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Keywords:

  • aviation;
  • process-oriented regulation;
  • regulatory inspections;
  • secondary learning;
  • voluntary disclosure

Abstract

Along with other types of process-oriented regulation, voluntary disclosure programs are increasingly used by regulatory agencies to supplement traditional inspection activities. Voluntary disclosure programs provide incentives, such as immunity or reduced regulatory enforcement to those submitting reports, while providing regulatory agencies with valuable information on existing risks and areas of non-compliance. This article contributes to the discussion of voluntary disclosure programs by highlighting an important unconsidered benefit of such programs: the secondary learning they generate, above and beyond information about violations. Beyond the information submitted by firms contained in the self-disclosures, the programs generate information and insights about the usual practices of the industry, the division of labor, typical problems, and ways to handle them – those details often invisible to those outside an organization or inside the organization but not “on the ground.” This additional information provides important benefits to both industry management and agency officials. We demonstrate the existence of secondary learning and describe the effect of the structure of voluntary programs on secondary learning with evidence from two case studies of the Federal Aviation Administration's voluntary disclosure programs: the Aviation Safety Action Program and the Voluntary Disclosure Reporting Program.