Last month, an independent committee I co-chaired released a U.S. Department of Transportation-commissioned report on the Federal Aviation Administration’s aircraft certification process. The report, which the Secretary of Transportation appointed us to write after the tragic loss of 346 lives in two separate 2019 crashes of Boeing 737 MAX 8 aircraft — one in Ethiopia and one in Indonesia — offers to Congress and to federal regulators a blueprint for reform of the aircraft certification process, with numerous actionable items that would immediately enhance global aviation safety.

It is important to note from the outset that it is safer to fly in an airplane in the United States than to walk down the street, ride a bike, drive in a car or travel on a train. In the past two decades, improvements in technology, training, procedures, and oversight combined to reduce the air carrier fatality rate from 80.9 per 100 million passengers boarded in FY 1996 to 0.6 per 100 million passengers boarded in FY 2019. That is a remarkable achievement; however, we must always strive to do better and improve imperfect processes. The loss of 346 lives in 2019 motivated us to find tangible ways to improve aviation safety with improvements to the aircraft certification process.

After more than six months of intensive study and deliberation, our committee made dozens of recommendations can now put into action to enhance aviation safety and keep up with changes in technology and the evolving globalization of aviation. This blueprint for action represents real, tangible and nonpartisan solutions based on a fact-based assessment, devoid of emotion, conflicts-of-interest, and partisanship. While there are other, more sweeping changes to the FAA certification process being deliberated in Congress, and typically mired in partisan battles, our committee’s recommendations should be considered the “low hanging fruit” that every member of Congress can and should get behind, regardless of political affiliation or ideology. 

Our blueprint begins with recognition of certain shortfalls in the existing certification process. Currently, the FAA does not have a mechanism for influencing the maintenance and pilot training requirements for U.S. products operating under another nation’s civil aviation authority. This is a fact that the FAA should take into account, as the differences in flight crew training and operator oversight internationally are important factors in the future operation of U.S.-manufactured and certified aircraft. Previously held assumptions on pilot skill levels and training cannot be relied upon. Our government must ensure that aircraft manufacturers design aircraft that take into consideration the expected end-users in a global marketplace, and variances in approach to pilot training and oversight worldwide. The FAA also must expand its engagement, policies, technical assistance and training efforts to foster higher international safety standards and practices for aircraft certification, operations and maintenance. This should include operational requirements as part of the type certificate – or approved design – of aircraft.

Aircraft design and manufacturing organizations like Boeing, Gulfstream, and GE Aviation should be mandated to have a Safety Management System, similar to the SMS required for large commercial and cargo airlines like American Airlines, Southwest Airlines and Federal Express Corporation. This codified system would help to ensure a holistic, proactive assessment of whether the combination of design, procedures, and training will support effective safety performance. Going forward, the FAA must take a total system approach to safety, linking all safety requirements from type certification to pilot training, and operational performance of the product and expand consideration of human–machine interaction.

The FAA should remove exclusions for skill-related errors associated with manual control of the airplane and ensure crew interaction with automated systems active in manual flight are systematically assessed. Further, going forward, the FAA should enhance standards to ensure that systematic human factor analyses are conducted for all safety-critical functions and failure modes associated with a change under the changed product rule. Test and evaluation should include multiple failure mode scenarios and involve trained pilots who again reflect the actual anticipated end-users of the product.

The system of delegated authority in aircraft certification needs reforms to ensure means of communication are clear, delegated personnel have appropriate system thinking skills, and concerns about potential undue pressure from industry are addressed. Further, a continued focus on change management is needed to empower FAA staff and enable them to adapt to a changing work landscape. The FAA should provide clarification and guidance on how and when FAA technical specialists and Organization Designation Authorization holders communicate directly regarding technical concerns.

Enhancing aviation safety when the system is already very safe is challenging, yet it is obtainable. This blueprint can serve as a guide to Congress for legislation and to the DOT and FAA for regulatory reform that can make our system safer. Additional reforms may be needed, but at a minimum, these recommendations should be carefully studied and acted upon.

Originally published on Morning Consult.

Lee Moak

Lee Moak

The focus, determination, and leadership skills developed over the course of Captain Lee Moak’s career as a Marine Corps and Navy fighter pilot, B-767 Delta Air Lines captain, and as President of the Air Line Pilots Association, International (ALPA), have led him to become a significant force for change in the realm of air transportation and international policy. Captain Moak’s extensive experience within the corporate, labor, and political worlds allows him to offer clients an expansive perspective on their business and policy agendas that has proven to be both widely applicable and incredibly effective. An aviation safety expert, Captain Moak recently served as co-chair of the U.S. DOT’s Special Committee to Review the FAA’s Aircraft Certification Process and currently serves on the FAA’s Drone Advisory Committee (FAA).
Lee Moak

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