What did the OIG really find in its audit of Boeing-FAA ?

JDA Aviation Technology Solutions

Something is and has been wrong in the relationship between the REGULATOR, the FAA and the Regulated, the Boeing Company. Many have opined as to where the problems emanate from, but now the US Department of Transportation’s Office of Inspector General  audited both organizations between July 2022 and August 2024. The OIG team had access to

• FAA’s Orders on Certificate Management of PAH (Order 8120.23A), on Organization Designation Authorization Procedures (Order 8100.15B). on Supplementary FAA Orders 8000.17 and 8000.18 on FAA’s Aircraft Certification Service Compliance Program, on Order on Compliance and Enforcement Program (Order 2150.3C) and associated inspector guidance;
• International Quality Management System standards for the Aviation, Space, and Defense industry;
• Settlement agreements between Boeing and FAA;
• Multiple independent reports on Boeing’s production issues, including an
• NTSB report and joint FAA-industry reviews from 2014 and 2024;
• FAA’s CEA system for compliance and enforcement reports and Boeing’s voluntary disclosures; Exhibit A. Scope and Methodology
• Audits from the ACAIS database
• Documentation for 737 and 787 aircraft production, including manufacturing defect data and FAI reports; and
• Correspondences between FAA and Boeing regarding aircraft production and Boeing’s ODA
• The OIG was briefed by FAA’s Oversight Division in Des Moines, WA, and North Charleston, SC, conducted interviews of FAA managers and Aviation Safety Inspectors and spoke to FAA’s Audit and Evaluation group regarding complaints of Boeing’s production and undue pressure.
• The auditors interviewed and received briefings from Boeing, which included further documentation regarding Boeing’s policies and procedures related to the production process and suppliers.
• The team visited Boeing facility centers in Washington and South Carolina, where we observed the 737 and 787 final assembly lines.
• The investigation included briefings from interviews of officials from Spirit AeroSystems and meetings with FAA’s inspectors performing audits at the facility.
• Public complainants, a/k/a “whistleblowers”, spoke the team regarding Boeing production issues and allegations of undue pressure.
• The OIG sought the opinions of the industry labor group, the Society of Professional Engineer Employees in Aerospace, regarding concerns of Boeing’s production.

With this massive accumulation of relevant information, the Assistant Inspector General for Aviation, Nelda Z. Smith[1], signed and issued a

a comprehensive 42 page report. The tone and facts cited in her report contributed to a response by the FAA that it concurred “with ALL THE OIG’S RECOMMENDATIONS.”

Here are the 16 findings about what must be better!!!

”What We Found : Weaknesses in FAA’s oversight processes and systems limit its ability to identify and resolve Boeing production issues.

• FAA’s approach to overseeing Boeing manufacturing and production does NOT USE DATA-DRIVEN ASSESSMENTS to target audits, and FAA has not structured its audits to perform comprehensive assessments.

• FAA has not adequately ensured that Boeing and its suppliers can produce parts that conform to the approved design. FAA does not require its inspectors to review First Article Inspections that are intended to ensure a manufacturer’s processes can, at the outset, produce parts that meet engineering and design requirements.

• Further, FAA’s compliance system cannot track milestones or determine whether potential repetitive noncompliances have occurred, nor has FAA assessed the effectiveness of Boeing’s Safety Management System.

• Finally, FAA has not established criteria to return delegated authority to Boeing’s Organization Designation Authorization (ODA).

FAA continues to face challenges addressing allegations of undue pressure within Boeing’s aircraft manufacturing.

• FAA issued guidance for reporting allegations of interference to FAA. However, FAA has not enforced requirements that Boeing provide information in sufficient detail on alleged undue pressure allegations. Additionally, changes to FAA’s review process have delayed FAA’s ability to resolve allegations of undue pressure reported by Boeing.

• Further, despite FAA organizational changes to improve oversight, FAA MANAGERS DID NOT KNOW ABOUT THE INVESTIGATIONS OF ONGOING UNDUE PRESSURE ALLEGATIONS WHEN THEY INITIATED A REQUEST TO EXPAND THE AUTHORIZED FUNCTIONS OF BOEING’S ODA.”

From an external perspective, it appears that the implementation of SMS did not provide the tools for the field personnel to utilize the data generated by this comprehensive aviation safety tool. Parenthetically, it must be noted that the world’s CAA reliance on this regulatory oversight discipline has confirmed SMS’s efficacy in addressing aviation risks on a preventative basis.

Historically, FAA inspectors visited the offices on their certificates, assessed the records, talked to contacts within the manufacturer (or airline), compared thar information with a checklist and determined which identified items merited possible enforcement action.

The new regimen places the same Principal back in her/his office reading data generated by the OEM’s system and assessing whether the trend lines flag issues which should be addressed collaboratively between the regulator and the regulated. The ANALYTICAL AND INTERPERSONAL SKILLS to meet the job requirements of this new regimen are significantly different from the past experiences; so, the OIG’s statement that training is needed to make SMS work is spot on.   

Equally this transition did not adequately provide the field with the necessary inquisitive attitude to ask Boeing about its international sourcing. Perhaps, the Boeing information system did not highlight the number of these overseas parts/components/systems and may not have tracked the QA performance of the suppliers.

The other points raised by Ms. Smith’s team are equally valid. The measures to be achieved as a predicate to issuing Boeing a full ODA probably require some outside help.

The most important, probably too subtle, message is that REAL COLLABORATION BETWEEN THE FAA AND BOEING is critical to RESTORING THE COMPANY’S SAFETY CULTURE based on trust, useful data and truly proactive SMS processes.

DOT Audit: FAA’s Boeing Oversight “Not Effective”

The Office of Inspector General issued 16 recommendations for the agency to improve its oversight role.

Meg Godlewski

Updated Oct 11, 2024, 5:04 PM EDT

FAA’s oversight of Boeing 737 and 787 production lines is “not effective,” according to a report from the U.S. Department of Transportation Office of Inspector General (OIG).

Boeing production has been under the microscope since January, when an improperly installed door plug blew out from an Alaska Airlines 737 900 Max as it climbed out of Portland International Airport (KPDX). There were no serious injuries and the aircraft was able to return to the airport for a safe landing.

The event prompted government officials including the National Transportation Safety Board (NTSB), and DOT to take a closer look at Boeing and its relationship with the FAA, the agency responsible for certifying aircraft.

The OIG AUDIT issued 16 recommendations for the FAA to improve its oversight, including developing a structured approach for assessing Boeing production, and guidance for evaluating the company’s supplier control.

FAA Responds

The OIG report noted that the FAA lacks “an effective system” to oversee individual Boeing factories and has not assessed the effectiveness of Boeing’s safety management system. Earlier this year, the latter was discussed at length at NTSB hearings addressing the door plug event.

FAA officials said the agency “concurs with ALL THE OIG’S RECOMMENDATIONS and has provided the Inspector General an implementation timeframe,” according to a statement sent to FLYING. “The agency is committed to continuously improving our oversight processes and took aggressive action following the January 5 Alaska Airline door plug incident.”

In addition to enhanced oversight of the aircraft manufacturer, “The FAA is currently conducting a comprehensive, systemwide review of our oversight models,” the agency said. “This work, in alignment with the OIG’s recommendations and recently passed reauthorization legislation, will enhance the agency’s capabilities to provide MORE DYNAMIC, DATA DRIVEN OVERSIGHT.”

Boeing officials continue to “engage transparently” with stakeholders and federal regulators in order to improve quality and “regain the trust of the flying public,” the company told FLYING in a statement. 

“This audit reinforces the improvements we are making as part of the Safety and Quality Plan we presented to the FAA in May 2024,” the manufacturer said. “Our plan emphasizes workforce training, simplifying manufacturing plans, eliminating defects, strengthening our safety and quality culture, and monitoring the health of our entire production system including with suppliers.”

Meg Godlewski has been an aviation journalist for more than 24 years and a CFI for more than 20 years. If she is not flying or teaching aviation, she is writing about it. Meg is a founding member of the Pilot Proficiency Center at EAA AirVenture and excels at the application of simulation technology to flatten the learning curve. Follow Meg on Twitter @2Lewski.

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[1] As Assistant Inspector General for Aviation Audits, Ms. Smith is responsible for managing DOT OIG’s reviews of a wide range of Federal Aviation Administration (FAA) programs, including the Next Generation Air Transportation System (NextGen), air traffic control operations, and key aviation safety workforces.

Ms. Smith joined DOT OIG in 1998 in the Atlanta Field Office and served as an analyst conducting audits of FAA’s aviation safety programs. In 2015, she became a Project Manager in Office of Aviation Audits. In 2017, she was promoted to Program Director, leading managers and staff that conduct audits of FAA’s Air Traffic, Airports, Aviation Safety, and NextGen programs. She has managed complex, nationwide audits including several congressional requests and mandates covering a range of issues, including FAA’s contract tower program, aircraft evacuations, and NextGen priorities. Ms. Smith has also been instrumental in leading the Office of Aviation Audits’ airport grant management reviews, which have yielded millions of dollars in savings. Her teams’ audit results regularly contribute to congressional briefings and testimonies.

Ms. Smith entered Federal service through the prestigious Presidential Management Internship Program. Previously, she served as an auditor at the U.S. Postal Service Office of Inspector General. With over 23 years of government audit experience, she has received numerous awards in recognition of her individual accomplishments and strong leadership abilities. She has significantly contributed to DOT OIG initiatives to promote staff development and foster high morale. Ms. Smith holds a bachelor of arts in political science from the University of Montevallo and a master’s in urban and regional planning from Alabama A&M University.