Rep. DeFazio’s Request for a DoT OIG audit of ODA should look forward to SMS/SAS/SASO not back to surveil/ inspect

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REPORT: Audit Initiated of FAA’s Oversight of the Organization Designation Authorization Program


Representative Peter DeFazio, whose experience on aviation issues extends back more than 40 years, has asked the DoT Inspector General to review the oversight of the Organization Designation Authorization (ODA) program. This delegation was designed to replace the FAA’s SFAR 36 authority, which appeared to have been granted to too many companies. The new ODA regime is both more carefully designed and incredibly necessary for the FAA Airworthiness certification responsibility to work.

Rep. DeFazio’s specific request includes the terms “oversight” and “surveillance.” Those words reflect his familiarity with the FAA’s past practices. To fulfill their regulatory obligation in the past, Aviation Safety Inspectors, Principal Maintenance Inspectors and Manufacturing Inspectors created an annual work schedule which included visits during which the FAA staff person would visually inspect the facilities, review the records and examine the credentials/experience/ability of the ODA, as an example, organization.

That’s the past.

The Congressman has seen the last ten years of FAA budgets pass through Congress and must have noticed that the personnel budget is getting tighter and tighter. He also must have participated in Transportation & Infrastructure Committee hearing in which Safety Management Systems, Safety Assurance System and System Approach for Safety Oversight have been discussed in detail. These acronyms are the vocabulary for the future FAA regulatory regime.

No longer will the field staff follow a routine of visits to certificate holder on a calendar basis. Those same “inspectors” will receive an ODA’s SMS report, which identifies what rules, practices, procedures or personnel which that rigorous process has identified as requiring the company’s greatest attention. That data will be incorporated in the discipline of SAS, that program will analyze and rank risks and then SASO will identify which certificates require further scrutiny, what should be examined and what priority will be the products.

These should be the focus of the IG review. Yes, SMS, SAS and SASO are not fully developed. The Congressman’s request is to determine the efficacy of “surveillance” and “inspection” today. That premise ignores that the OIG’s recommendations will not have much longevity. It will be far more productive for the OIG to use its audit time to help the FAA refine these tools of the future.

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