FAA's Organization Designation Authorization,ODA, Failure......More Regulation is NOT the answer!
In a recent article in USA Today, "Boeing 737 Max: FAA's outsourcing of air safety raises conflict-of-interest questions." Link:
Woodyard states, "The FAA has for years allowed many aerospace companies to use their own workers in place of FAA inspectors, a system that is coming under scrutiny after two 737 Max jetliners crashed, killing crew and passengers." There are currently 79 companies that are using the ODA program for oversight.
The article suggests that the FAA take back over the oversight of these companies directly, which would cost the U.S. taxpayers 1.8 Billion dollars to hire over 10,000 FAA inspectors. The root cause of the ODA failure may not be the relinquishing of oversight, but may be to the way the FAA oversees the program.
The question must be asked, "Why did the FAA start this ODA program if all the data necessary to assess the effectiveness of the companies' self oversight can be easily obtained from the Safety Management System.
The FAA needs to take a lesson learned from their northern neighbors. Transport Canada mandated SMS to their 705 enterprises over 10 years ago. DTI Training was honored to be one of the Design and Development companies for Transport Canada's Regulatory Surveillance program for enterprises that have SMS. The requirement clearly mandates that a company is to be "Self Healing." which simply stated means that the company performs the regulatory compliances on themselves through the SMS and Quality Assurance functions. This is completely difference the current FAA ODA program. Here is an illustration of the difference:
This illustration shows how the ODA are still under the pressures of management and would revert to cutting corners in lieu of safety. This program has come under a lot of skepticism. It isn't just Congress that's skeptical. A union representing FAA inspectors, the Professional Aviation Safety Specialists, has been opposed to the expansion of the ODA system for years.
"SMS Mandates companies to be 'self healing'"
The illustration below shows that the SMS uses the companies own system to produce data that can be constantly analyzed for regulatory and safety compliance. The system detects variation and mandates risk assessment, analysis and corrective actions that are documented. The FAA inspectors merely assess the company's own data to determine compliance and secure safe operations from design to deployment.
The SMS allows Process Control and Continuous Improvement but, only if implemented correctly. DTI used the "Control" concept successfully at NASA's Kennedy Space Center after the Columbia Space Shuttle Accident. Knowledge of Systems and Process Control can only be obtained from training and experience.
Article by: Dennis Taboada, M.eng.,CQE, CQM CEO, DTI Training International
For Free SMS briefing or to schedule formal SMS/QA training contact:
dtiquality.com 1-866-870-5490 webmail@dtiatlanta.com Blog: dtitraining.blogspot.com Linkedin: Dennis Taboada YouTube: dti training
“We should add more regulation to solve problems†~ no one ever
Development Assurance Lead & FAA DER at Joby Aviation
5 å¹´I am a firm believer in SMS.? However, I do not believe that such a system would have prevented the series of events (at least as described in public sources) that led to the 737 Max design making it out the door.? Modifications to the ODA oversight structure are likely to be just a piece of the set of corrective actions needed.??
President at Expedited Airworthiness Services, DAR-F, DAR-T, A&P, IA
5 å¹´https://www.faa.gov/about/history/deldes_background/. Delegation has been around a long time....just saying
Aircraft Maintenance Engineer
5 å¹´Unfortunately without sufficient regulatory oversight any SMS is only as good as the people running it, and is only as good as the senior management of the company wants it to be.? Like any system it's garbage in, garbage out.
Airworthiness/Flight Sciences - FAA Flight Analyst DER - NIAR WERX
5 å¹´As an ODA Engineering Unit Member (UM), I, through the ODA, am beholding to only one group and that is the FAA. As a UM, I have and will continue to tell my management NO if compliance with the regulations, as interpretted by the FAA, is not shown. Having said this, I am able to utilize my knowledge and expertise to help guide the company during development so that I don't have to say no when the time comes given that clear compliance has been shown. ODAs have an exceptional track record overall. Could there be improvements, maybe so. But this is true of any system, from full FAA participation to full delegation. The reason that ODAs were developed in the first place was that the FAA resources required to fully manage all projects could not keep up with the demand. The FAA realized that this could effect safety. Resourse restrictions are not the FAAs doing. The FAA has to ensure safety with the resources allocated by Congress. With those resources, the FAA has done an outstanding job and through oversite of the ODA system, have made the skies safer. I welcome the results of the certification safety review. I am sure they will find out what we as UMs aleady know. That the ODA system works. I also welcome ...