ARTICLE: How To Play By The Same Rules
In reviewing the current standardization problem, the authors report that documentation might not be consistent and mentions how to include the apparent errors into the FAA’s Consistency and Standardization Initiative. The strongest recommendation is to use very powerful remedial tools such as:
- the Aviation Safety Action Program (ASAP),
- the Aviation Safety Reporting System (ASRS),
- Line Operation Safety Audit (LOSA), and
- other voluntary reporting systems to highlight all documentation challenges.
These programs invoke processes that compel responses from regulatory systems.
As noted before here, standardization is a very difficult challenge—so many pages of regulatory materials (49 USC, 14 CFR, ADs, ACs, Handbooks and an seemingly infinite number of other reference materials) plus a large inspector workforce which is geographically diverse and which is less inclined to receive guidance from management.
While the Consistency and Standardization Initiative and the ARC on Consistency of Regulatory Interpretations work their way through the required processes, make recommendations and initiate implementation for their recommendations (probably years?), one would be well advised to attend a 400 level course on how to deal with your local FAA while the new standardization guidelines emanate from Washington. Such a course should include tools such as:
- researching the current FARs,
- finding their intent by reading their preambles (where the FAA spells out the intent of the new rules),
- getting to the web page where the FAA Chief Counsel issues THE official interpretation of the rules,
- citing the FAA handbooks on conducting investigations, permissible/impermissible conduct by FAA inspectors and remedies to address indiscretions,
- hard wiring a headquarters interpretation of a rule which the field does not follow without blowing up your relationship with your POI or PMI,
- creating your own documentation system designed to minimize your CP exposure and
- receiving a host of information and tactics.
Attending the next Regulatory Affairs course will provide the information and tools that you need to work better with the FAA.Share this article: