Voluntary Disclosure Reporting Program
When deviations from regulatory standards occur, the FAA's goal is to use the most effective means to return an individual or entity that holds an FAA certificate to full compliance and prevent recurrence. The FAA's Hazardous Materials Voluntary Disclosure Reporting Program (VDRP) allows air carriers to disclose violations of the Hazardous Materials Regulations (HMR) under an FAA voluntary program. This program applies to U.S. air carriers certificated under 14 CFR Parts 119, 121, 125, 135, and to foreign air carriers operating in the U.S. that are issued operations specifications under 14 CFR part 129.
The historical approach to making aviation safety improvements is based on reviewing data obtained after an aviation accident or incident. This reactive approach has transitioned into a more proactive strategy where the FAA is using the data it obtains through surveillance and design reviews of an air carrier's overall operations. Aviation safety improvements can also be obtained when the air carrier shares information about its non-compliance openly with the FAA. The Hazardous Materials VDR program allows air carriers to submit information disclosing their own non-compliance with the HMR without incurring civil penalties if the appropriate process is followed.
FAA issued Advisory Circular (AC) number 121-37A (PDF), titled Voluntary Disclosure Reporting Program (VDRP) Hazardous Materials. Air carriers may self-disclose potential violations of 49 CFR Parts 172, 173, and 175 to the FAA under the VDRP program.
There are six (6) stages in the FAA VDRP Process:
- (Initial Notification or IN) is performed by a Regulated Entity to begin the self-disclosure (SD) process.
- (Initial Notification Response or INR) is performed by FAA Systems Oversight Division to approve the Initial Notification as a valid self-disclosure (SD), followed by FAA HQ (SOM) review for concurrence.
- (Written Report or WR) is performed by the Regulated Entity to present all of the details of the apparent violation, including root cause(s) and an implementation plan for comprehensive fixes.
- (Written Report Review or WRR) is performed by FAA Systems Oversight Division to review and approve the information included in the Written Report and reconfirm that the apparent violation is a valid self-disclosure.
- (Surveillance or MON) is performed by FAA System Oversight Division to confirm that the Regulated Entity is successfully implementing the comprehensive fixes outlined in the Written Report. After completion of fixes, the Regulated Entity provides a self-audit report(s).
- (Inspector Signoff or IS) is performed by FAA Systems Oversight Division to confirm that the self-disclosure remains valid, to assess whether the comprehensive fix steps outlined in the Written Report were implemented satisfactorily,
The FAA believes that aviation safety is well served by incentives for operators to identify and correct their own instances of noncompliance, and to invest more resources in efforts to preclude their recurrence. FAA's policy of forgoing civil penalty actions when a covered entity detects violations, promptly discloses the violations to the FAA, and takes rapid 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.
For further information or to disclose a violation under the VDRP, see the VDRP user guide.