If I had to pick one single issue that exists in our industry regarding our ability to work efficiently with the FAA I would have to say it is a lack of standardization between FAA offices. Having worked in the maintenance compliance arena now for almost 20 years, I have seen the difference in regulatory interpretation between offices cause confusion, frustration, and lack of trust between industry and the FAA. Such confusion, frustration, and lack of trust results in everything from adding unnecessary personnel to support a high maintenance FAA safety inspector to payment of thousands of dollars in fines rather than question the interpretation of an FAA safety inspector.
For many, dealing with the FAA is a necessary evil. Because we work in a highly regulated industry where safety is critical, the FAA has an extremely important role to play. Unfortunately, time spent working with and satisfying the FAA does not generate revenue and albeit necessary, takes away from the bottom line. I continually teach that the most effective way to work with the FAA is to dedicate personnel to manage and control organizational quality and compliance and ensure that those persons are experts in all regulations that pertain to your specific business. Not just knowledgeable, but expert enough to know if the FAA is right or wrong when an issue arises. People working within the walls of your organization will always know more about your business than the FAA. In order to be effective in working with the FAA they must also know as much or more about the rules that govern your business and how you are in compliance with those rules.
Customer Service Initiative
As many of you are likely aware, the Customer Service Initiative (CSI) program was first mentioned by FAA Administrator Marion C. Blakey on Feb. 20, 2003, in a speech at a luncheon meeting of the Aero Club of Washington in Washington, D.C. In her speech Ms. Blakey made the following statement regarding inconsistent regulatory interpretation and enforcement and the FAA’s plans regarding CSI:
“One thing that we’ve heard over and over is that we need to be more consistent with our customers. You can get one answer from one FAA office or region and another from another. So, I’m announcing today a new customer service initiative that provides written guidance and training to all managers and supervisors in our regulation and certification offices throughout the country on applying FAA rules and policies in a standard and consistent manner. And, we want to know from our customers if we’re not being consistent. We’re going to let them know that they have the right to ask for review on any inspector’s decision on any call that’s made in the certification process … that they can “buck it up” to first-line supervisors, field office managers, regional division managers, or even to Washington if necessary — with no fear of retribution. Information on how to do this — names, titles, and phone numbers — will be prominently displayed on the Web and in all our regional and field offices. We need your help to make this program a success.”
For a complete copy of Administrator Blakey’s speech go to: http://www.faa.gov/news/news_story.cfm?contentKey=2992.
Since then, the FAA has made an effort to get the word out to industry that the program is underway and encourages industry to start pushing back when they feel that the local FAA office is inconsistent in its approach or interpretation. My observation is that the key to the success of the customer service initiative is to gather data from “the customer” — industry. You see, as industry questions regulatory decisions made by the local FAA and requests a supervisor’s review of the issue through the CSI program, the database will receive a record of the question and ultimately the final decision. The FAA will then be able to identify issues that are most commonly misunderstood either by the FAA or by industry and share that information throughout the agency, providing for more consistent interpretation of the regulations (at least on the most common issues) across the board.
The most difficult part of the CSI program has been to get industry to participate. And unfortunately, without industry participation the program is going nowhere. We all work hard to establish a relationship with the FAA inspector that we deal with day-to-day. One major issue keeps us as an industry from participating in the CSI program and pushing back on our local FAA inspector. We are simply afraid of retribution or retaliation. It’s easy for Washington to say that there will be not retribution but once the dust settles, the local FAA could potentially make your world extremely difficult. At least that is our fear.
Commitment From the Top
As I read through this program material, I notice something that makes me believe that the CSI program may indeed be able to put our fear to bed. It is not our local FAA inspector who is telling us not to fear retribution. It is the highest FAA official in Washington, FAA Administrator Marion C. Blakey. This means that FAA headquarters in Washington is aware of our fears and has put in place a program intended to prevent such retribution. Because the success of the program depends on our use of the program, retribution can not be tolerated, period. If for some reason you experience some sort of retaliatory action from your inspector, I am certain that it will be acted upon very quickly by supervisors and managers.
When reading through the guidance information provided by the FAA for the CSI program, it seems obvious that a primary objective of the program is efficiency on the part of the FAA and that it too will benefit as an organization when there is a consistent and even-handed approach to compliance enforcement. In a memo to all managers within the Regulation and Certification branch of the FAA (AVR) — Nicholas A. Sabatini, the associate administrator for aviation safety put it this way: “The customer service initiative enables us to better document AVR decisions; helps us to be consistent and fair in application of our regulations; and promotes earlier resolution of disagreements.”
The CSI program is also intended to force accountability at all levels within the organization. If implemented correctly, the accountability will force safety inspectors to stop hip shooting issues and really investigate the situation from the beginning.
Nicholas A. Sabatini goes on to say in his memo “… we will continue moving our organization in a positive direction, where every member of the team is fully accountable in a way that is significant for mission success.”
The FAA CSI program could be a tremendous step forward for our industry if implemented correctly. But we have to play too. Please take the time to look into the program and understand how simple it is to submit a request for review. Don’t expect your local inspector to be doing back-flips over the program. They are going to be held more accountable than ever before for their decisions.
In closing, there are several documents of interest associated with the CSI program all of which are available at the FAA web site. This includes a document titled “Operator’s Guide to the AVR Customer Service Initiative”. This document includes lots of good information but I want to share with you two that give me some hope for the program:
“The goals of the AVR CSI and our CSI: (Flight Standards) are as follows:
- Promote more consistency and fairness in applying FAA regulations.
- Promote earlier resolution of disagreements.
- Better document our decisions.
- Make every Flight Standards employee accountable for achieving the Service’s mission.”
Think about it; consistency, fairness, accountability — these are goals set forth by the Director of Flight Standards in Washington (as directed by the administrator) James J. Ballough. I think that is a significant step in the right direction.
Following are the documented customer service principles. “As our customer, you can expect from us:
- Service that promotes a safe, secure, and efficient aviation system.
- Considerate, respectful, and professional service.
- A clear explanation of the requirements, alternatives, and possible outcomes associated with your inquiry or request.
- A timely and complete response to your inquiry or request.
- A clear explanation of our decisions.
- An environment without fear of retribution if you challenge our decisions.
- Fair and careful consideration of your issue.
- Clear guidance on how you can elevate your concerns to the next higher level of authority.”
Regardless of if or how you use the FAA CSI program, I must re-emphasize the need to get smart on all of the regulations that affect your business. And know, without a doubt, how you are in compliance and how you are staying in compliance with those applicable regulations. It is critical to the success of your business.