Opinion: FAA ODA ‘Designees’ Need Training
In their Oct. 19 letter, friends and relatives of Ethiopian Airlines Flight 302 (ET302) 737 MAX crash victims demanded termination of Boeing’s organization designation authorization (ODA) “because it cannot be trusted to certify the safety of Boeing designs free from undue influence, interference and incompetence.” Investigations into ET302 and a second fatal 737 MAX accident spotlighted numerous failings, including ODA problems.
Designees are embedded non-FAA personnel who referee the U.S. civil aviation industry—legal agency representatives charged with protecting the flying public’s interests. They have been integral for decades.
The 2006 introduction of ODA made a crucial change: Company engineers and specialists who do the work—and make up the ODA units—are not designees. Instead, the responsibility of legally representing the agency now rests with the company, not individuals. Simply put, under ODA, the applicant and designee are one and the same.
ODA unit members receive special training to be de facto FAA representatives. Company executives who oversee the ODA do not. Recent policy assigns a direct FAA point of contact for some ODA unit members, but they are still not designees.
In my 33-plus years as an FAA designee, I was always the filter, regardless of the applicant’s integrity—or lack thereof. The ODA system removed the filter.
Defining “designee” under ODA becomes philosophical. The FAA’s current list of ODA holders includes Boeing, General Electric and Pratt & Whitney. Who or what are they? Whatever they are, their culture and conduct are defined by executives more than anyone else—executives who receive no special ODA training.
The European Union Aviation Safety Agency (EASA) at least addresses the issue. When I was the head of independent system monitoring for GE/CFM’s Design Organisation Approval (DOA), a new vice president took over. I spent days training him on certification principles—EASA’s acceptance of him was a condition for DOA renewal.
Company executives don’t need technical training on issues the ODA units handle. Let’s train ODA “designees”—managers within the units and executives who oversee them—to manage effectively, empower ODA unit members and not interfere with our work.
ODA unit members have to be experienced, knowledgeable and competent. To some managers, that makes us good “fixers” of company shortcomings. But the FAA’s own ODA regulations, specifically 14CFR§183.57(c), forbid this. Managers must “ensure that no conflicting non-ODA unit duties or other interference affects the performance of authorized functions by ODA unit members,” it says.
Asking unit members to fix problems, instead of just to identify whether problems exist, disables the system.
When I designed and monitored repairs on Pan Am 747s, major repair coordinators, authorized by FAA regulation, had to be satisfied before aircraft left the hangar.
Fast forward 35 years, to early 2021. My job: verify, as GE Aviation’s ODA deputy administrator and inspection unit member, that GE’s parts, engines, test setups and processes conform to design. But I found myself, the verifier, pressured to become the fixer of GE’s conformity failings—past, present and future.
I refused. And then I quit.
Managers at corporations with ODAs that design and produce new aircraft and engines—type certificate (TC) ODAs—must represent the FAA and the flying public above all else. Far too frequently they don’t. So here we are, bolting on accountability legislation.
My experience tells me Congress’ efforts, while fruitful, are not enough. Left unchecked, these untrained, underqualified managers, acting as designees, will continue to compromise commercial aviation safety.
Stakeholders must become more accountable. Manufacturers should select their best and brightest as ODA unit members and administrators, and they should be empowered to represent the flying public, full stop.
The FAA needs to step up, too. A competent ODA isn’t just a stack of forms. The agency must audit for Part 183 violations, including disempowerment and interference. A recent FAA survey of Boeing ODA unit members found enough to trigger a probe of Boeing’s unit management. Other ODAs have similar issues. My third-party ODA employers are better. Perhaps these smaller companies are less beholden to exuberant “lean” and “shareholder value” mantras. Maybe a heavier reliance on consultants builds a firewall.
For TC ODA designees who prove incorrigible, implement Mike Borfitz’s proposal (AW&ST July 26-Aug. 8, p. 74). Apply the supplemental type certificate world’s third-party ODA concept to the TC-holder world. Preserve ODA procedures but disconnect ODA unit control from persons not shown to be qualified to fulfill their responsibilities as FAA designees.
Richard Kucera is an FAA designated engineering representative, designated airworthiness representative, member of multiple organization designation authorization units, EASA compliance verification engineer and a former ODA administrator.
The views expressed are not necessarily those of Aviation Week.