The FAA alleges that Delta Airlines failed to repair a chip in the nose radome on a B-737 after an FAA inspector conducted a pre-flight inspection and informed them of the damage. The FAA alleged that Delta did not make the mandated repair per their structural repair manual. In a separate event, the FAA alleges the carrier incorrectly deferred repair of a broken cockpit floodlight socket. Maintenance procedures allow the airline to defer repairs on a dome light for only for 10 days before repairing or replacing it. As a result of these 2 events the FAA has proposed that a fine of $975,000 be levied against Delta Airlines.
It is quite possible, since the FAA press release does not reveal all of the facts, that this violation was reported to a line maintenance person and it is also possible that under operational constraints, that a chip in the radome may not have been recorded in the Delta records.
Regardless of the circumstances, this scenario points out the value of having a system wide Regulatory Affairs Process/Procedures Manual and Regulatory Affairs Group in place. Such a program would have defined that any person, FAA or otherwise, who seeks permission to enter Delta property, must be logged in and supported by a responsible Delta representative. In the Delta scenario, the inspector may have informed a mechanic or even maintenance control of the findings. Somewhere in the chain of events the ball got dropped and Delta missed the opportunity to correct the discrepancies per their repair manual and MEL. Had a Regulatory Affairs program been in place, someone would have escorted and supported the FAA inspector and ensured that the problems were recorded for corrective action. A good Regulatory Affairs program would also enable a record surrounding the event for tracking and historical purposes.
Air carriers have numerous programs to track operations, safety and maintenance programs but the function of tracking and managing FAA inspections, visits and requests may not be documented at all or it may be handled by numerous groups within the airline. It would behoove air carriers to implement standard operating procedures (SOP) on how to manage FAA interactions and centralize their function under the Safety or Legal department. Based on its experience assisting air carriers dealing with thorny compliance issues, JDA has developed a Regulatory Affairs training course and has previously published rationale for initiating such a valuable program.Share this article: