The Game Is Over!

Plain language initiative should resolve misinterpretations of Federal Aviation Regulations

For decades, many mechanics secretly suspected that most bureaucrats are cerebrally short-changed and soft around the edges. These suspicions are strengthened by daily affirmations of fact when they sit down and ponder the darker meanings of the Federal Aviation Regulations (FAR).

Suspicions quickly turn into belief when, out of frustration, a mechanic calls the local Flight Standards District Office (FSDO) inspector to find out just what the heck the rule is supposed to mean.

He gets an answer. Not quite sure of the validity of this first answer, our suspicious mechanic administers a time-honored litmus test, and makes a call to another FSDO. From what mechanics tell me, one out of four times that a mechanic calls for a second opinion, he will get yet a different interpretation of the rule.

Interpreting the rules
Our mechanic is not surprised if this second answer is 90 to 180 degrees off from the first interpretation of the rule because most mechanics know that interpreting the legal language in a rule is an art form and not a science. In many ways, reading a rule is like reading the ancient Mayan petroglyphs on a temple wall. You never are quite sure what the author truly wanted because most of our rules go back to the 1940s and 1950s — the guys who wrote them are no longer around. So, depending on what side of the fence you live on, mechanics and FAA inspectors rule interpretations float between a positive and negative answer. Like so many times before, our intrepid mechanic picks the “official” answer he likes the best and presses on. And this is how “Interpret the FAR” game has been played for the past 30 years.

In defense of my FSDO inspectors, be advised that they do not write the rules. These folks are not bureaucrats, they are inspectors. However, they still have the less than enviable task of explaining, enforcing, and defending the FAR — which is all the more difficult, because they must interpret the rule from the same Code of Federal Regulations that our mechanic is quoting from. All in all, this word game the FAA inspectors are forced to play has the same odds of daily success that General Custer had at Little Big Horn, so be kind to them.

Blame the bureaucrats
To delegate blame and set the matter straight, it is we bureaucrats in Washington who are the ones who write the rules and generate policy that goes with them. However, in defense of my fellow bureaucrats, it isn’t easy to write a rule because there are so many interest groups and individuals beating on your door. It isn’t easy to write policy that goes along with the rule that has to explain the unexplainable in accordance with the Government Style manual. Also, please remember that all of our rule and policy work is reviewed, and re-written by members of the legal profession. I rest my case.

Written in plain language
But, delegating blame not withstanding, the “Interpret the FAR” game is on its way out. The beginning of the end of this nationwide industry pastime began with a memorandum from the White House, dated June 1, 1998 — the memorandum that requires all government agencies to use plain language in all proposed and final rulemaking by Jan. 1, 1999. In December of 1999, the FAA issued the Administrator’s broadcast message that explained the FAA’s Plain Language effort. It was quickly followed by an FAA Aircraft Maintenance Focus Group in February of this year to discuss plain language issues in the maintenance community.

The Maintenance Focus Group members consisted of aircraft mechanics, airline engineers, maintenance school instructors, and holders of Inspection Authorizations (IA). There was also a representative from the Air Transport Association and National Air Transport Association. The meeting was held here in Washington, and the group members were pleased to note that no FAA representatives were to participate in the group, so they knew that they would be spared the obligatory defense of the status quo by the establishment.

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