CSI: Washington

If Joe Hertzler had to pick one single issue that exists in our industry regarding our ability to work efficiently with the FAA he would have to say it is a lack of standardization between FAA offices. The FAA’s Customer Service Initiative (CSI) program...

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.

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