The FAA’s Consistency and Standardization Initiative (CSI) — formerly the “Customer Service Initiative” — has given those affected by agency decisions a process they can use to ask for review at increasingly higher levels of the FAA with no fear of retribution.
CSI began life as the Customer Service Initiative in 2004. The name change to the Consistency and Standardization Initiative emphasizes the original intent to ensure consistent interpretation and implementation of agency regulation and policies. CSI defines what the aviation community can expect from the FAA when doing business with any Aviation Safety office, and what we expect from the community in return.
The program has always made clear the FAA’s top priority is safety, and that the goal is to ensure consistent interpretation of agency regulation and policies throughout the FAA. Since it became operational in February 2004, CSI has processed 350 appeals.
How It Works
The CSI process allows for multiple stages of review within the FAA’s Aviation Safety organization. At each level, and between levels, the review progresses through increasingly higher levels of management.
When someone (the “stakeholder”) disagrees with a decision from an FAA inspector or engineer, the employee’s manager reviews that decision. The stakeholder and the FAA employees may have face-to-face meetings, telephone conversations or e-mail exchanges to try to resolve the issue at the local level.
If the stakeholder still isn’t satisfied with the FAA’s proposed resolution, they start the CSI process with the field office manager. Stakeholders must support their position with specific documentation, not just opinion. For example, if an FAA office requires something in a manual not called for in a regulation, the stakeholder must cite the regulation. The field office may suggest applying for a regulatory exemption or some other alternate means of compliance.
If a stakeholder doesn’t accept the proposed resolution at the field level, they can appeal to the appropriate FAA regional office. Regional management reviews the stakeholder’s appeal file. The manager and other FAA employees may meet directly with the stakeholder to discuss appeal documentation and negotiate a decision. If the stakeholder is satisfied, the appeal case may be closed. If not, the appeal may be addressed to the “service” level, i.e., Flight Standards or Aircraft Certification at FAA Headquarters in Washington.
The service director examines the stakeholder’s documentation, the field office’s resolution, and any additional information added during the division or directorate review. The goal is to determine if there is any new or mitigating information that might help identify alternate paths for resolution. The director may ask another office (e.g. legal) to recommend an action. When the director makes a decision, it is communicated to the stakeholder and the related offices.
Although the service director’s decision is considered a final technical determination, within a specified time period the stakeholder may appeal to the Associate Administrator for Aviation Safety for a review. If the Associate Administrator concurs with the service director’s decision, the stakeholder has exhausted the appeal process, and the decision is final. If the Associate Administrator disagrees with the service director’s decision, he or she may direct the issue be resolved at a previous level of review.
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...
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