Thank you for proposing additional clarifications to your Form 6120.1, NTSB Pilot/Operator Aircraft Accident/Incident Report and requesting comments on the proposed changes. While I generally agree with the changes and clarifications you have proposed, there are several issues which you haven’t addressed. Before pointing them out, I want to re-state something I have said before on multiple occasions . . . .. the NTSB is the world standard in aviation accident investigation.
Now to the business at hand . . . . .
These are several existing sections of Form 6120.1 which should be changed and/or eliminated. Several sections of the form are problematic in that they encourage whoever is completing/submitting the form, whether it is the operator or pilot, to engage in speculation, guesswork and investigation of the incident/accident, all things which the NTSB neither permits, nor engages in. The following two sections suffers from such problems.
“Was there Mechanical Malfunction/Failure? (If yes, list the name of the part, manufacturer, part no., serial no., and describe the failure) (p.4)”
“Recommendation (How could this accident/incident have been prevented?) Operator/Owner Safety Recommendation (p.10)”
The responsibility for the investigation of aviation accidents resides exclusively with the NTSB. Moreover, the NTSB routinely cautions parties and those involved in such investigations, including operators/pilots that they should not conduct their own investigation of accident or speculate about the course of the accident.
Failure to follow these rules risks the party being removed from the participation in the investigation process and being publicly, in effect, censured by the NTSB.
Yet despite the foregoing, Form 6120.1 encourages, indeed mandates, that operators/pilots engage in an investigation and provide their speculation regarding an accident which, theoretically, happened within 10 days of the required report. In fact, the proposed change makes clear that the operator/pilot must do these things in a public way, as the form will now indicate that “by signing the document, the pilot/operator consents to the public release of the information contained therein.”
I applaud the NTSB making changes to the Form 6120.1, but I suggest you focus on the fact that the form continues to encourage investigation/speculation by the very people/citizens who are involved in the investigation.
Once again, while we applaud the proactive approach of the Board relative to reporting requirements we urge you to review and revise the sections of the form that certainly appear to run counter to the basics precepts of the Board process.
Thank you in advance