The Department of Transportation (DOT) and the Federal Aviation Administration (FAA) have recently taken a much tougher stance on enforcement actions with air carriers, manufacturers and maintenance repair organizations. The number of fines and enforcement actions has increased year after year. Whether this tougher enforcement stance is warranted remains to be seen. Critics postulate that the punitive approach will make certificate holders hunker down and abandon voluntary reporting given the possibility that the report will result in a fine. Hard-line enforcement types say it protects consumers and ensures operators toe the line.
Traditonally, the avaition industry has taken a reactive approach to dealing with Letters of Investigation (LOIs) and enforcement actions. The FAA issues an LOI, and the certificate holder reacts (defensively) and does not understand or agree with the action taken by the regulator – typical and not unexpected. As a result, the business relationship between certificate holder and the FAA becomes more contentious.
What kind of relationship do you have with your FAA Certifcate Management Office or Flight Standards District Office (FSDO) principal inspectors? Do you treat them like the enemy and , respond defensively, or are they your best golfing buddy? Hopefully neither of the cases apply to you or your organization!
Here are some suggestions for creating a positive and professional business relationship with the FAA.
- Create a regulatory affairs organziation or FAA/industry liasion group – name is up to you but it should define the role.
- The size of the regulatory affairs organization should refect the size and complexity of your company – a 1-person department or a 4-6 person staff are both OK.
- Have a regulatory affairs office and locate it close by where FAA personnel arrive at your facility – even a sign that says FAA please check in here may be appropriate.
- Create a regulatory Standard Operation Procedure (SOP), forms and data reports.
- Dessiminate information throughout the organization so employees are aware of your process and procedures – conduct all-hands training as necessary.
- Ensure all other line stations or other company locations that receive FAA inspectors are trained and use these procdures – consistency is the key!
- Treat the FAA like a customer: Assist the FAA whenever they show up at your facility.
- Log their name, time in and out and purpose of the visit– keep these records.
- Escort the FAA while they are conducting business. If they are attending a meeting drop them off, and ensure someone escorts them after the meeting.
- If the FAA requests copies of records or files, ensure that they are provided with copies promptly. Make sure you log what they received, take notes during any visit and enter the information into a data file.
- When you are with the FAA representative, listen more and speak less – no one ever learned anything by talking and what you say may come back to haunt you.
- Establish great record keeping standards. This applies to the entire organzition not just Regulatory Affairs.
- Become knowldegable of regulations and FAA policies. The www.faa.gov website is a great resource, but it is complex, so make the necessary time to become familiar with the site.
“We’re not one big happy family.” Your job is to build a positive working relationship with the FAA. Creating a pseudo-family isn’t part of the job. You should absolutely be friendly, but you should not be best buddies. Don’t say you have the interpersonal and professional skills to strike the right balance, because you don’t – no one has that ability.
“You won’t have all the answers and neither will the FAA.” Just because someone works at the FAA, does not means that all their views and opinions are valid. Positions and promotions don’t always come with wisdom. Always assume you don’t have all the information you need to make a great decision or respond to a request; that way you’ll listen more than you speak.Share this article: