Legal Issues in Paperless or Strip-less Environments

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Legal Issues in Paperless or Strip-less Environments

46TH ANNUAL CONFERENCE, Istanbul, Turkey, 16-20 April 2007

WP No. 162

Legal Issues in Paperless or Strip-less Environments

Presented by PLC


At the 45th annual Conference of IFATCA in Kaohsiung, Taiwan the Technical and Operational Committee (TOC) presented the paper B5.11 “Study operations in a paper strip-less environment”, which concluded to refer studies on legal issues pertaining to paper/strip-less environments to the PLC. Therefore this paper became one of the working items of PLC.


2.1 General

2.1.1  Bert Ruitenberg (HF-specialist) and the Austrian company FREQUENTIS, a leading provider in paperless systems were consulted. Besides the technical issues already covered in the paper presented by TOC at last years annual conference, the key issues were: stripmarking, seamless operations in case of equipment failure, redundancy of data, storage and accessibility of data, tracing of inputs and situational awareness.

2.1.2  Stripmarking: Stripmarking procedures in a paperstrip environment are the most vital function of data input and storage. Stripmarking was always thought as a mirror of the present traffic situation, with the additional use of data storage and availability in case of system failures. Modern paperless and even strip-less systems do automatic data exchange and storage, for those reasons stripmarking as a matter of redundancy becomes obsolete. The controller will still be responsible for keeping the information accurate.

2.1.3  Situational awareness: Handling paperstrips manually, such as triggering, resorting etc. increases memorization due intense eye-hand coordination. Through the loss of paperstrips, situational awareness might be reduced. PLC is of the opinion, that as long as a manual input is necessary the hand-eye coordination is not lost, and memorization will not be reduced.

2.1.4  Tracing of system inputs: As an electronic input is available for all controllers concerned, a beneficial situation can arise, but it might be harder for a releasing controller to re-trace inputs made. Therefore these inputs should be easily retrievable.

2.1.5  Seamless operations and redundancy of data: One of the most important items when replacing paper strips by paperless systems is the availability of all relevant data in case of system failure. As mentioned above, paperstrips give a rough picture of the air situation. Paperless and strip-less systems should provide as good – or preferably even better information as paperstrips in case of system failure. Therefore systems should have sufficient redundancy and work independent of radar systems in case of failure. Training of these fallback procedures shall be provided regularly.

2.1.6 Storage and accessibility of data

All flight data and inputs are sensitive, and shall be stored and shared carefully. Access shall be limited for handling such as replay, investigation etc. As electronic systems are able to identify the time and duration of an entry, it will be possible to identify the workload of a controller or working position very easily.

Data derived from those systems should not be used as performance indicators.

2.2 IFATCA policy

2.2.1  Use of recorded data: On page 4422 paragraph 2.1.9 is stated:

“Audio, visual and area recordings, together with associated computer data and transcripts of air traffic control communications are intended to provide a record of such communications for use in the monitoring of air traffic control operations, and the investigation of incidents and accidents. Such recordings are confidential and are not permitted to be released to the public. Such recordings are not to be used to provide direct evidence such as in disciplinary cases, or to be used to determine controller incompetence (Nairobi 87.C.17, amended Taipei 97.C.11).”


This policy is considered to be sufficient.

2.2.2  Liability: The legal section of the IFATCA Manual states:

“1.2.4. A controller shall not be held liable for incidents that may occur due to the use of inaccurate data if he is unable to check the integrity of the information received (Christchurch 93.C.22).

1.2.5 A controller shall not be required or compelled to use equipment that is known to be unserviceable, inaccurate or subject to irregular functioning (Marrakech 00.C.13).”


and in the Automation/Human Factors section of the Manual:

“2.5.3. The legal aspects of a controller’s responsibilities must be clearly identified when working with automated systems (Port of Spain 91 C.12).”


PLC is of the opinion, that no further policy is needed.

2.2.3 Automation: Additionally to the paragraphs mentioned above, IFATCA-policy on page 4123 ff. is:

“2.5.1. Automation must improve and enhance the data exchange for controllers. Automated systems must be fail-safe and provide accurate and incorruptible data. These systems must be built with an integrity factor to review and crosscheck the information being received (Port of Spain 91.C.8).

2.5.2. The following factors are of prime importance:

  • The Human Factors aspects of Automation must be fully considered when developing systems.
  • Automation must assist and support ATCOs in the execution of their duties.
  • The controller must remain the key element of the ATC system.
  • Total workload should not be increased without proof that the combined automated/human systems can operate safely at the levels of workload predicted, and to be able to satisfactorily manage normal and abnormal occurrences.
  • Automated tools or systems that support the control function must enable the controller to retain complete control of the control task in such a way as to enable the controller to support timely interventions when situations occur that are outside the normal compass of the system design, or when abnormal situations occur which require non-compliance or variation to normal procedures.
  •  Automation should be designed to enhance controller job satisfaction. (Port of Spain 91.C.8-11, amended Santiago 99.C.19, Geneva 01.C.13)”


2.2.4 Training: Though the IFATCA policy on training is under review, as presented in a separate paper to this conference, existing policy on training on automated systems as laid down on page 4 3 2 5 is found to be sufficient:

“2.6.1. Controllers required to operate in an automated air traffic control system should receive relevant instruction in automatic data processing for ATC (Brussels 79.- C.20).

2.6.2. Controllers should be involved at all levels in the specification, evaluation and implementation of an automated ATC system (Brussels 79.C.21).

2.6.3. Formal training should be established for all ATC personnel in the theoretical and practical procedures associated with the automated ATC system (Brussels 79.C.22)

2.6.4. The above training should be carefully integrated with the implementation of each stage of the automated ATC system (Brussels 79.C.23).

2.6.5. ATC supervisors and managers (of ATC units about to implement automated ATC systems) should attend a course or seminar dealing with “The Management of change”) (Brussels 79.C.24).

2.6.8. The implementation of automated systems shall include sufficient training, including the Human Factors aspects of automation, prior to using new equipment. The level of training is a major factor in determining the level of traffic that can be safely handled until all controllers have gained enough hands-on experience.”



It is the opinion of PLC that the existing professional policy covers paperless and strip-less environments.


This paper to be accepted as information.


WP No. 91 Kaohsiung Agenda Item B.5.11. “Study Operations in a Paper Stripless Environment”.

IFATCA Manual.

“The use of Flight Progress Strips while working live traffic: frequencies, importance, and perceived benefits”, Francis T. Durso, Texas Tech. University, Peter J.Batsakes and Jerry M. Crutchfield, The Boeing Company.

Last Update: September 29, 2020  

April 9, 2020   791   Jean-Francois Lepage    2007    

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