Originally Posted by
paul salerno
"...Companies are very adverse to VDRPs."
Depending on the principal inspectors, the VDRP my company used was very successful, and really works well with SMS. We would discover (inadvertent, unintentional) violations from internal pilot reports, or sometimes records reviews, and disclose them to FAA with a 'comprehensive fix'.
We improved our processes, and never once received a civil penalty or certificate action; both the company and the pilots involved.
And if FAA issued a Letter of Correction (which they sometimes did) it was in the name of the certificate holder; NOT the name of the pilot! This is the real downside of ASAP, is that the LOC is on the pilot's record; not so with VDRP.
If there's a warning notice issued to the pilot under ASAP, it is not searchable/included in the pilots normal record. ASAP protects it from PRIA and FOIA.
That said, there may be big changes to ASAP coming, since the new compliance philosophy kind of makes the necessity for a non-punitive system redundant. No plans that I know of yet and I would highly advise everyone to use ASAP to the fullest extent, but even routine violations that would have gotten regular warning notices or small civil penalties are now being handled without anything on the pilot's record.