Rep. Graves and Rep. Graves ask the FAA unusually good questions about ODA

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Congress’ insipid practice of setting deadlines for answers in statutes without priorities

Rep Graves (MO) and Rep. Graves (LA) ask good questions

ODA staffing, training and support are critical issues


Congress has developed a pattern of including deadlined requirements to report back on certain specific questions. The FAA Reauthorization Act of 2018 included roughly 400 such requests. It is an odd practice because one of the powers of both Houses is to hold hearings and write questions to obtain such information any time prior to enactment. This requires the FAA to integrate those assignments with the existing regulatory priorities and to do so without any setting of what Congress deems to be more important than others.

This practice has been repeated over the years and the futility of such unspecified goals is shown by the number of mandates which have not been met.

The Republican leadership of the Transportation & Infrastructure Committee and its Subcommittee on Aviation has sent a letter to Administrator Dickson requesting the status of three provisions of the  most recent Reauthorization Act. The requests suffer from a lack of prioritization and all provide adequate time to prepare a response. In fact, all three inquiries involve issues which the FAA is likely doing any way- standards for staffing for oversight of ODAs, the training of inspectors needed to perform this critical mission and a staffing model for these positions.

The questions seem reasonable and the letter may be a clever way to frame the questioning  the Administrator appointed by a Republican President at the next MAX 8 hearing.

T&I Republicans Seek Update on FAA Safety Inspector and Safety Oversight Reporting Requirements

Transportation and Infrastructure Committee Ranking Member Sam Graves (R-MO), Aviation Subcommittee Ranking Member Garret Graves (R-LA), and other Committee Republicans have requested the Federal Aviation Administration (FAA) to provide Congress with an update on several provisions in law intended to ensure the agency has the appropriate number of well-trained safety inspectors to conduct risk-based oversight of the aviation industry, including those with Organization Designation Authorization (ODA).

“Implementing these provisions from the 2018 FAA Reauthorization has become even more important since the 737 MAX accidents,” said Ranking Members Sam Graves and Garret Graves.  “In particular, we need to know where the FAA is in its assessment of its safety inspector workforce and training needs, and its process for updating its strategy for ensuring robust, risk-based oversight of the aviation system.  As the various investigations continue into both the FAA’s certification processes and these accidents that occurred within other countries’ aviation systems, this information will be critical for Congress in considering how to keep our system the safest aviation system in the world.”

[note; the large number of signators]

The text of the letter to FAA Administrator Steve Dickson:

Dear Administrator Dickson:

We write regarding the status of several important safety provisions included in the FAA Reauthorization Act of 2018 (P.L. 115-254; “FAARA.”)  These provisions were included in the FAARA to ensure that the Federal Aviation Administration (FAA) has the appropriate number of well-trained safety inspectors to conduct risk-based oversight of the aviation industry, including delegated activities. The importance of these provisions has only increased in the wake of the two Boeing 737 MAX accidents.  Since the FAARA was enacted more than one year ago, we request an update on the status of the FAA’s implementation of the following provisions:











Section 216. ODA staffing and oversight.
This section directs the Administrator to report to Congress no later than 270 days [1]after enactment on its progress on, among other things, determining what additional model inputs and labor distribution codes are needed to identify ODA oversight staffing needs; and developing agreements and processes for sharing resources to ensure adequate oversight of ODA personnel performing certification and inspection work at supplier and company facilities.

Section 231. Safety workforce training strategy.
This section directs the FAA, not later than 60 days[2] after the date of enactment to review and revise its safety workforce training strategy to align with an effective risk-based approach to safety oversight, utilize best available resources, allow employees participating in organization management teams or ODA program audits to complete appropriate training in auditing, identify a systems safety approach to oversight, foster an experienced and knowledgeable inspector and engineer workforce, and seek knowledge-sharing opportunities between the FAA and aviation industry.







Section 303. Safety critical staffing.
This section requires the FAA, not later than 270 days1 after the date of enactment, to update the safety critical staffing model of the Administration to determine the number of aviation safety inspectors that will be needed to fulfill the safety oversight mission.

As Congress begins to consider what legislation may be necessary to address recommendations from the expert safety reviews undertaken in response to the Boeing 737 MAX accidents, the information learned from implementation of these three provisions and other FAARA reports will be of great assistance.  Therefore, we request a written response detailing the status of the FAA’s implementation of these three provisions.  Should the implementation of these provisions be incomplete, we would encourage you make them a priority and accelerate their completion. 

Given the lessons of the Max 8 investigations have made it clear that the Organization Delegation Authorization must function well to make this regulatory construct better protect aviation safety. The ODA-OEM communications must function at a high level of openness and a deeper level of granularity.

This is not to say that the FAA response will be easy. The Aviation Safety organization is transforming the location of its staff, making a major change in the skill sets of the staff and reconsidering how the work will be done. All of those revisions may delay the ability to respond the Graves and Graves three questions. Here are some explanations of the confusion:

FAA Legal Reorganization Is An Effective Mechanism Of A New Compliance Policy Now

Two Important News Stories On The Way To The New Aviation Safety Cornerstone

It’s A New Flight Standards Service- Here’s How The CHANGE Is Being Managed

Change, Change, Change Is Coming To Flight Standards, For Better

FAA Organizational Evolution Is Required For A Proactive Agenda

The New Part 23 May Lead To A New AIR Organization: Why & What?

New FAA Compliance Policy A Sea Change From Enforcement—10 Forcing Elements

The FAA needs to answer these three questions and hopefully their reply will satisfy Congress.


[1] October 5, 2018 + 270 days = July 2, 2019


[2] October 5, 2018 + 60 days = December 4, 2018


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