Lessons Learned = Good; Reliable Interpretation of FARs = Much Better

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The FAA is aggressively pursuing methods to improve aviation safety and the efforts should be commended. As described in the below article, the Lessons Learned page is a useful compendium of past accidents with analyses of what happened and how  the mistakes may be avoided.

The page is well designed (see the above picture) and is easy to navigate. As the author of the AVIATIONPROS.com website chronicles, the recently added information includes:

  • “1960:  Capital Airlines Viscount (Turbine Engine Icing, Engine Isolation)
  • 1995: Atlantic Southeast EMB-120 (Structural Inspection, Propeller Blade Failure)
  • 1996: Birgenair B757 (Avionics Confusion, Cockpit Resource Management)
  • 1997: Fine Air DC-8 (Cargo Loading, Organizational Safety Oversight)
  • 2000: Air France Concorde (Fuel Tank Structural Integrity, Minor Repair Processes)
  • 2008: British Airways B777 (Fuel System Icing, Engine Isolation)”

The FAA’s website uses videos, animations, and photographs to help the users comprehend the technical significance of the specific accidents. It is a powerful tool and should provide useful guidance.

Lessons Learned is a useful tool, but its focus is retrospective.

The hallmark of the FAA’s most dramatic safety advances has been PROACTIVE and/or PREVENTATIVE. CAST, SMS, VDRP, SASO and a number of other systematic approaches are designed to develop solutions to as-of-yet unencountered problems. These new methods have been incredibly successful.

The primary bible for aviation safety is entitled the Federal Aviation Regulations, which number almost 400 parts and 1,500 pages. A linguistic expert would analyze those safety rules and opine that the tone of those regulations is not consistent. For example, most of the standards used to define safe operations are extremely precise; whereas the sections devoted to maintenance are more susceptible to broader interpretation. There may be good rationale for this difference in tone: the rules have long lives and flexibility in interpretation it is useful to fit the rules to future changing circumstances.

Practitioners of FAA enforcement proceedings will likely characterize the interpretations of the FARs by inspectors, managers and lawyers as being heavily dogmatic. Rarely will the enforcers recognize any ambiguity and much to the contrary, they assert that their reading of the rules is akin to papal infallibility. Yet there is a reluctance among those regulators to provide THE right interpretation of those standards which define safety compliance. The standard position of the FAA is that the certificate holders have an obligation to discern the proper way to implement the rules.

The FAA recognizes that uniformity of interpretation of the FARs among its staff is a significant problem in its Consistency and Standardization Initiative. While getting its field personnel on the same page in applying these complex rules is daunting, providing guidance to certificate holders as to how they should comply with the FARs is even more challenging.

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