Culture & Customer Service Initiative Impede Safety Inspectors

Mon, Apr 21, 2008 — David Evans


Obstacles galore are placed in front of aviation safety inspectors, making it very difficult to provide effective oversight, claims Tom Brantley, President of the Professional Aviation System Specialists (PASS). As a union, PASS represents 11,000 Federal Aviation Administration (FAA) employees, 2,900 of whom are field safety inspectors.

Brantley laid out his bill of particulars in a recent statement to the U.S. House of Representatives Transportation & Infrastructure Committee. His description of the Customer Service Initiative (CSI), by which the FAA views the airlines – and not the flying public – as its clients, particularly irked committee members:

Rep. Peter DeFazio (D-OR): “Who put in place the customer service initiative?”

James Ballough, director of FAA Flight Standards: “It was within our safety organization.”

Nicholas Sabatini, associate administrator for safety: “I heard ‘client’ for the first time today; that is unacceptable.”

Rep. Corinne Brown (D-FL): “Do you think it is appropriate to view the airlines as the customer?”

Sabatini: “We need to recalibrate that.”

Rep. James Oberstar (D-MN), committee chairman: “It raises the appearance of impropriety.”

Not to mention that it raises the question of the FAA’s overall relationship with the airlines, which many of the legislators maintain has gone beyond the arms-length role of oversight to one of incestuous coziness with the airlines.

PASS’s Brantley provided the best description of the cultural problem within the FAA:

“A 1996 act of Congress eliminated a portion of the FAA’s mandate that directed the agency to promote air travel. Although the written version of the FAA’s mandate now instructs the agency to focus on maintaining and enhancing safety, there remains pressure on inspectors to promote the aviation industry even if it is at the sacrifice of safety enforcement. In fact, PASS has learned of numerous instances in which, due to collaboration between the FAA and industry, FAA safety inspectors were prevented from moving forward with enforcement actions after identifying a violation of the Federal Aviation Regulations. As a result, the role of inspector as safety enforcer is becoming increasingly overshadowed and inspectors are being pressured by FAA management not to pursue enforcement actions or to severely censor their evaluations. …

“Unfortunately, seasoned safety inspectors report that filing an enforcement action against an airline is often futile because there is little chance the enforcement process will work as intended. If the many required steps are executed properly by the inspector, an enforcement action may not even leave the inspector’s office if it is not moved forward by FAA management. A suspension or revocation action that is inactive for six months may be considered stale and dropped, voiding the hours of work the inspector has done on the issue. …

“Customer Service Initiative (CSI)

“In 2002, the FAA unveiled its Customer Service Initiative (CSI) program in order to allow certificate holders to ‘request reconsideration of a decision made by an Aviation Safety office.’ The guidance on the initiative reads similar to what one may expect to encounter in any service-based industry where the emphasis is on satisfying the customer. In PASS’s view, however, the FAA should be focused on protecting aviation safety and treating the flying public as the most important customer rather than satisfying the aviation industry.

“The CSI allows the airlines the right to ask for review on any inspector’s decision made in the regulatory or certification process. While it is no doubt important for an air carrier to have a method of reporting an inspector believed to be acting inappropriately, the FAA is permitting air carriers to use the CSI to remove an inspector simply for doing his or her job. In essence, the CSI program finds the inspector guilty without trial, granting the airlines an almost effortless way to clean the slate, as well as sending a disturbing message to any other inspector assigned to the carrier that if they attempt to hold the carrier responsible, they may be removed from the assignment or face other repercussions. …

“In some cases, air carriers have even requested that their certificate be transferred to another Flight Standards District Office (FSDO). Consider the following examples:

  • “In 2005, an inspector working at the Northwest Airlines CMO [Certificate Management Office] in Minnesota detected a problem with the airline’s use of temporary workers who were not properly trained and familiar with the airline’s maintenance operation. The inspector repeatedly related concerns that the airline’s use of temporary workers … could jeopardize the continued operation of the airline. In response to these findings, the airline contacted the FAA manager at the CMO and accused the inspector of harassment … the FAA removed the inspector … When the agency refused to address the issues regarding the use of temporary maintenance workers, the inspector was forced to file a safety recommendation. This safety recommendation was ignored ….

  • “In April 2006, an inspector in Reno as conducting a routine inspection of a repair station, Rebuilt Aircraft, and noticed that the repair station was not following the manual correctly, using the correct work orders, tracking the shelf life of supplies with expiration dates and other discrepancies. The inspector processed an enforcement action and recommended a sanction of $23,100. As is often the case, the FAA attorney negotiated the penalty with the repair station and the case was settled with a $500 fine [a 98% reduction] … Following this case, the owner of the repair station complained about the inspector and wanted the inspector removed … to appease the owner, FAA management decided to remove the inspector ….

  • “The industry has also become adept at using the CSI process to move certificates to different FSDOs. For instance, inspectors working in the Minneapolis FSDO were holding Champion Airlines strictly accountable to follow the certification process [Champion has since declared bankruptcy]. The airline complained to the FAA and the certificate was moved to the Northwest Airlines CMO in 2005. In addition, when the O’Hare FSDO discovered several safety-related issues with Midwest Airlines [now in bankruptcy], the certificate was transferred to Milwaukee in 2005.

Due to the repeated misuse of the CSI program, PASS recommends that there be an independent review of the program to ensure that it is being used properly and achieving intended results.”

One might ask an even more salient question: is a customer service initiative, focused on the airlines as clients, even necessary? Just five years after Congress voided the FAA’s dual mandate (promote aviation, oversee safety) the CSI was created, and it had the effect of undercutting the Congressional intent that the FAA concentrate solely on safety and adherence to the Federal Aviation Regulations.

An added thought occurs: if the FAA were renamed the Federal Aviation Safety Agency (FASA), it would be difficult for managers to rationalize the customer service initiative, given the overarching mission of safety. Admittedly, changing the title of the agency may be seen as a small thing, but over time and over the course of numerous Congressional hearings, any testimony that conflicted with the title of the agency would be cause for embarrassing questions, like, “What don’t you understand about the Safety in FASA?”

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