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is lacking.” The growth of the ODA program is making oversight increasingly difficult with limited resources for proper regulatory compliance. Congress should bar any expansion of the designee and ODA programs until the FAA conducts an audit to ensure the programs are regulatory compliant and are being properly overseen by fully qualified, trained and proficient FAA inspectors.
Aircraft Repair Outsourcing Congress must also address unfinished business related to the epidemic of outsourcing of aircraft maintenance and repairs. With more than 700 foreign-based aircraft repair stations certified by the FAA to work on U.S. aircraft, federal policy fails to ensure that the same safety and security rules imposed on domestic repair facilities are applied to facilities based overseas. Congress has spoken on these issues. In the 2012
FAA reauthorization bill, lawmakers voted in favor of a provision (Section 308(d)(2)) directing the FAA, within one year of enactment, to issue a proposed rule requiring all repair station employees responsible for safety-sensitive maintenance on U.S. aircraft to be subject to an alcohol and controlled substance testing program. While we are pleased that Congress moved to address this safety issue, the FAA is now well over two years late in fulfilling this mandate for a proposed rule and the provision will have no impact until it is formally implemented by the FAA. To ensure
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compliance and to stop the proliferation of unsafe standards, we urge Congress to prohibit the additional certification of any foreign repair station until the drug and alcohol rule is implemented. The 2012 law also mandated that each foreign repair station be inspected by the FAA at least once a year. While this is a step in the right direction, inspections at foreign stations must still be announced and notice provided to the host country – contrary to the surprise visits correctly imposed on domestic stations. Transportation labor calls on Congress to close this basic safety loophole and mandate the use of unannounced inspections at both foreign and U.S. stations. Congress must also resist efforts to allow foreign countries, instead of the FAA, to perform the minimum inspections required of U.S. certificated stations. If foreign stations and their governments do not wish to be subject to these requirements, they should not be allowed to work on U.S. aircraft.
Strengthening Safety Reporting Programs Voluntary safety reporting programs such as Flight Operations Quality Assurance (FOQA) and the Aviation Safety Action Program (ASAP) are important, collaborative tools that enhance aviation safety through the analysis of voluntarily reported safety events and discrepancies that lead to the prevention of accidents and incidents. Congress can improve and increase the safety benefit of ASAP programs and voluntarily submitted aviation safety information by automatic acceptance of ASAP reports. Currently, the acceptance process may take weeks waiting for the Event Review Committee (ERC) to meet, delaying safety benefits. Reports should be automatically accepted. Under an automatic acceptance scenario, a report could be excluded when the ERC convenes if the report is determined to meet one of the five established exclusionary criteria, but until then the safety benefit would be realized immediately. Several ASAP programs already have automatic acceptance protocols built into their programs. This model should be universal to the ASAP program.
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On-board Phone Calls and Broadband The FAA reauthorization should also include language that would prevent federal agencies from allowing in-flight voice cell phone use as well as ensuring that expanded use of mobile broadband wireless services on commercial aircraft does not jeopardize aviation security. The FCC is currently undertaking a rulemaking process that could lift the decades-old ban on both. The use of cell phone voice calls on flights would not only create an unnecessary nuisance for passengers who seek peace and quiet, but it would pose serious safety and security concerns as flight attendants would be forced to police disputes between passengers rather than dedicating their attention to tasks required to keep passengers safe. Higher noise levels would also reduce the ability of flight crewmembers to relay important safety information in the event of an emergency. Before expanded
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