Survey Highlights Issues Within Boeing’s Delegated Workforce

Many Boeing employees authorized to act as FAA representatives still perceive pressure to make decisions that prioritize company schedules and budgets, or fear retaliation if they report potential safety issues, a new survey commissioned by the company shows, but the number of concerns appears to be lessening.

The survey of Boeing’s Organization Designation Authorization (ODA), conducted by corporate culture analysis and improvement specialist Integrity Lab at Boeing’s request, found that 24.1% of respondents “expressed some concern around retaliation for reporting an interference issue,” a summary of the results released by Boeing on Aug. 25 shows. While troublesome, the figure improved over a 2019 internal Boeing survey that found 37.1% had similar concerns.

• ODA lead sees need for more improvement
• 71% of ODA unit members surveyed in May responded

Respondents’ retaliation concerns mirror broader themes in the survey results. For instance, 49.4% of respondents believe “interference concerns” are becoming less of an issue within the ODA, while 5.6% see them getting worse. The remainder have seen no change.

Interference was encountered, or at least perceived, by 13.9% of respondents in the 2022 survey, compared with 40.1% in the 2019 survey.

“We consider this to show some progress, but we also know that there’s work ahead of us and more improvement to go,” says Tom Galantowicz, Boeing chief safety officer and ODA lead administrator.

Comparisons between the 2022 survey and previous ones should be accepted with caveats. The latest survey is the first done by an outside organization, while previous versions were conducted solely by Boeing. In addition, Integrity Labs worked with the FAA to develop relevant questions for the 2022 version, which—in theory—should have helped align it with what the agency is seeking as it revamps some aspects of the ODA program.

The focus on ODA—and Boeing’s work in particular—stems from broader concerns about the program’s expansion over the last two decades and how several weaknesses contributed to two fatal Boeing 737 MAX accidents in 2018 and 2019.

In transport-category aircraft projects, the percentage of work delegated to the ODAs—measured in certification plans and deliverables within each plan—routinely tops 90% and has for several decades.

Although lauded by industry and the FAA, ODA’s expansion was raising red flags long before the 737 MAX accidents. A 2015 Transportation Department auditors’ report highlighted several issues. Among them: the FAA’s staffing model did not factor in certain risk-related variables such as a company’s size or a project’s complexity.

Investigations triggered by the 737 MAX accidents spotlighted an even bigger problem. ODA members surveyed within Boeing said they often felt pressured to push projects along by approving tests or ignoring potential issues rather than raise possible safety concerns. Those who wanted to speak up often felt they had no clear path to a sympathetic FAA ear.

The two issues helped create safety risks, such as questionable design decisions and system safety analysis, that could have been addressed during the 737 MAX’s development. Instead, they were muted or ignored and investigations into the accidents and the aircraft’s development concluded (AW&ST, Sept. 28-Oct. 11, 2020, p. 20).

Legislation passed in 2020—much of which is still being put into place—sought to close some of these gaps (AW&ST July 25-Aug. 7, 2022, p. 50). Among the results is new FAA draft guidance that targets unit member interference, including how to measure and mitigate it.

While Boeing insists the latest survey was done voluntarily, an annual pulse-taking of ODA members via a survey is included in the FAA’s draft guidance. The survey would focus on detecting ODA “unit member” interference concerns that are not evident in more formal reporting channels that ODA holders are required to have in place, the guidance says.

Boeing is also enhancing the training that the new guidance would mandate for ODA managers and administrators.

“We had training materials that were available and were deployed to the management team and administrators as well,” Galantowicz says. “We’ve been, in the last two years, doing significant updates. . . . We actually just this month gave the latest iteration of that to the Boeing team.”

The 2022 survey was sent to about 1,000 ODA unit members in May and generated a 71% response rate. The 2019 survey was sent to about the same number of employees and generated a 60% response rate, Boeing tells Aviation Week.

Responses to both suggest Boeing ODA members have a lot to say, as a typical response rate for these types of surveys runs 30-40%, says Integrity Lab founder Eugene Soltes, a Harvard Business School professor specializing in organizational compliance issues.

Boeing did not release full results, but a review of the 26-question survey suggests the company is compiling specific trends by variables such as employee location and job function. The survey also asks respondents to indicate how much time they spend on ODA functions.

Annual surveys are part of what the FAA envisions as a multipronged approach to ensuring ODA unit members have multiple outlets to voice concerns. Direct reporting of safety concerns, including undue pressure, is the first step. Ensuring unit members have direct links to the FAA is another change.

One part of the 2020 law requires the FAA to assign “personnel with appropriate expertise” as ODA unit member advisors. Beyond serving as a resource within the agency, their functions include communicating with unit members about FAA policy and monitoring ODA unit performance.

“They actually aligned a FAA individual to every single person that we have in the Boeing ODA, so each [person] would know at least one direct [contact] within the FAA that they could go to,” Galantowicz says.

This particular policy applies only to ODA holders with type and production certificates for air transport aircraft with maximum gross takeoff weights of 150,000 lb. or more and their engine suppliers—lawmakers’ way of targeting Boeing, GE Aviation and Pratt & Whitney.

Boeing has five FAA-approved ODA functions—type certificate; production certificate; major repair; alteration and airworthiness; and supplemental type certificate. The FAA renewed all of them in June, but for only three years instead of the customary five.

In a letter communicating the approvals, FAA Acting Manager of Boeing’s ODA oversight office Ian Won told Galantowicz that the agency wanted to see specific improvements in several areas. Among them is ensuring ODA unit members are not pressured or interfered with, even if their concerns threaten project schedules or budgets. The issues are not new. In 2021, Boeing agreed to pay a $1.2 million fine to settle allegations of undue pressure on ODA members at its North Charleston, South Carolina, 787 production facility dating back several years.

Boeing is working on about 20 initiatives that target ODA improvements, Galantowicz says. One is to better internally publicize what actions are taken when unit members raise concerns.

“Even if there isn’t necessarily a finding, there’s generally some improvement, a corrective action that’s put in the system,” he says. “We have not done as much as we could to help communicate that out to the rest of the unit member base so that they understand that raising a concern is encouraged and will result in some positive action.”

Another key change is grouping unit members that focus more on certification-related activities together and giving them supervisors with specific regulatory experience.

“Not every job in the company has a heavy certification [or] FAA responsibility,” Galantowicz says. The reorganization “allowed us to take the work that was heavier in terms of certification and consolidate it under a certification leader that [possesses] the special skills and knowledge necessary to be most effective in an ODA operation.”