FAA CONSISTENCY A LAUDABLE GOAL—JUDGEMENT IS ESSENTIAL TO AVIATION SAFETY

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ARTICLE: Consistency Of Regulatory Interpretation ARC Requests Industry Stakeholder Input
Survey Being Conducted Online Through September 25

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Consider this—there are more than 3,000 pages of FARs, add hundreds of thousands of interpretative FAA documents, then consider that these rules apply, for example, to a small organization with a few aircraft in Alaska, and at the same time, to a huge company which operates worldwide. Finally, be aware of the fact that the employees who enforce these regulations are broadly geographically distributed.

Clearly consistent application of the FARs is a difficult, if not impossible task. It is possible to argue that the same answer should not always be given under such diverse operations; the certificate holder’s demonstrated competence and the wide variations in the flight environments in which they operate.

Perhaps a more reasonable goal would be to establish a workplace in which the application of the regulatory decisions reflect the knowledge of the rules and their intent, understanding the operational realities of the certificate holder’s mission and REASONABLE JUDGMENT. A one FAA goal is neither realistic nor appropriate.

What is needed is:

  • A robust training budget in which the field personnel are exposed to the thinking of the knowledgeable rule writers,
  • Local managers who have the authority to create work experience which allows their staff to grow in their understanding of the demands faced by their certificate holders and of how these companies attempt to meet the FARs,
  • A national resource where field personnel can easily obtain national guidance, and
  • An internet “application” in which field personnel can share experiences and compare their positions with their peers; this list-serve could also be monitored by the same people in Washington who are the subject matter experts on the topic of this “application.”

That said, the goals of this ARC are laudable and should be supported by the aviation safety professionals. Specific examples of inconsistency should be submitted to assist the FAA in defining the scope of the problem. Comments are due by September 25.

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