Consistent Interpretation of FARs by dispersed staff
Source materials GIGANTIC and Constantly Changing
Dynamic Regulatory System THE INFORMATION RESOURCE
For all, everywhere and quick
The FAA Aviation Safety Organization employs ~7,000 people distributed among over 100 physical locations interpreting 10s of thousands regulations (14 CFR Part 1-198) plus an almost infinite number of pages of Handbooks, Orders, ACs, ADs, InFos, SAFOs AND ON AND ON… A simple probability calculation of that many people so geographically separated with different aviation environments READING that many documents over time RESULTS in a very high LIKELIHOOD OF INCONSISTENCY.
Those being regulated have known that there have been great variances in these positions resulting in making determining what do the rules mean/require VERY DIFFICULT and not terribly reliable. After several Advisory and Rulemaking Committees (ARAC) complaining about these variances, the FAA in 2009 started its Consistency and Standardization Initiative. It allowed “stakeholders” to submit an inquiry to get the definitive answer. The CSI page notes:
“When an AVS action is questioned or disputed, decision-makers at every level of the AVS management chain are expected to thoroughly review the matter and be accountable for the answers provided.”
The process had its limitations—the review took time and even the final position was based on a complex, dispersed and even dynamic database.
The FAA’s announcement (below) signals the addition of an incredibly significant tool for consistent interpretation of the FARs. Dynamic Regulatory System (DRS). This application integrates all of the Office of Aviation Safety guidance materials through a highly sophisticated search machine. As NATA’s Vice President of Regulatory Affairs John McGraw explained:
“When it comes to safety, both speed and reliability are imperative. NATA is pleased to participate in initiatives that greatly improve the access to and consistency of valuable safety information and guidance. The Association has always promoted continuous improvement as a key to success in safety management and the DRS will provide a means for achieving this goal throughout the industry…
- More than 2 million regulatory guidance documents
- Over 65 document types from more than a dozen repositories
- Links to Codes of Federal Regulations
- Guidance material from the FAA’s Flight Standards Information System and its Regulatory Guidance System
- Pending and current versions of documents, along with corresponding revision history
According to the FAA, “the DRS exceeds the requirements of the FAA Reauthorization Act of 2018 (Public Law 115-254), to establish a centralized safety database.” The information contained in the DRS is scheduled to update every 24 hours, and the DRS will continually evolve to include more features and functionality.
“The much-anticipated DRS provides a centralized public database of regulatory safety guidance materials, which will benefit the general aviation manufacturing, maintenance and repair industries as well as the FAA…GAMA and its member companies have been advocating for this critical tool and we were pleased to be a resource throughout its development and have the opportunity to provide feedback during the testing phase. We have also appreciated the congressional support for this important initiative. The industry has been eager to use a tool that helps promote consistency in regulatory interpretation and application by making regulations, policy and guidance readily available. We look forward to the continued evolution and improvements to the DRS.”
DRS now means that all in aviation have a tabula pulchra, where all have equal, quick, and reliable access to the meaning of the FARs.
FAA press release
The Dynamic Regulatory System (DRS) is a comprehensive knowledge center that includes all regulatory guidance material from the Office of Aviation Safety.
DRS combines more than 65 document types from a dozen repositories into a single searchable application. It also includes all information found in the Flight Standards Information System (FSIMS) and the agency’s Regulatory Guidance System (RGL). You can browse or search the more than 2 million regulatory guidance documents. A complex search engine serves as the backbone of DRS and allows for basic or very advanced searches, while applying a variety of filters. The system includes pending, current and historical versions of all documents along with their revision history. And to ensure you have the most current documents, it is updated every 24 hours.
DRS is mobile-friendly and users will get the best experience using Chrome or Safari. DRS does not support Internet Explorer.
How is DRS different from the FAA’s Flight Standards Information System (FSIMS) or the Regulatory Guidance Library (RGL)?
DRS consolidates safety information from more than a dozen information repositories, including RGL and FSIMS. The application consolidates information into a single source that can be explored using a robust search engine and by applying a variety of filters. DRS provides one-stop-shopping for regulatory research. It’s like Google for aviation safety information.
What kind of information can be found in DRS?
DRS includes all regulatory guidance material from the Office of Aviation Safety. The system warehouses over 2 million documents and over 65 documents types.
What are the benefits of using DRS rather than the many other information repositories available?
The system represents a giant step forward in providing consistency and standardization of regulatory interpretation by expediting research of aviation regulations and related documents. In the past, regulatory research required cross-referencing information from dozens of sources, validation of the information quality, and inconsistent presentation of current versus historical documents and their associated versions. Complex research projects sometimes took days. DRS has consolidated all of this information into a single master source of regulatory guidance material. What once took days of effort can now be done with a few clicks and in a matter of minutes.
Who updates DRS and how often is it updated?
DRS automatically searches more than a dozen information repositories daily for new regulatory guidance. The system is updated nightly.
How does the FAA determine what information is shared on the database?
DRS contains all regulatory guidance material from the Office of Aviation Safety. Any new guidance material is added as soon as it is available.
Who designed DRS?
Flight Standards Service, Office of Aircraft Certification, Office of Information Technology, labor organizations, contractors, and industry aviation partners across the globe all worked together to make DRS a reality.
Can members of the aviation industry request specific information be added to the database?
DRS is not intended to be a repository for anything and/or everything. The system was designed as an aviation safety regulatory guidance knowledge center, specific to content from the Office of Aviation Safety. The FAA worked closely with industry safety partners from around the globe to develop the Master List of Documents. While it is possible to add additional document types, we believe that system is very comprehensive today. As the system evolves, additional document types will be added.
Can DRS include other types of information?
Yes. DRS is built on an Enterprise platform that can be expanded to include other information types in the future.
Is development of DRS complete and what is in store for the system in the future?
The initial operating capabilities and content of DRS are extensive, but the system will continue to grow and evolve. There is still much work to be done. Over the next year DRS will receive additional enhancements that will provide users even more features, functionality, additional information, and document types.
Can the public access DRS and who is expected to use the system?
DRS is available to all FAA employees and the general public. It is estimated that more than 5,000 government employees will use the system and more than 100,000 industry aviation safety partners.
 Although all of these documents are useful, only the text of the FARs can be relied upon for an interpretation.
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