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LEGAL SPIN


BY JASON DICKSTEIN


BY JASON DICKSTEIN


DOT OIG Report Critical of the FAA


I


s the FAA effective in its oversight of repair stations? The Inspector General’s Office doesn’t seem to think so. The Inspector General’s Office has released a report that is critical of the FAA’s oversight of repair stations. This critique reflects concerns that are much bigger than repair station oversight, though. The Inspector General’s report could be read as an indictment of the fundamental direction in which FAA has been moving for several years in its efforts to improve safety oversight through implementation of safety management systems (SMS). The Report follows-on to earlier DOT-OIG reports that were issued in 2003 and 2008 and addressed


FAA oversight of repair stations. The 2003 Report explained that the auditors had found non-compliances at repair stations and attributed those non-compliances to lack of effective FAA oversight. In 2008, DOT- OIG concluded that the FAA was not effectively focusing its inspection resources on those repair stations providing the highest volume of repairs. DOT-OIG felt that this caused deficiencies at repair stations to go undetected or reoccur. They also felt that this prevented FAA inspectors from obtaining sufficient data to perform comprehensive risk assessments. The most recent report in the series was issued May 1, 2013. The Report acknowledges that FAA has


created a risk assessment tool, but found that it is not being well-used for a variety of reasons, including conflicting guidance, ineffective checklists, narrow data pools for conducting risk assessment and lack of FAA inspector training. DOT-OIG opined that “As a result of FAA’s insufficient oversight, some repair stations may not be operating in full compliance with Federal aviation regulations.” To enhance its oversight of repair stations, DOT-OIG recommend that FAA take the following steps: 1. Modify its oversight system so that all inspection elements are considered in inspector risk assessments of repair stations. 2. Implement a risk-based system appropriate for oversight of foreign repair stations. 3. Modify the risk assessment tool so that inspectors can document changes to their surveillance plans as soon as they are made. 4. Develop a control that will ensure inspectors prioritize inspections to those repair stations determined to have increased risk. 5. Enhance training for inspectors so they understand the importance of using the available tools for assessing and trending risk. 6. Develop the Repair Station Data Package and provide training to all inspectors on how to use it. 7. Develop a standardized checklist that all inspectors can use to improve the consistency in the way they perform and report their inspection findings. 8. Provide training for inspectors to improve their review and acceptance of repair station


corrective plans. 9. Provide training to inspectors on how to conduct comprehensive post-inspection briefings and


require them to issue a draft report of tentative findings to repair station officials at the conclusion of inspections. In response, FAA pledged to offer training to its workforce, and improve the capabilities and performance of the risk-based analytical tools available to inspectors. Really? Training did not work the first time, so FAA is going to retrain the inspectors and hope that it works this time? DOT-OIG was satisfied with most of FAA’s remedial plans but remained concerned about three areas: 1. FAA stated that it will conduct recurrent training to improve the use of the risk assessment tools, but DOIT OIG noted that this did not help the fact that FAA inspectors continue to complete mandatory inspections instead of targeting resources where they are needed based on risk. DOT-OIG felt that additional training would be helpful, but it would not address the fact that FAA guidance requires only seven inspection elements to be assessed for risk while the other nine are inspected annually, regardless


38 Aviation Maintenance | avm-mag.com | May 2013


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