The Seattle Times article by Kyung Song leads the reader to believe that the FAA abdicated its safety and certification duties on the B-787. More specifically the piece critiques the design and associated approvals for the Lithium Ion battery system to Boeing – akin to the fox guarding the chicken coop. He referenced that Boeing has what is called an Organization Designation Authorization (ODA) to act as proxy on certification oversight. Kyung Song also stated that Boeing became an FAA designee with wide latitude in picking the company’s own engineers to sign off on their employer’s work on behalf of the FAA. Previously, the writer points out, engineers in that role were approved by and reported directly to the FAA.
Unfortunately, the article fails to go into sufficient detail to explain the ODA processes that the FAA delegates, after an extensive qualification process, to organizations like Boeing. ODA, in fact, increases the efficiency of FAA oversight through a systems safety management approach. The Boeing engineers now are extremely conscious that they are exercising the powers of the FAA, actually add to the agency’s expertise. In this case, Boeing is required to send its certification plans to the FAA, explaining what it wants to make and how it wants to accomplish the associated designs and testing. In response thereto, the government may add tests, enhance standards or require additional analyses. Then, the FAA may delegate those activities which are subject to the ministerial actions of the company’s employees/FAA designee, ONLY if the company has shown that it has accomplished the specific type of certification testing many times before. Under an ODA when there is anything new and novel, such as the use of Lithium Ion battery system, the FAA must be involved significantly more in both the definition of the tests/analyses and the review of the results.
For every project that the ODA wants to exercise, its designee authority must be submitted as a very specific certification plan and approved by the FAA. The FAA is responsible for audits, certification plan approval, training and coordination. The key to a successful program, as well as the FAA oversight of the ODA, is the ODA procedures manual. First and foremost, systems oversight means that the FAA is going inside the halls of a company and helping to define the processes and expectations by which that company needs to work, including quality and technical procedures. The second component of the system is the daily interaction between the FAA and the company with the ODA. The third piece is the FAA biennial audits. If issues arise, the onsite visits can become much more frequent. All three steps allow the FAA to be more engaged from an oversight perspective.
Under the ODA, the FAA can gather data and look for trends, best practices, and critical issues, identify critical risks, and adapt policies throughout the certification process. ODA companies work to the same standards and requirements as the government personnel would. This delegation allows the FAA to look across similar ODA holders and the agency’s broader perspective, looking at other comparable ODA tasks, helping to find hidden precursors and failure modes.
Examples of the insights gained through the ODA perspective include discovery of improper assumptions made during certifications, equipment trends, reliability issues and human factor issues. Spotting these trends could help to adjust policy, improve oversight and reduce risk.
If a company has a strong organization, tight discipline, strong engineering skills and risk assessment methods, an ODA is of great benefit to both the company and the FAA. In the future it would behoove writers like Kyung Song to do some research and review the FAA procedures for ODA.Share this article: