You can be your own aviation safety inspector or you can consider being one. Dr. Bill Johnson discusses the FAA Airworthiness Inspector, the qualifications, the training, and how you can best interact with your inspector. The article is a spin-off from a recent FAA quarterly web-based maintenance human factors newsletter.
Prior to my formal employment I had numerous associations with the FAA. I was a 50-year holder of FAA flight and maintenance certificates. I served as a Designated Mechanic Examiner, and spent numerous years as a contractor for human factors work. Those associations provided an outsider’s view of the FAA. For the past 10 years I have had the insider’s view of the FAA. Because of my chief scientific and technical advisor role, I have interacted with many of the FAA offices, directorates, and divisions. That experience has been enlightening. It has permitted me to understand and appreciate the immense FAA employee knowledge, experience, and dedication to safety. A pessimist would say that Dr. Bill finally “Drank all the Kool-Aid.” No he has not! However, I can recognize a good thing when I see it. This article focuses on the FAA Flight Standards Airworthiness Aviation Safety Inspector (ASI). The ASI can add immense value to your organization by cooperating with you not only for regulatory compliance but also for continuing safety and efficiency.
Qualifications of ASIs
The formal list of qualifications is available at the FAA web site (Google “FAA Inspectors”). That list describes the job responsibilities and necessary prerequisite experience and certification. An initial impression is that an Airworthiness ASI must be a top technical expert on the aircraft, equipment type, and organization type for which they have shared oversight responsibility. There is an effort to place those with airline experience in airline inspector positions. Same is true for general aviation experience. For the most part technical knowledge and experience is a given. ASIs have experienced the rigors of aircraft maintenance work ranging from a small shop to a major carrier. They are from MROs, manufacturers, and the U.S. military. They know maintenance.
Aircraft technical knowledge and experience are only a part of the ASIs necessary skill set. Today’s best ASIs must be particularly good with interpersonal skills. They must relate to each individual and organization as they partner in safety and compliance. They must be able to manage conflict and overcome that impression of being only a compliance officer. When potential ASIs are evaluated the knowledge, skills, and abilities (KSAs) include such things as: risk management, workload management, communications, teamwork, and more (see Table 1).
Table 1. Example of Necessary Knowledge, Skills, and Abilities for ASI Position
1. Risk Assessment
3. Workload Management
4. Information Management
7. Interpersonal Skills
8. Decision Making
After an ASI is hired their industry knowledge and experience is supplemented with extensive training, mostly at the FAA Academy in Oklahoma City. ASIs receive about 1,000 hours of resident and computer-based training in their first two years of employment. That would be equivalent to the number of contact hours for about two years of college. That training is usually supplemented with annual recurrent training. Suffice it to say that FAA ASIs have the experience and training to partner with you for continuing safety and efficiency in your maintenance organization.
Look in the Mirror - The ASI is Just Like You
As I have lectured in Inspection Authorization renewal courses and industry conferences you have heard me say “Look in the mirror to see a potential Aviation Safety Inspector.” In most aspects you and the inspectors have the same professional credentials. You share the dedication to safety in all of your aviation maintenance activities. You have and follow the regulations and have full access to the same oversight and compliance documents that your inspector uses. The inspector has the responsibility to check your interpretation and compliance with the regulations. When you combine your safety commitment, knowledge, and skill with those of the FAA ASI then everyone benefits.
When I participate in an FAA-only class I am always impressed by the overwhelmingly positive comments that inspectors make about the organizations that they oversee. They relate to the importance of efficiency and to the challenges of economics. They are consistent in the opinion that regulatory compliance, doing the job properly the first time, and attention to worker safety help ensure long-term commercial vibrancy. An inspector can relate to you.
ASIs, especially in the human factors discussions, are very sensitive and considerate when they talk about crew and passenger injury or loss. They have the same sensitivity regarding worker health and injury. I am proud of FAA ASI colleagues when they talk about the human side of the people and companies they oversee. They take pride in your success. They are just like you.
Teaming with your ASI as a Partner in Safety
Below are examples of the kinds of activities in which you can engage your ASI as a safety partner:
1. Seeking information and regulation interpretation
Inspectors know the regulations and exactly where to find pertinent information. Count on that. The information sources that they access are mostly public. If you do your homework you can have the same sources that they have. They can show you how to do that. Of course, you will not be able to see proprietary data from other companies. FAA ASIs protect all proprietary data including information that you provide.
ASIs are very good at finding manufacturer’s instructions, information about foreign aircraft and parts, and information about the European Aviation Safety Agency (if relevant to you). When you are stumped for information, call your inspector. It has worked for me, repeatedly. Just ask an ASI!
2. Voluntary reporting
The Aviation Safety Action Program (ASAP) and other voluntary reporting systems are a critical means to obtain information to foster risk-based decision making (RBDM) and your safety management system. The ASI role as a member of the ASAP event review committee is critical. Their maintenance job experience helps them to relate to human error. They are able to empathize with erring maintenance personnel. ASAP is but one example of how ASIs demonstrate their commitment to maintenance personnel. Talk to your ASI about voluntary reporting options.
Risk-based decision making is a top priority for Administrator Huerta. FAA management and the inspector work force will be asking how you find and document the small threats in your organization. Early identification and management of the small threats will help avoid the larger events. For example, if you know that you are seeing trouble-shooting challenges on new digital systems then you should consider increasing the training for your technicians. If tool control is an issue, then establish a better system to control not only company tools but also the AMT’s personal tools. A RBDM system is part of your evolving safety management system.
3. Human factors information
ASIs receive more human factors training that any other regulatory agency in the world. Airworthiness inspectors receive more human factors training than other FAA inspector categories. First of all, many come from commercial or military organizations where they have already received human factors training. Then, all Airworthiness ASIs receive a three-day residential human factors class. Many are currently taking a recurrent class, currently offered by the Department of Transportation with the FAA Academy.
While human factors training and initiatives may not be regulated that does not mean your FAA inspector is not interested. Show them what you are doing. Ask them to teach a segment of your human factors class. ASIs receive a DVD with all of the FAA human factors training materials. They will give you a copy of the disc and direct you to additional FAA materials. If the inspector does not deliver the information he/she may ask for assistance from the FAA Safety Team. Therefore ASIs, can add value to your human factors initiatives including training.
4. Finding alternate approaches
FAA inspectors have the benefit of seeing multiple organizations. Therefore they may be aware of multiple solutions to any of your challenges related to ensuring safety. ASIs also talk a lot of “shop” when back in the office. Your ASI can seek multiple ideas and solutions for your specific organization. Take advantage of that experience.
5. Specifying topics for study
FAA research and development is supposed to be practical and driven by field requirements. Ideally, the FAA Technical Community Requirements Group (TCRG) elicits ideas from the field. That would be from you through FAA personnel like the ASI. Topics are specified, planned, and presented to FAA management for funding approval. That means that you and your FAA ASI can submit topics that may be included in the FAA research portfolio. A motivated ASI, with the right management support, can make the research and development system work as designed. The Chief Scientist and Technical Advisor team help facilitate consideration of your ideas.
This article does not suggest that every ASI is a super hero. FAA strives for professionalism and trains for consistent application of prescribed safety standards. Of course, there is variance in human ASIs. Often you get what you expect. I always anticipate high standards, knowledge, skill, and partnership from the hundreds of ASIs with who I interact. I am pleased to say that I have never been disappointed.
The FAA Airworthiness Aviation Safety Inspector can be a high value addition to your organization. The ASI should be considered as an available highly experienced consultant. The ASI can partner with you to ensure safe public air transportation. The ASI can not only help ensure regulatory compliance but can also contribute to organizational efficiency and worker safety. Let’s face it. You have paid (taxes) for an outside safety consultant. You should capitalize on that partnership.
Dr. William B. Johnson is the FAA Chief Scientific and Technical Advisor for Human Factors in Aircraft Maintenance Systems. His comments are based on nearly 50 years of combined experience as a pilot/mechanic, an airline engineering and MRO consultant, a professor, and an FAA scientific executive.