The Boeing and FAA ACO communications further deteriorate

Old Boeing Board
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FAA ACO announces limitations on Boeing ODA

Press emphasizes failed communications between the two

FAA Aviation Safety Organiztion has been traumatized

ODA’s legislative roots may contribute to tension

Boeing senior leadership needs to address this SOON

An FAA manager has issued a restrictive decision about Boeing’s future use of its Organization Delegation Authorization (ODA). While the limitation of this authority was not surprising, the back story is relevant to understanding of the Boeing-FAA mess.

Here are some observations that help put this debate in context

I. The FAA Aviation Safety Organization (AVS)has experienced much disruption over the past 5-10 years.

    1. An important leader, who initiated a number of sea changes, retired.
    2. Her replacement incurred a major crisis, which he did not weather.
    3. After a lengthy search, a successor (Billy Nolen) was hired, but as an outsider, his rolodex did not include the names of internal support needed to move the pending agenda forward.
    4. While these chairs were shuffling, an experienced FAA professional, who had succeeded in a number of AIR positions, was named to run the certificationFAA org merry-go-round organization (Liro Liu) replacing another veteran in the service.
    5. Last, but not least, the FAA Administrator announced his retirement and the Secretary of Transportation named Nolen to be Acting Administrator. Behind those personnel shocks, two senior Aviation Safety executives left.
    6. With this merry-go-round, it is highly unlikely that the FAA headquarters has much stroke out in the field,



II. Simultaneously, the entire AVS was dealing with a number of new policies that changed the way that these civil servants are called on to do after careers in which their performances were measured against different tasks.

FAA policy sea change

    1. The institution of the Safety Management System (SMS) as the primary method of regulating certificate holders. The shift from enforcement and sanctions to compliance and cooperation shocked many in the field who for years had used  threat and punishment as their leverage with the regulated.  These professionals were frequently collocated with their AIR peers and saw their distress.
    2. More directly, the headquarters AIR leaders spent years defining a new means of determining airworthiness. This rubric has been applied to the Part 23 certifications. The old measure was prescriptive in nature; the TC applicant had to submit a number of specific measurements for assessment. Now the methodology is “performance” based; aspects of a proposed aircraft which is different from prior applications are subject to appropriate ASTM process(es) to determine the relevant criteria. This disruption was not well received by the field and the transitional training was found to be less than needed.
    3. To achieve all of new directions, the entire AVS organization was reordered and many career employees were requested to relocate. These disruptions affected all in the AVS.

III.Most directly relevant to the below announcement of the future restrictions on the Boeing ODA, these stories presage the bad interactions”

      1. The creation of the Boeing ODA was the direct result of Congress’ passage of legislation which authorized all TC applicants to review, on the behalf of the Administrator. Part of Boeing’s motivation in seeking an expanded ODA was a difficult track record between the FAA and the ACO over the validity of analytical approaches and data.
      2. The MAX 8 debacle eventually disclosed the disdain between the FAA staff and the Boeing representatives. As the investigation evolved, it was evident that the OEM failed to fully discharge its duties under the authorizations—
        1. Time For ODA Order Chapter 7 Action On Boeing ODA?
        2. New York Times Article- Is It Time To Reconsider The Boeing ODA?
        3. Should/Can The FAA Modify The Boeing ODA???

Quite clearly, this disastrous Boeing performance justified the emasculation of their ODA as announced below.

It is pretty clear that what we have here is a failure to communicate. Repeated public statements by the ACO criticizing the work of Boeing appear not to have been taken seriously in that the May 31st letter (mentioned below, but the document unseen) appears to repeat these themes:

          1. Aviation SafetyWhistleblower Report
          2. FAA warns Boeing may not win certification for 737 MAX 10 by year-end

Ian Won, acting manager of the FAA aviation safety office that oversees Boeing, asked the U.S. planemaker in a letter dated March 21 to provide a “mature certification schedule,” according to a source familiar with the letter. Won also sought updates on progress for both the 737 MAX 10 and 777-9.

3.Feds: Boeing staff hires ‘not meeting FAA expectations’.

The FAA letter was signed by Ian Won, the acting manager for aviation safety of the FAA’s local office that oversees Boeing, and Melissa Sandow, the FAA’s system oversight manager.

3.FAA opens new Boeing safety review after employees warn about conflicts of interest

“Boeing’s company culture appears to hamper members of the ODA unit from communicating openly with the FAA,” wrote Ian Won, acting manager of the FAA’s Boeing safety oversight office. “Further, the organizational structure also appears to provide a strong influence on how unit members are appointed, managed, and allowed to perform authorized functions, which provides ample opportunity for interference rather than independence.

Without more, it’s hard to determine who might be the responsible party or parties; however, it is clear that the relation is broken and intervention at a higher level is urgently needed. The origins of the MAX 8 disaster, by its own admission, was a lack of oversight by senior management and the Board. A trip from Chicago and Washington DC to Des Moines, WA would be my recommendation to Boeing

failure to Communicate


Federal regulators say they will keep closer eye on Boeing

FAA wants to assess ‘multiple’ improvements over the next 3 years

FAA NW Mountain Region and ACO WASHINGTON — Boeing employees will still be allowed to perform some safety analysis on the company’s aircraft, but for three more years instead of the five-year extension the company requested, federal regulators have determined.

Federal Aviation Administration officials indicated Tuesday that the agency’s decision on the safety-related work was designed to keep a closer eye on Boeing BA, -1.39%.

Under rules in place for more than a decade, employees of aircraft manufacturing companies can be deputized to do certain tasks for the FAA. That practice came under more scrutiny after two deadly crashes involving Boeing 737 Max jets and allegations that Boeing employees misled regulators about a key flight system on the planes.

Boeing’s ability to do that work for the FAA was due to expire Tuesday.

In a letter to Boeing, an FAA safety official said a three-year renewal was “more appropriate” than a five-year extension.

“There are multiple in work improvements that the FAA would like to assess within the Boeing organization over the next three years,” Ian Won, acting manager of the FAA office that oversees Boeing, told the company.

The list of items that the FAA wants Boeing to complete in the next three years includes ensuring that employees who help the FAA are protected from pressure by company managers, and making sure that Boeing quickly corrects any problems it finds.

Boeing issued a statement, which in its entirety read, “As always, we are committed to working transparently with the FAA through their detailed and rigorous oversight processes.”

The FAA also said its inspectors — and not Boeing employees — will continue to be responsible for issuing final safety certificates for all new Boeing 737 Max and 787 jets rolling off the company assembly lines. That was a step taken in November 2019, during a 19-month grounding of the Max following crashes in 2018 and 2019 that killed 346 people.

Deliveries of the 787, which Boeing calls the Dreamliner, have been halted most of the past two years because of a series of production problems. That is depriving Boeing of cash, because buyers typically pay a large portion of the purchase price for jets on delivery.

FAA inspector delivering a Certificate of Airworthiness


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