NASIP's Last Gasp
National Aviation Safety Inspection Program — gone with the wind
By Stephen P. Prentice
September 1999
In 1986, an inspection process was created to provide a periodic inspection for air carriers and repair stations. Technicians employed in these areas most likely are familiar with this inspection that some time later was called NASIP (National Aviation Safety Inspection Program). Air carrier and repair station technicians may have experienced at least one or more NASIP inspection periods if they have been on the job long enough.
This examination has been the classic conformity inspection by independent FAA inspectors who were directed to determine if an air carrier or repair station was being run according to the regulations. It was designed to be an independent assessment of regulatory compliance.
The theory behind the independent inspection is simple. FAA wanted outside inspectors to double check what the local assigned inspectors were doing in the area of compliance. FAA recognized that oversight provided by local assigned inspectors may not see the trees for the forest. That is, the thinking was that familiarity with the carrier may breed a loss of objectivity.
ValuJet NASIP We all remember ValuJet. After the accident, there was an immediate check on the airline by a large cadre of FAA inspectors. These outside inspectors were brought in to see just what was going on with regard to the extent and quality of surveillance by the local Flight Safety District Office (FSDO) inspectors. The whole affair turned out to be a very troubling exercise. Very little has been written about the aftermath of the inspection. However, the Department of Transportation Inspector General (DOTIG) determined and stated that there was an ongoing battle between the local nspectors and the outside inspectors that resulted in a less than adequate conclusion to the process. Valujet may well have been the swan song for the NASIP style inspection!
The DOT Inspector General
After the ValuJet inspection report was published in February 1998, relations became so strained that the Department of Transportation Inspector Generals Office was asked by Congress to look into the whole affair and determine what, if anything, went wrong with the process. In effect, they were asked to review the inspection and more importantly, NASIP. As we all should know by now, ValuJet is alive and well today under the name AirTran airlines.
You have to remember that the FAA falls under the jurisdiction of the DOT and the Inspector General (IG) is supposed to act as FAA's watchdog. The IG has a specific statutory duty to keep an eye on how the FAA and the rest of the Department of Transportation do their jobs.
In completing their NASIP review, the Inspector General's staff interviewed FAA employees, NASIP team members, and airline officials. They examined all of the relevant documents, including enforcement action investigative reports.
The IG's Office was asked to determine the systemic weaknesses in NASIP and to evaluate the process used to develop the ValuJet report.
The results were predictable. People in the industry had pointed to many deficiencies in the inspection program. The former IG, Mary Schiavo, who left the office under pressure after firing critical salvos at FAA, would no doubt be pleased by the findings of her replacement.
Inspector General's conclusions
Following is a summary of findings by the Inspector General:
1. Many NASIP inspectors were inexperienced and some were even in a training status.
2. The NASIP inspection process does not identify systemic weaknesses.
3. FAA failed to insure that guidance was followed, communication enhanced and report quality reviewed.
Concluding from the above, the IG found that air carrier compliance may go undetected and more important, uncorrected. Therefore, the final NASIP report may be flawed.
FAA response
FAA's response to this critical assessment of their work was somewhat surprising. They concurred with all the findings and recommendations of the Inspector General and simply stated that the inspection process would be strengthened.
A NASIP inspection has sometimes been a difficult time for any air carrier. The Maintenance department is usually singled out for intense scrutiny simply because this is usually where most non-compliance is found. However, NASIP procedures will no longer apply to the new Air Transportation Oversight System of continuous data inspection.
The critical IG report on the ValuJet examination resulted in FAA fine tuning an inspection process to replace NASIP. The ATOS (Air Transportation Oversight System) has now been in place since October 1998, but only applies to the ten largest air carriers for the time being. It is a continuous data collection and evaluation inspection system. ATOS is set up to automatically ring bells when something is amiss with the airline in question.
CSET
CSET (Certification, Standardization and Evaluation Team) is a supporting component of ATOS. CSET was created in February 1997 to provide a national team of experienced aviation safety inspectors trained in certification procedures and requirements. This newly established group of inspectors supports the ATOS system, and will also be available to fill the void left by the demise of NASIP when an inspection requires their expertise. The plan provides comprehensive surveillance for each airline entity that will continuously monitor the regulatory health of the airline. Joint FAA/air carrier safety teams will analyze the information to determine any corrective action that is necessary.
Inspector General oversight
There is no doubt that the Inspector General's evaluation played a significant role in FAA starting a new approach. The pressure from ValuJet resulted
in some heads rolling, meaning retirements at 800 Independence.
After the initial phase of the new system is completed, it will be applied to the rest of the airline and repair station industry as resources permit. This will be a major task at first and technicians and management will play a significant role in the process.
What this means for air carrier maintenance staff
The Inspector General focused on several significant maintenance areas that should get management's and technician's attention. Since the new approach to compliance has to do with a continuous process, the IG, CSET, and local inspectors place a strong emphasis on the FAR mandated (FAR 121.373) Continuing Analysis and Surveillance Program (CAS). It is easy to see why this is the case. This requirement is a fundamental step toward ATOS. Once experience with an internal CAS system is in place, it is a relatively easy move into ATOS. This is clearly one of the reasons that a continuous maintenance analysis system is important and required.
In addition, to insure that independent review continues, FAA plans to include all air carriers in the new surveillance system. This system, as noted, looks more at trend analysis and will not require the type of inspection process found in NASIP. That's the good news.
But don't get the impression that you won't be inspected. The Inspector General's final comment to FAA was that independent inspection assessments should continue in some form until such a time as ATOS is fully implemented and shows that it works. Lets see what develops.
