DOT IG provides FAA with good guidance on Organizational Delegation Option

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DOT’s Fiscal Year 2020 Top Management Challenges

OIG usually hypercritical of FAA

TMC19 lists more aviation challenges than other DOT modes

OIG makes some good recommendations as to FAA ODA issues!

The Inspector General, among many duties, annually analyzes the agenda which the Secretary and her operating divisions face. Congress also commissioned the OIG to determine the DOT’s top challenges. (2019 Top Management Challenges [TMC19] One of that office’s primary focuses has been aviation[1]; so it is not surprising that this year’s list includes a top heavy number of FAA issues:

 

The Aviation TMC19 cites aircraft certification, air carrier safety oversight, airspace modernization, cybersecurity and the future of transportation (UASs, eVTOLs, UTM, etc.) The TMC Report actually provides some useful criticism of the Organizational Delegation Option, which has been the source of considerable, visible discussion by the media and Congress.

Key Challenges

  • Resolving certification issues related to the Boeing 737 MAX aircraft
  • Enhancing FAA’s oversight of aircraft certification processes Resolving Certification Issues Related to the Boeing 737 MAX Aircraft

 

Here is what Mr. Scovel and his team advised about the FAA certification policy, procedures and practices:

 

 

Enhancing FAA’s Oversight of Aircraft Certification Processes 

Recognizing that it is not possible for FAA employees to oversee every facet of such a large industry, Federal law allows the Agency to delegate certain functions to private individuals or organizations. Designees can perform a substantial amount of critical certification work on FAA’s behalf. For example, in 2018, one aircraft manufacturer approved about 95 percent of the certification activities for its own aircraft. In 2009, FAA fully implemented the Organization Designation Authorization (ODA) program to standardize its oversight of organizations (e.g., manufacturers) that are approved to perform certain delegated functions on its behalf.

While delegation is an essential part of meeting FAA’s certification goals, the Agency faces the significant oversight challenge of ensuring that ODA companies maintain high standards and comply with FAA safety regulations. Our work over the years on the ODA program has identified management weaknesses with a number of FAA’s oversight processes. For example, our 2011 report identified inconsistencies in how FAA aircraft certification offices interpreted FAA’s role and tracked ODA personnel for oversight. In response to our findings, FAA improved its training and guidance for FAA engineers responsible for overseeing ODA employees, leaving them better positioned to detect regulatory noncompliances and take enforcement actions.

 

 

 

 

 

In 2015, we reported that FAA’s oversight of ODA program controls was not systems- and risk-based, as recommended by an aviation rulemaking committee, but rather was more focused on individual engineering projects and areas that were low risk. For example, FAA had not provided oversight teams with tools or guidance on data they should use to identify the highest risk areas. Another gap in FAA’s oversight pertained to companies that produce and supply components to other manufacturers. FAA performed oversight of only 4 percent of personnel conducting certification work on the Agency’s behalf at suppliers in the period we reviewed.

 

In responding to our 2015 report, FAA recognized the need to improve its oversight of organizations performing certifications or other functions on its behalf. By March 2020, FAA plans to introduce a new process that represents a significant change in its approach to overseeing ODA companies. For example, the new process will include identifying critical system elements and developing new evaluation criteria. While revamping FAA’s oversight process will be an important step, continued management attention will be key to ensure the Agency identifies and monitors the highest-risk and safety-critical areas of aircraft certification.”

 

 

 

 

 

 

 

 

 

 

 

 

No doubt that the FAA, with the help of Congress, implemented ODA for good reasons. Equally valid, public opinion has lost some confidence in the Boeing ODA specifically and this authorization generally. One possible response is to separate any ODA from the company for which it is providing the surrogate judgments of the Administrator.

The suggestions of the OIG in its TMC19 report should be carefully considered by the FAA.

[1] A SAMPLING: Inspector General Finds That In Spite Of FAA ATO’s 51 Cost Saving/Productivity Efforts, Per Flight Costs Have Increased; Surprise! The OIG Finds Serious Faults With STARS, But Is The Inspector A Nattering Nabob Of Negativity?; OIG Report On SUPs Should Reenergize FAA & Remind Industry Of The Risk; NOT GOOD: DoT IG’s Opinion On NextGen’s Expenses, Completion & Future Costs:



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