OIG charge from Congress , to study pilot training standards worldwide, is ill-timed, should wait for experts to finish and potentially damaging

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As stated in the below February 10, 2020 memorandum from the Department of Transportation Office of Inspector General (OIG) announced a review requested by the Chairmen and the Ranking Members of the House Committee on Transportation. The subject is pilot training, US and International as well as interaction with computers.[See also the longer article by Flight Safety Foundation’s AeroSafety World.] The inquiry seems straight forward, but as with most high profile issues, it is incredibly complex and arguably poor choice of issue/timing.

1. It is most evident that the recent aviation events have not endeared the United States to the international aviation community. [i.e. FAA’s Past International Profile And A Look How To Reinvigorate Its Reputation; Reflections On The Global System Aviation Safety Audits.] Since 1992, FAA has audited the other CAAs around the world under a Congressionally inspired International Aviation Safety Assessment program. FAA staffers with aviation standards have gone to the offices of sovereign authorities and have assessed their technical competence. Now, OIG investigators, who are not trained flight safety inspectors familiar with the FARs or the ICAO standards, will examine whether those IASA findings as to the foreign governments competence to train their pilots were adequate. No doubt these OIG likely findings of faults will exacerbate an already bad situation.FAA global relations

2. A body with particular expertise of aviation standards, the International Civil Aviation Organization (ICAO), several months ago, initiated a process to review pilot licensing requirements. The Flight Safety Foundation submitted a working paper on pilot training and competency for consideration at the ICAO 40th Triennial Assembly. It might be a more efficient use of the OIG resources to wait for this expert body’s assessments. The Ranking Members of both the full T&I Committee and the Aviation Safety subcommittee sagely made this point:
A spokesman for Rep. Sam Graves (R-Mo.) and Rep. Garret Graves (R-La.), said they hope the IG’s review also will examine how the FAA works with other civil aviation authorities at the International Civil Aviation Organization setting standards for pilot training.

“The ranking members believe this audit is another critical facet of the investigations after the two 737 Max accidents, and that every potential factor in those crashes has to be examined in order to best ensure future safety,” the spokesman said. “This includes ongoing reviews of the FAA’s aircraft certification processes.”

Graves and Graves

3. No technical aviation safety problem is more complicated than the interface between a universe of pilots and the evolving computer systems that assist in operating an aircraft. As the then NTSB Chair Chris Hart explained it in a prescient 2016 speech,

At the ALPA 62nd Safety Forum NTSB Chairman, the Honorable Christopher A. Hart, himself a licensed pilot with commercial, multi-engine, and instrument ratings, spoke to an audience of 400+ delivered a simple message, “the good news is that there is more automation; and the bad news is that there is more automation.”

The specific words from his address were:

“The most fundamental lesson that we have learned from our accident investigation experience is that introducing automation into complex human-centric systems can be very challenging…The problems that we have seen thus far from increasing automation include increasing complexity, degradation of skills, complacency, and the potential loss of professionalism.”

Max 8 MCAS console

Resolution of the safest balance between the human element and the computer is neither intuitive nor likely to be completed in the near term. As the Chair pointed out, the multiple dimensions of the problem include the increasing complexity, degradation of skills, complacency, and the potential loss of professionalism.

In addition, the investigations of causes of the two accident are incomplete. However, two theories seem to have some merit—the task-based training of the pilots of these two aircrafts and the miscalculation by Boeing software engineers of the pilot response time to the MCAS warnings .

Under these circumstances, an OIG conclusion would appear to be premature and not based on the best information.


audit language

U.S. Agency to Probe FAA Oversight Practices
by AeroSafety World Editorial Staff | February 11, 2020

AeroSafety World LOGO


The U.S. Federal Aviation Administration’s (FAA’s) oversight and certification practices will be the subject of a review by a government watchdog agency, which says it is especially interested in the process used by the FAA to establish pilot training requirements for the Boeing 737 MAX.

The Department of Transportation’s Office of Inspector General (OIG) said Monday that the review, which will begin later this month at the request of members of the U.S. House of Representatives, was prompted by concerns associated with the fatal crashes of two 737 MAX airplanes.

The crashes involved Lion Air Flight 610 on Oct. 29, 2018, after departure from Jakarta, Indonesia, and Ethiopian Airlines Flight 302 on March 10, 2019, after departure from Addis Ababa, Ethiopia. All passengers and crew in both airplanes ─ a total of 346 people ─ were killed.

The FAA certified the 737 MAX in March 2017.

“These fatal accidents have drawn widespread attention to FAA’s oversight and certification practices, including the agency’s process for establishing pilot training requirements for the aircraft,” the OIG said. “For example, at the time of the October 2018 fatal accident, pilots were reportedly unaware of the new automation system ─ known as the maneuvering characteristics augmentation system (MCAS) ─ that Boeing included on the MAX aircraft to improve aircraft performance.”

The report by the Indonesian accident investigation authority said that a contributing factor to the crash was “the pilots’ response to erroneous activation of MCAS.” The pilots’ actions raised “international concerns about the role of pilot training” in the accident, the OIG said.

In response, leaders of the Aviation Subcommittee of the House Committee on Transportation and Infrastructure asked the OIG to review domestic and international pilot training standards for commercial passenger airplanes, including training on automation.

The OIG said it would conduct that review and also examine requirements by other civil aviation authorities regarding pilot training on the use of flight deck automation.

It is axiomatic to say that answers to the question posed need to be promptly resolved. An OIG audit does not appear to be the best process to identify substantial solutions. Aggressive DoT auditors getting involved in the delicate, perhaps even strained, relationships between the FAA and its international equivalents.

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