ARSA CORNER In the “you aren’t meeting the FAA
halfway” case, facing reality straight on while changing the relationship between the parties, we worked up a polite letter to the FSDO manager clearly explaining all the steps the company had taken to “satisfy” the “local offi ce” request to comply with the inspector’s “guidance” (yes, it was in the SAS oversight “elements). We (again politely) requested that the matter be closed with no further action necessary. Although there has been no
answer to the request, the agency is moving forward with other requests and I am hopeful that the letter was taken as having met the agency “halfway.” The company also promised to institute a much more formal approach to communication with the agency – no longer letting
it dictate how communications take place. Everything important is put in writing, all written communication is sent in a manner that receipt can be verifi ed. No more phone calls, no casual emails, etc. In other words, the company promised to control the elements that create professionalism and (hopefully) will stick to them throughout the years and changes in inspectors, frontline managers and managers. A signifi cant culture change for a company that had always “gotten along” with its “local offi ce” and did not feel the “necessity” to “be so formal.” Maybe it won’t stick, but if it doesn’t the company will at least have an understanding of how to put itself back in a more professional position.
In all other cases, I stick with a tee-shirt my husband (and his sons)
bought me years ago: “Just Do As I Say And No One Will Get Hurt.” The only time I believe in meeting someone halfway is when the road is clear of unnecessary obstacles and unsupported opinions. A road to regulatory compliance that is based upon the SAS “elements” and oversight “requirements” does not meet that criteria. .
Sarah MacLeod is managing member of Obadal, Filler, MacLeod & Klein, P.L.C. and a founder and executive director
of the Aeronautical Repair Station Association. She has advocated for individuals and companies on international aviation safety law, policy and compliance issues for 30 years.
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DOMmagazine.com | oct 2019
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