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Organization Designation Authorization

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Main article: Federal Aviation Administration § Regulatory process
FAA document that establishes the ODA program

The Organization Designation Authorization (ODA) program was established by FAA Order 8100.15() (image at right). The ODA, in conjunction with the Federal Aviation Administration (FAA), grants airworthiness designee authority to organizations or companies. The regulations addressing the ODA program are found in Title 14 of the Code of Federal Regulations (14 CFR) part 183, subpart D, sections 183.41 through 813.67.

The ODA program's intention is to elaborate on the tasks that are available their organizations design authorizations. While adding in this "final rule" for designs, the ODA also added in a phase-out timeline for design programs.

The FAA asserted that the ODA program does not introduce any type of self-certification.[1] However, the practice has been criticized for substantial manufacturer influence over personnel designation and design certification, particularly after the Boeing 787 Dreamliner battery fires in 2013 and the Boeing 737 MAX groundings in 2019.

Purpose

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"The ODA program expands the scope of approved tasks available to organizational designees; increases the number of organizations eligible for organizational designee authorizations; and establishes a more comprehensive, systems-based approach to managing designated organizations."[1]

The ODA program was created for the FAA to standardize the operation and oversight of organizational designees.[1]

This program aims to "increase the efficiency with which the FAA appoints and oversees designee organizations, and allow the FAA to concentrate its resources on the most safety-critical matters."[1]

Types of Organizational Designation Authorizations

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The following are the different types of Organizational Designation Authorizations for which qualified organizations may apply.[2]

History

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In the "VISION 100—CENTURY OF AVIATION REAUTHORIZATION ACT" of 2003, legislators passed a section entitled "DESIGN ORGANIZATION CERTIFICATES", which instructed the FAA to deputize designers, so that the designers would "certify compliance with the requirements and minimum standards... for the type certification of aircraft, aircraft engines, propellers, or appliances."[3]

In 2005, the FAA granted Boeing "in-house oversight for new planes in production and approval of major repairs and alterations".[4] The manufacturers’ engineer is delegated to review the design, plan and observe tests, and certify they meet applicable standards.[4] FAA staff do attend "many critical tests involving safety issues — such as flammability of new materials and design of flight controls".[4] The ODA status is granted for an aircraft manufacturer to act as the proxy on certification oversight.[5] Previous to the ODA programme, "engineers in that role were approved by and reported directly to the FAA".[4]

In 2011, Associate Administrator for Aviation Safety Margaret Gilligan issued National Policy Order 8100.15A to establish the "procedures, guidance, and limitations of authority" the FAA grants to an organization under the ODA program. Order 8100.15A was 293 pages long and composed of 16 chapters and seven appendices. The legislative authority for the ODA program was derived under Title 49 of the US Code § 44702: Issuance of Certificates, which authorized the FAA to "delegate to a qualified private person a matter related to issuing certificates, or related to the examination, testing, and inspection necessary to issue a certificate on behalf of the FAA Administrator".[1] The FAA established the ODA program in 14 CFR part 183, subpart D: Representatives of the Administrator.[6]

Boeing has 1,500 people in its ODA, under supervision by an FAA team of 45 people, of which only 24 are engineers.[7] By 2018, the FAA was letting Boeing certify 96 percent of its own work.[8]

Historical examples

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The Boeing 737 series had suffered from rudder issues in the past, resulting in several accidents. A previous model of the 737 also experienced a similar mix of questionable safety assessment, insufficient pilot training, and automated system malfunction when Turkish Airlines Flight 1951 crashed.[9][10] In February 2020, Boeing and NTSB officials refused to cooperate with a new Dutch lawmakers inquiry.[11]

In November 2019, the online media "The Air Current" reviewed historical parallels between the MAX and the McDonnell Douglas DC-10, which had been grounded after the crash of American Airlines Flight 191.[12] A safety panel was convened by the FAA under the auspices of the National Academy of Sciences to investigate both the design of the DC-10 and the regulatory system itself. In its report, published in June 1980, the safety panel highlighted the FAA's reliance on the manufacturer during the certification process and the fact that in most cases it performs only a "cursory review" of the manufacturer's information.[13][14] The New York Times noted that the panel found "critical deficiencies in the way the Government certifies the safety of American-built airliners".[15]

For Marian Pistik, head of asset management at International Airfinance Corporation, the case of the MAX is unprecedented due to allegations of wrongdoings. The groundings of the DC-10 and of the Dreamliner could not be directly compared to the global B737 MAX grounding: "there was no suspicion that Boeing or any OEM knew of the problem and tried to disguise it or […] any suspicion of wrongdoing or not being compliant or forthcoming with the issues of the 737 Max."[16]

Oversight of delegation policies by SOCAC

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The Safety Oversight and Certification Advisory Committee (SOCAC) was created by the FAA Reauthorization Act of 2018. The committee will provide advice to the Secretary of Transportation on policies related to FAA safety oversight and certification programs and activities, utilization of delegation and designation authorities.[17][18]

Controversies

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The ODA process has been criticized as detrimental to safety.[5] Since 2012, the FAA had successfully pushed to increase the scope of delegating safety checks to the manufacturer.[19]

On 4 February 2013, an article in The Seattle Times written by journalist Kyung Song[4] critiqued the process by which the airworthiness certificate was obtained for the Boeing 787 because approvals for the lithium ion battery system were akin "to the fox guarding the chicken coop".[5] In the words of an onlooker, "Song stated that Boeing became an FAA designee [sic] with wide latitude in picking the company’s own engineers to sign off on their employer’s work on behalf of the FAA".[5]

Executive-summary – Special Committee to Review the FAA's Aircraft Certification Process[20]
Official report – Special Committee to Review the FAA's Aircraft Certification Process[21]

In April 2019, U.S. Secretary of Transportation, Elaine L. Chao, who boarded a MAX flight on March 12 amid calls to ground the aircraft[22] created the Special Committee to Review the FAA's Aircraft Certification Process to review of Organization Designation Authorization, which granted Boeing authority to review systems on behalf of the FAA, during the certification of the 737 MAX 8. The committee recommended integrating human performance factors and consider all levels of pilot experience, but defended the ODA against any reforms.[23][24] Relatives of those on board the accident flights condemned the report for calling the ODA an "effective" process.[25]

In June 2020, the United States Senate criticized the FAA for failing to turn over 737 MAX documents and accused the FAA of trying "to keep us in the dark".[26] The U.S. Inspector General said that by 2017, Boeing was handling all certification checks on behalf of the FAA.[27]

FAA response to criticisms of excessive delegation

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In response to questions from Project On Government Oversight, a FAA spokesperson said “FAA has never allowed companies to police themselves or self-certify their aircraft. With strict FAA oversight, delegation [of certification] extends the rigor of the FAA certification process to other recognized professionals, thereby multiplying the technical expertise focused on assuring an aircraft meets FAA standards.”[28]

In May 2020, the FAA announced a reform of existing processes to improve management of aircraft development and corporate practices.[29] In June 2020, a Senate Bill calling for changes to the existing ODA was being drafted to resolve potential conflict of interest between Boeing, FAA, designated representatives and whistleblowers. [30] FAA Director Steve Dickenson admitted that "mistakes were made" with the 737 MAX and that the implications of MCAS were not fully understood. [31]

In August 2020, the FAA proposed a $1.2 million fine on Boeing for exerting undue pressure on designated inspectors to expedite aircraft approvals.[32]

Further reading

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  • Raso, Connor (2019-12-18). "Boeing crisis illustrates risks of delegated regulatory authority". Brookings. Retrieved 2020-07-18.
  • FAA, Become an ODA.

References

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  1. ^ a b c d e "Establishment of Organization Designation Authorization Program". Federal Register. 2005-10-13. Retrieved 2019-08-31. Public Domain This article incorporates text from this source, which is in the public domain.
  2. ^ "Types of Organizational Designation Authorizations". www.faa.gov. Retrieved 2019-08-31.
  3. ^ PUBLIC LAW 108–176—DEC. 12, 2003 VISION 100—CENTURY OF AVIATION REAUTHORIZATION ACT (PDF). Washington: Government Publishing Office. 12 December 2003.
  4. ^ a b c d e "FAA faulted for outsourcing 787 safety checks to Boeing". Seattle Times. 4 February 2013. Lithium-ion batteries are well known for being much more flammable than older nickel-cadmium batteries, with fires that are all but impossible to extinguish until a battery's solvent-based liquid electrolytes burn out.
  5. ^ a b c d Rioux, Mike (8 February 2013). "Boeing Has FAA Organizational Design Approval". JDA Journal.
  6. ^ "U.S. DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION National Policy SUBJ: Organization Designation Authorization Procedures ORDER 8100.15A" (PDF). faa.gov. FEDERAL AVIATION ADMINISTRATION.
  7. ^ "Max Disasters Fuel Outcry Over How FAA Let Boeing Self-Certify". Bloomberg. 2019-12-03. Archived from the original on 2019-12-04.
  8. ^ Kitroeff, Natalie; Gelles, David; Nicas, Jack (July 27, 2019). "The Roots of Boeing's 737 Max Crisis: A Regulator Relaxes Its Oversight". The New York Times.
  9. ^ Tucker, Emma (2020-01-20). "Boeing's Responsibility for a Deadly 737 Crash in 2009 'Got Buried': NYT". The Daily Beast. Retrieved 2020-01-20.
  10. ^ Hamby, Chris (2020-01-20). "How Boeing's Responsibility in a Deadly Crash 'Got Buried'". The New York Times. ISSN 0362-4331. Retrieved 2020-01-20.
  11. ^ Hamby, Chris; Moses, Claire (2020-02-06). "Boeing Refuses to Cooperate With New Inquiry Into Deadly Crash". The New York Times. ISSN 0362-4331. Retrieved 2020-02-07.
  12. ^ "The DC-10, 737 Max and the struggle to polish a tarnished airplane". The Air Current. 2019-11-22. Retrieved 2019-11-22.
  13. ^ "Searching for 40-year old lessons for Boeing in the grounding of the DC-10". The Air Current. 2019-10-15. Retrieved 2019-10-16.
  14. ^ Improving Aircraft Safety. National Research Council. June 24, 1980.
  15. ^ Witkin, Richard (19 June 1980). "U.S. Safeguards Faulted As Plane Accidents Rise; Aviation Safety First of five articles. Delegation of Authority A Three-Month Inquiry Panel, in Report to U.S., Finds Major Flaws in Certifying Aircraft Concentration on Certification Program Antedates Administrator Fatal Accidents Have Declined Many Attributed to Pilot Error Prone to Erroneous Readings Agency Prescribes Standards Prime Concern of Panel Not Enough Manpower Production-Line Derelictions Crack in Plane's Flange Cadre of Specialists Pilots Want a Voice Aviation Officials Opposed". The New York Times.
  16. ^ "Grounding of Boeing's 737 Max has 'no historic precedent'". Business Traveller. Retrieved 2019-11-01.
  17. ^ "FAA's new safety committee taking shape". www.ishn.com. Retrieved 2019-09-01.
  18. ^ "Advisory and Rulemaking Committees – Safety Oversight and Certification Advisory Committee (SOCAC)". www.faa.gov. Retrieved 2019-09-01.
  19. ^ "With close industry ties, FAA safety chief pushed more delegation of oversight to Boeing". The Seattle Times. 2019-04-14. Retrieved 2020-06-27.
  20. ^ Official Report of the Special Committee to review the Federal Aviation Administration's Aircraft Certification Process Executive Summary (PDF) (Report). U.S. DOT. 2020-01-16.
  21. ^ Official Report of the Special Committee to review the Federal Aviation Administration's Aircraft Certification Process (PDF) (Report). U.S. DOT. 2020-01-16.
  22. ^ LeBeau, Phil (2019-03-13). "Feeling pressure to ground Boeing planes, US Transportation Secretary flies on 737 Max 8". CNBC. Retrieved 2020-01-19.
  23. ^ Pasztor, Andy; Cameron, Doug (16 January 2020). "Panel Clears 737 MAX's Safety-Approval Process at FAA". The Wall Street Journal. Retrieved 15 February 2020.
  24. ^ German, Kent. "Independent panel says process for certifying 737 Max was safe". CNET. Retrieved 2020-01-19.
  25. ^ Leggett, Theo (2020-01-17). "Victims' families slam report into 737 Max crashes". BBC News. Retrieved 2020-01-19.
  26. ^ "Senate Examines FAA's Certification Of Boeing's Troubled 737 Max Airplane". NPR.org. Retrieved 2020-06-27.
  27. ^ "Inspector General report details how Boeing played down MCAS in original 737 MAX certification – and FAA missed it". The Seattle Times. 2020-06-30. Retrieved 2020-07-02.
  28. ^ "How the FAA Ceded Aviation Safety Oversight to Boeing". Project On Government Oversight. Retrieved 2019-08-31.
  29. ^ Whiteman, Lou (2020-05-19). "FAA to Reform Aircraft Review Process Following 737 Max Disasters". The Motley Fool. Retrieved 2020-06-04.
  30. ^ Cirium2020-06-03T21:31:00+01:00. "Senate bill seeks FAA changes after 737 Max crashes". Flight Global. Retrieved 2020-06-07.{{cite web}}: CS1 maint: numeric names: authors list (link)
  31. ^ "'Mistakes were made': US aviation body admits 737 MAX lapses". www.aljazeera.com. Retrieved 2020-06-28.
  32. ^ Aratani, Lori; Duncan, Ian (August 6, 2020). "FAA proposes $1.25 million fine for Boeing, alleging managers pressured employees to rush inspections". Washington Post. Retrieved 2020-08-08.
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