The two recent fines imposed by FAA against Alaska Airlines and Horizon Airlines, raise the question posed above.
The quick answer to this question, based on the billions of dollars of capital that an air carrier devotes to its fleet, is “having a preventative maintenance program that is designed to keep our airplanes in airworthy condition.” That’s a good answer to most accounting queries, but actually not totally accurate.
All of those aircraft are worthless if one piece of paper is in disarray: the FAA certificate. What does a company do to preserve that asset? Your most positive answer probably is to avoid the principal inspectors. Why? Because your experience suggests that every time you encounter someone from the agency, bad things happen. The definition of your relationship with the people who control your company’s destiny is in terms of anger and angst. That, we would suggest, is at best myopic and at worst dangerous.
Such an ostrich based approach leaves much at risk and denies that there could be a proactive strategy. Much like any sophisticated customer relation program, a proactive strategy begins with understanding the core needs and philosophy of the FAA.
Most agencies depend on ease of administration, and there is actually a chapter in most regulatory law books on the underlying theory. The FAA is responsible for “surveiling” a long list of airline activities—maintenance, pilot competence, training, airworthiness of airframes, powerplants and literally millions of parts. The administration personnel cannot be present at each of these regulatory moments; so the Federal Aviation Regulations (FARs) require what as a surrogate? RECORDS. The papers, that record when a Return-to-Service tag is issued by whom, when and where, consequently are critical to the regulator when (s)he comes to your facility to determine the company’s compliance. RECORDS DEFINE THE RAISON D’ETRE OF MOST REGULATORS. That simple, first observation is critical to a positive regulatory relationship.
For a moment, consider who within your company has the task of keeping those records, where that office is located, and what priority is given to maintaining the required documents. All too often, our experience has been that the record clerk has multiple duties, some (if not most) have direct, visible consequences to the airline’s primary mission—flying planes. If the document person does not get a work order out, the engine will not be maintained and a flight will probably be delayed. That person is encouraged, facetiously, to do all of his/her filing on alternate February 29th’s! Consequently, the FAA documents, we have found, are randomly distributed in piles in the office. The basic “organization” is not well designed. The office is likely dank and dour: not prime real estate. The person assigned to this task is often not on the short track for promotion list.
Now with that picture in mind, consider the impression made on the FAA inspector when arriving to complete an agency prescribed audit. The atmosphere, the disorganization and the attitude all send a message that your airline does not possess the all important compliance disposition. The unspoken message to the federal employee is that with some effort, violations will be found. The proverbial blood in the water attracts sharks.
This is one of the lessons of a Regulatory Affairs course that is taught by three former FAA professionals. Their message is that there are a number of tactics and strategies that if wisely implemented, can convert your antagonistic relationship into a more cooperative approach. Based on their 100-plus years of FAA experience, they convey to their students:
- Valuable research techniques, so that you can cite authoritative interpretations of the FARs
- Who can do what to whom; what the details of the FAA processes mean
- How to develop internal procedures that minimize the risk of FAA enforcement, and at worst, prepare the facts/law of your defense throughout your FAA relationships
- A lot of other practical, useful information
Your airline spends a lot of money on the preventative maintenance of its second most valuable asset. By signing up for this two-day program, you can devote a fraction of that budget to learn how to protect your FAA certificate, an asset that is essential to your operation. Click here to learn about the course and to sign up.Share this article: