For the non-believers,Compliance Philosophy is RENEWED

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FAA Order 8000.373 Federal Aviation Compliance Policy 8/26/2015

FAA Order 8000.373 Federal Aviation Compliance Policy 10/31/2018

Policy originally issued by Administrator Huerta

Field’s reaction was not 100% positive

Acting Administrator Elwell reissues Compliance Policy

Way back in 2015, voices of dissent were heard when Administrator Huerta and Associate Administrator Gilligan issued a new Compliance Policy, The Change was driven by a number of important policy reasons and some practical realities. Some of the long term Aviation Safety Investigators in the field, in particular, questioned the efficacy of the collaboration/ cooperation approach which derives from SMS. The transition to the safety regime which prioritizes finding solutions as opposed to assessing civil penalties, will require time to learn the new rubrics and apply the new policies. Initially, civil penalties were issued, raising doubts about the field’s willingness to follow the orders from Headquarters.

The DOT Office of Inspector General has initiated a review of the Compliance Policy. The value of this program, initiated by ICAO and adopted by other CAAs, should be evident.

One of the realities of any regulatory agency is delay; if the staff drags its feet, it is possible to wait until new political employees take office hoping that the new Administration will not adopt the policy with which the field disagrees.

Thus, an obscure notice published recently is SIGNIFICANT. The Compliance Policy, adopted by the previous Administration, was being reissued by the current political leaders of the DOT and FAA[1].

There is only one difference between the 2015 and the 2018 documents—the signatures.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The Compliance Policy continues

 

[1] The Acting Administrator may not appear to signal Administration endorsement, but before the notice was issued, it had to be approved by both the Secretary’s staff and the OMB analysts.


 

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