ARSA CORNER
AN OUNCE OF PREVENTION BY SARAH MACLEOD, EXECUTIVE DIRECTOR AND CHRISTIAN A. KLEIN, EXECUTIVE VICE PRESIDENT AERONAUTICAL REPAIR STATION ASSOCIATION
WE ENTERED 2019 IN THE MIDST OF A GOVERNMENT SHUTDOWN THAT DRAGGED ON THROUGH MOST OF THE YEAR’S FIRST MONTH. IN FEBRUARY, A CONGRESSIONAL COMPROMISE FUNDING BILL HELPED THE COUNTRY EVADE A RELAPSE. ITS TIME TO TAKE A BREATH, THINK ABOUT WHAT HAPPENED AND TRY TO FIGURE OUT HOW TO BE PREPARED FOR THE NEXT GAME OF POLITICAL BRINKSMANSHIP.
Without reservation, the association extends deep
appreciation to government employees that worked without pay to ensure aviation safety remained uncompromised; particularly those “essential” individuals that communicated with other aviation safety agencies (namely EASA) to address continued compliance with international agreements. Before and during the unfortunate hiatus, the association engaged in alternative planning for its Annual Conference, helped its members and the agency address immediate issues and tracked the progress and gradual return of FAA’s workforce (much of this progression can be viewed at arsa. org/shutdown). In the aftermath, the association engaged with its members and other aviation groups on how best to prepare the industry for future FAA service interruptions. The most obvious answer is for every certificate holder to explore and, after study, develop a list of FAA designees needed to continue operations in the most efficient and effective manner. If that includes requesting designee status or expanding current capabilities, appropriate requests should be made to the agency as soon as practicable. Even if the approval is not granted, the request will provide the agency with information on how its inability to act directly impacts certificate holders and ultimately aviation services and safety.
DESIGNEE OPPORTUNITIES IN THE RULES 49 U.S.C. 44702(d) gives the FAA administrator authority to “delegate a qualified private person, or to an employee under supervision of that person, a matter related to the examination, testing, and inspection necessary to
issue a certificate, and issuing the certificate.” Through regulations (14 CFR part 183), the FAA has fleshed out its delegation authority and prescribed rules for designating individuals to act on behalf of the administrator as aviation medical, pilot and technical personnel examiners; aircraft maintenance inspectors; designated engineering, manufacturing inspection and airworthiness representatives; and air traffic control tower operator examiners. Subpart D of part 183 addresses Organization Designation Authorization, “which allows an organization to perform specified functions on behalf of the administrator related to engineering, manufacturing, operations, airworthiness, or maintenance.” The rules prescribe, among other things, specific qualifications, personnel, manual and recordkeeping requirements. The thinking behind the law and related regulations
is fairly simple: the FAA can appoint individuals and organizations that meet certain qualifications to act in the agency’s stead. That, in turn, allows the aviation industry to contract certain FAA tasks to private individuals and companies, avoid the bureaucratic log jam at the agency and obtain an approval more rapidly. The FAA’s most recent ODA directory shows they’re widely used in design and manufacturing, but the law doesn’t limit ODAs to those purposes. Expanding the use of designees is the way of the future. The industry is growing rapidly, but FAA’s budget isn’t. Oversight must become more flexible and efficient to keep up. Forward thinking organizations should consider creative ways to make broader use of ODA to limit their dependence on regulators.
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DOMmagazine.com | apr 2019
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