NTSB Board Member Goglia and FAA as Gold Standard
Better Listening and More Focus on Public Safety
Six Suggestions to Improve FAA Stature
John Goglia has been a point of reference here more than any other aviation safety expert. As usual, the former NTSB member (10 years), aviation maintenance technician, and noted commentator (under the apropos title “Torqued”) has made some cogent comments about the current stature of the Federal Aviation Administration (FAA) in the United States, within the aerospace engineering academy , and among the global Civil Aviation Authorities community. John’s “Can the FAA Win Back the Aviation Safety Gold Standard?” traces how this loss of altitude was precipitated by two, recent tragic crashes and then offers two suggestions of how to rectify this loss of imprimatur:
- “…should start listening to its employees and the employees of regulated entities in the same way it listens to executives of those regulated entities”
- “agency executives, managers, and supervisors to always act as though they work for the public and not the aviation industry”
The decline in the FAA’s stature has had a long low profile. Some of the reasons are exogeneous variables (like Congress) and as John has aptly pointed out, much can be attributed to internal attitudes.
As the posts listed in FN2 explain, this trend has long and deep roots and our analyses support Mr. Goglia theses. Focusing not on the past, but on the future remedies. Here are a few suggestions—
- People matter and the lessons of the Max 8 internal (Boeing and FAA) suggest that the communications between and among the participants were dysfunctional. Sadly, this pattern appears to be absolutely contrary to SMS and this discipline appeared not being applied (within the FAA[ upper management- field with direct responsibility]), between the FAA local office and the Boeing ODA; between the Boeing ODA and their management; between the Boeing senior management and the FAA senior management [especially Washington]). THIS ABSURD: the FAA is the advocate for SMS and the authority assigned to assure implementation (not just externally). The FAA has a significant segment of its administration assigned to SMS’s success:
FAA and Aviation Safety SMS Program Manager:
Director, Safety Management and Research Planning Division, AVP-300
Air Traffic Organization Safety Management Group Manager:
Office of Safety Standards, SMS Program Office
Airports (Part 139) SMS Program:
Part 139 SMS Program Manager, AAS-300
Acting Manager, Airport Safety and Operations Division
Aircraft Certification Service System Performance and Development Branch Manager:
Designated Federal Official for Office of Aviation Safety SMS Aviation Rulemaking Committee:
Chief Systems Engineer for Aviation Safety
SM International Collaboration, ICAO Annex 19 and Industry Outreach:
Director, Safety Management and Research Planning Division, AVP-300
The structure is there, but effective SMS begins with the leadership inculcating safety culture in every corner of the organization. It would appear that the Administrator should continue to be the Apostle for a SMS Reaffirmation in all disciplines and at every level of his organization. Boeing should engage in a similar reaffirmation of SMS.
- John’s next point has to do with all FAA staff focusing on aviation safety and the public—not the regulated entities (Fred Bruggeman, Aircraft Engineers International calls the phenomena “CAPTURE”; so EASA may have the same problem). SMS should resolve this conflict by including all of the relevant parties in the process. Transparency should eliminate the appearance of industry influence and place any economic considerations on the record.3. FAA Administrator—By setting the term for an Administrator appointment is not a great idea. In particular by establishing a five-year period creates a political anomaly; Presidents have a four year term; so, there is no congruity between the appointer and the appointed. That’s breaks the political rational for AOA-1 selection by the Administration. Why not require that the Administrator possess SIGNIFICANT aviation experience and then allow her/him to continue in the office as long as performance is sustained. Greater qualification hurdle and an indefinite time in office places more stress on relevant knowledge and time to complete initiatives. Transitions create disruptions—needed?
- The FAA is an operating mode of the DOT and within the Cabinet level umbrella APPEARS to be subject to political considerations. Administrator Halaby argued for aviation safety’s inclusion in the new DOT to assure that it receive adequate funding for its budget that comes from one sitting at the table with the President. Recent history suggests that Secretaries vary in their advocacy for the needed dollars. Might it make sense to return the FAA to its independent status?
- FAA Funding: one analyst has urged that the agency’s budget desperately demands an increase. Added funds for the talent deficiency should be a 2021 proposal of the White House and Congress. The added dollars should attract the numbers and quality of staff needed to determine the airworthiness of aircraft which involve ever more complexed, advanced technology.
- INTERNATIONAL AVIATION: (see FN2) the FAA’s stature has suffered among their peer agencies for a variety of reasons. Its international footprint is shrinking. There are more options that could help FAA expand its impact – USTDA, IASA bolstering FAA international offices and staff. While the US has abandoned important overseas initiatives, EASA has declared that it will increase its international outreach (Monroe Doctrine?)—not just to benefit aviation safety, it is fair to assume. The pan European organization is placing products from their Member States around the world. Congress must recognize that this form of “promotion” does not blur the FAA’s safety focus, but does expand the influence of US safety standards.
There are other aspects of the FAA which could benefit, but the Goglia agenda provides a useful basis to consider how to return the FAA to the Gold Standard.
by John Goglia
– November 2, 2020, 8:00 AM
Being the best matters in aviation as in other industries. Being perceived as the best matters, too, if you believe that perception is as important as reality when it comes to aviation safety. For the FAA, being considered the gold standard for aviation safety oversight has been a matter of pride for many up and down the agency’s chain of command. I have heard bragging about this from FAA administrators as well as from executives, managers, and inspectors in offices around the country and in far-flung places.
Being the gold standard, of course, was of immeasurable benefit to aviation entities in the U.S. People buy U.S. aviation products, fly U.S. airlines, and use U.S.-certificated maintenance repair stations because of the confidence they place in the safety oversight that these entities are subjected to by the FAA.
That gold standard has been severely tested by the two 737 Max crashes. The first occurred on Oct. 29, 2018, when Lion Air Flight 610 crashed into the Java Sea 13 minutes after takeoff from Jakarta, Indonesia. The second occurred less than five months later when Ethiopian Airlines Flight 302 crashed just six minutes after takeoff from Addis Ababa, Ethiopia. The two accidents killed a total of 346 people, including eight Americans. And thus began the tarnishing of the FAA’s reputation as the world’s preeminent aviation safety authority. Recovering from that tarnishing is important to the critical safety oversight work that the FAA does and also to the American entities that depend on it.
As I write, one more report has been issued criticizing the FAA for its oversight of Boeing and the tragic 737 Max accidents that resulted. …
The House report was preceded by a U.S. Department of Transportation Inspector General report. It will likely be followed by other reports. Criminal prosecutions may also result as the Department of Justice has convened a grand jury to review whistleblower complaints regarding the lead-up to these accidents.
Reports criticizing the FAA are nothing new, of course. After every major accident or incident, fault can be found in many places including the government agency responsible for safety oversight. What hurt the FAA’s safety standing are the actions nations of the world took to ground the 737 Max before the FAA took similar action and, most disturbingly, while the FAA continued to insist on the safety of the aircraft. No report can compare with the reputational hit the FAA took when countries decided that safety demanded that they ground the aircraft regardless of what the FAA said about its safety. Whether done for purely safety reasons or partially for political or economic reasons, the impact was to tarnish the FAA as setting the gold standard for aviation safety.
As the FAA enters its final deliberations on restoring the 737 Max to operation, it’s also time to consider how the FAA will prove to the world once again that it deserves to be considered the preeminent safety oversight organization. My suggestions are twofold.
First, the agency should start listening to its employees and the employees of regulated entities in the same way it listens to executives of those regulated entities. For years I have seen the safety concerns of FAA employees, pilots and mechanics, and other employees of regulated entities given short shrift by agency supervisors and managers. If an employee raises a safety issue, take the time to analyze that issue and reach a decision based on a proper safety risk analysis. Of course, the FAA will not always agree with its employees or the employees of aviation entities raising concerns, but it should thoughtfully consider and properly analyze those concerns. Too often, I have not seen that happen in accident investigations I was involved in.
My second suggestion is for agency executives, managers, and supervisors to always act as though they work for the public and not the aviation industry. Stop kowtowing to the industry and stop pressuring employees when industry executives complain. Treat the industry at arm’s length as a safety regulator should. Of course, the industry’s input and concerns are critical, but they are not the ultimate concerns. It will take time for public confidence and international confidence in the FAA to return. But I am confident that it can.
 John Goglia Is The 2020 Laura Taber Barbour Air Safety Award Sir Stewart Matthews Honorary Winner; John Goglia’s Position On SMS Is An IMPORTANT READ; Two Well-Earned Recognitions To Member John Goglia; John Goglia’s ValuJet Lessons As Flags For SMS Teams; Today’s AeroBio Is John Goglia; Child Safety Restraints For Airplanes: Goglia Speaks; Industry Listens & Must Carry The Message Further; Goglia’s AMT Fatigue Needs SMS For Solutions; Member Goglia’s Article On SC Military/Civilian Collision Suggests That An SRA Might Enhance Safety There And At Other MOAs; THE AEROSPACE MAINTENANCE OLYMPICS- 2019; Aircraft Maintenance Competition Promotes Excellence In The Craft And Designed To Attract Future AMTs
 The FAA Is Closing Its International Field Offices; Does It Matter?/ FAA’s Past International Profile And A Look How To Reinvigorate Its Reputation; USTDA’s Hardy Might Consider Using His Authority To Help Reinforce The FAA’s Gold Standard;One MAX 8 Immediate Actionable Aviation Safety Lesson For International Aviation Safety
 Paul Weisbrich, managing director of investment banking at D.A. Davidson adds that while not directly responsible for it, in his mandate Trump has failed to revitalise the country’s struggling FAA. “The FAA is one of those perennially underfunded areas,” he says. “It’s like a can that keeps getting kicked down the road and the problems it has are going to keep on coming.”
An issue that has persisted, he says, for the past three administrations, it’s currently exacerbated by new cybersecurity challenges and the rise of unmanned aircraft in the US commercial aviation.
“Whoever is president next is going to inherit an underfunded FAA in a pandemic with a budget under a lot of pressure but several other issues,” he comments
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