Policy originally issued by Administrator Huerta
Field’s reaction was not 100% positive
Acting Administrator Elwell reissues Compliance Policy
Way back in 2015, voices of dissent were heard when Administrator Huerta and Associate Administrator Gilligan issued a new Compliance Policy, The Change was driven by a number of important policy reasons and some practical realities. Some of the long term Aviation Safety Investigators in the field, in particular, questioned the efficacy of the collaboration/ cooperation approach which derives from SMS. The transition to the safety regime which prioritizes finding solutions as opposed to assessing civil penalties, will require time to learn the new rubrics and apply the new policies. Initially, civil penalties were issued, raising doubts about the field’s willingness to follow the orders from Headquarters.
One of the realities of any regulatory agency is delay; if the staff drags its feet, it is possible to wait until new political employees take office hoping that the new Administration will not adopt the policy with which the field disagrees.
There is only one difference between the 2015 and the 2018 documents—the signatures.
The Compliance Policy continues
 The Acting Administrator may not appear to signal Administration endorsement, but before the notice was issued, it had to be approved by both the Secretary’s staff and the OMB analysts.
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