Designee Programs

NEED FOR PROPER OVERSIGHT OF FAA DESIGNEE PROGRAMS

Reliance on Designees Has Not Been Sufficient To Prevent Significant Safety Incidents

ISSUE: The Government Accountability Office issued a report last October on the Federal Aviation Administration’s Designee Programs (GAO-05-40) and found that the FAA’s reliance on designees has become unmanageable and has not been sufficient to prevent significant safety incidents.  Additionally, in November 2005, the GAO released another report on the FAA’s Oversight System and found “inadequate evaluative processes and limitations with data for FAA’s designee programs.”

NATCA POSITION

The National Air Traffic Controllers Association requests, in order to properly address the oversight problems in the designee program of aircraft certification, that the FAA increase its field offices’ staffing by 300 safety/aerospace engineers over the next six years.

BACKGROUND

The safe development and implementation of aircraft technology performed by aerospace engineers in the FAA’s aircraft certification division is a critical component in the safety chain that has given us the safest and most efficient air traffic control system in the world.  Many of those new technologies are developed and tested by designee engineers who work for aerospace companies and their work is certified as safe by FAA’s aerospace/certification engineers. 

NATCA’s members employed as FAA aerospace/certification engineers reacted quickly to post 9/11 Congressional mandates to install cockpit doors to minimize terrorists’ ability to take over aircraft.  They were involved in investigating the causes of crashes such as Swissair Flight 111 in September of 1998, Senator Wellstone’s in October of 2002, and Air Midwest Flight 5481in May of 2003 in order to help write new safety regulations to minimize any significant mechanical or piloting/operational error from ever happening again.

The FAA has utilized and plans to increase use of the designee programs that delegate safety oversight directly to companies rather than to individual government engineers as in the past.  Since Boeing and other aviation companies are outsourcing production and design to foreign countries, it will be nearly impossible for the FAA’s limited number of aircraft certification engineers to properly oversee design and production processes.  Further exasperating this problem is that the FAA is allowing companies to re-delegate to other companies (suppliers), making it impossible for proper oversight. This process removes individual accountability from the safety chain as the roles are assigned to organizations rather than individuals.

The November GAO report (GAO-06-266T) also noted “concerns about the consistency and adequacy of designee oversight that FAA field offices provide have been raised by experts and other individuals we interviewed.  For example, designees and industry officials that we spoke with indicated that FAA’s level of oversight and interpretation of rules differ among regions and among offices within a region, which limits FAA’s assurance that designees’ work is performed uniformly in accordance with FAA’s standards and policy.  Experts also ranked this issue as a top weakness.”  The table shows the top five weaknesses identified by the GAO’s experts.

Ranking Weakness

1   FAA offices level of oversight and interpretation of rules are inconsistent.

2   Inactive, unqualified, or poor performing designees are not identified and removed expeditiously.

3   It is difficult to terminate poor performing designees.

4   Inadequate surveillance and oversight of designees.

5   FAA has not made oversight of designees a high enough priority.

In spite of the GAO’s report, the FAA has created new delegated systems, known as Organization Design Authorization (ODA).  These new delegations and the upcoming Design Organization Certificates (DOC) should be suspended until the GAO’s recommendations are addressed thoroughly, FAA engineering staff should be increased appropriately, and the ability of FAA to oversee the designee programs must be assured.