulation harmonized U.S. requirements for aviation organizations needing state acceptance of their SMS with International Civil Aviation Organization (ICAO) SMS standards. A key component of 14 CFR part 5 is the requirement for organizations to have a confidential safety reporting system within their SA framework. Given this established foundation of mandatory safety reporting through SMSs, the expansion of the ASAP to include a C-ASAP definition in policy emerged as a logical next step in SMS Voluntary Programs (SMSVP), building upon the existing safety culture and reporting mechanisms.

5. General Information.

a. Corporate Entities. In general, “corporate” refers to the large, established business structures and entities that operate for profit and are often characterized by a hierarchical Distribution: Electronic Only Initiated By: AFS-900

1/15/26 N 8900.765 structure of organizations with a large number of employees. A C-ASAP consists of a single accountable executive who signs the ASAP Memorandum of Understanding (MOU) and is responsible for the program.

b. ASAP. The FAA’s ASAP is a voluntary, non-punitive reporting system designed to encourage employees of participating airlines and repair stations to report potential safety hazards and near-miss incidents. This program aims to identify and address safety issues through corrective actions rather than through punishment, fostering a safer environment for aviation operations.

c. C-ASAP Coverage. The C-ASAP will cover all employees of the corporation with a single MOU. The eligible employees abide by the terms of the applicable C-ASAP MOU and the decisions of the eligible entity’s event review committee (ERC). Each eligible entity in the corporation has an ERC. The ERC has the discretion of considering the timelines of a report as a criterion for determining its acceptance, thereby allowing the ERC to make a decision in the best interest of safety.

Note: A C-ASAP can be used to cover all employees of a single organization.

The C-ASAP allows flexibility with the reduced requirement of multiple MOUs.

Note: C-ASAP referenced in this notice is for individuals in the company, not for the company itself. The CH would use the VDRP process for regulatory disclosures.

d. ERC Composition. An ERC is a group comprised of a representative, and alternate, if possible, from each party to an ASAP. This includes a management representative from the eligible entity, a representative from the employee group or employee labor association (if applicable), and a qualified FAA inspector from the responsible Flight Standards office.

6. Generating an MOU. The C-ASAP MOU can be generated in the standard MOU template found at https://asapmou.faa.gov/ .

a. Automated MOU Generator. The automated MOU generator creates a demonstration or continuing ASAP MOU that fully complies with FAA ASAP guidance, thereby expediting the FAA review and acceptance process. Although designed primarily for use by CHs operating under 14 CFR, it may also be used by corporations that own operators that wish to establish an ASAP. The automated MOU generator produces an ASAP MOU in text or Microsoft Word, based on the user’s answers to a series of questions. Proposed ASAP MOUs produced by the automated MOU generator will be processed by the FAA on an expedited basis. Demonstration or continuing ASAP MOU submissions should be based on the most recent version of the MOU generator.

b. Eligible Entities. When adding a C-ASAP MOU, all eligible entities covered under a single MOU should be entered into the system. The MOU needs a Federal aviation regulation part for each entity covered under the MOU. If one of the entities of the corporation leaves the agreement, an update to the MOU generator should be entered to accurately reflect the status of the MOU.

1/15/26 N 8900.765 7. Summary Reports. FAA OMs or designees are required to prepare a summary report of ASAP quarterly statistics for each eligible entity under the C-ASAP(s) for which they have oversight responsibility.

8. Disposition. We will incorporate the information in this notice into FAA Order 8900.1 and Advisory Circular (AC) 120-66, Aviation Safety Action Program, before this notice expires.

Direct questions or comments concerning the information in this notice to the Safety Management, Analytics, and Systems Integration Division (AFS-900) at 9-NATL-SMS-ProgramOffice@faa.gov.

Robert Reckert for Hugh Thomas Acting Executive Director, Flight Standards Service