While generally praising the FAA’s system of designated examiners and representatives, a Government Accountability Office (GAO) report said that the agency has not ensured that its oversight process for designees is consistent among its field offices.
The GAO did not find systemic safety problems associated with the FAA’s oversight of designees but warned that inconsistent oversight limits the FAA’s ability to ensure that the designees’ work meets the agency’s standards and policies.
As the investigative arm of Congress, the GAO found examples of weaknesses in the FAA’s designee programs–such as inspectors with too great a workload to conduct required surveillance of designees–that underscore the need for the FAA to ensure that its staff consistently follows agency policy concerning oversight of designees and validates those policies and their application through periodic evaluations.
The GAO prepared the report at the request of Rep. Peter DeFazio (D-Ore.), the ranking Democrat on the House aviation subcommittee. As part of its investigation, the GAO enlisted the help of about 60 experts, including some from general aviation organizations.
The FAA has been using designee programs since the 1920s to concentrate its limited staff resources on the most safety-critical functions, such as certifying new and complex aircraft designs. But according to the GAO, the FAA has evaluated only six of its 18 designee programs over the past seven years.
All pilots are familiar with aviation medical examiners (AMEs) and designated pilot examiners (DPEs). Three FAA offices–Flight Standards Service, Aerospace Medicine and Aircraft Certification Service–all of which are under the office of the associate administrator for regulation and certification, oversee the AMEs and DPEs, as well as the 16 other designee programs.
Nearly 13,400 technically qualified individuals and about 180 organizations perform thousands of certification tasks each year as FAA designees. That represents more than 90 percent of the FAA’s certification activities. The designees have proven to be convenient to the aviation industry because they are spread throughout the nation.
Improving the Designee Program
The GAO said the FAA’s inconsistent monitoring of its designee programs and oversight of its designees are key weaknesses of the programs. While the FAA has evaluated half a dozen of the programs– and plans to evaluate two more–it has no plans to evaluate the remaining programs because of limited resources, according to a program official.
The agency does not have requirements or criteria for periodically evaluating its designee programs. It conducted the six evaluations on an ad hoc basis, usually at the request of FAA headquarters directors or regional office managers.
Although the FAA uses these evaluations to determine whether designee programs are being carried out in compliance with agency policies, it has not implemented some of the recommendations from these evaluations.
“For example,” said the GAO, “a 2000 evaluation of designated alteration stations recommended that the FAA establish a process to periodically assess the effectiveness and applicability of existing oversight policies concerning designated alteration stations and consider feedback from FAA field offices and designees as part of that process. The agency has not implemented this recommendation.”
The GAO found that the FAA field offices do not consistently implement agency policies on monitoring, selecting and terminating designees. For example, it said that inspectors in one region were not reviewing designated pilot examiners’ work annually and were not conducting oversight as required by agency policy.
According to the GAO, the FAA’s lack of oversight limits assurances that the designees are performing their work properly. The GAO said the FAA’s incomplete databases on designees’ performance and the workload demands and lack of refresher training for FAA staff who oversee the designees hamper the agency’s oversight.
The GAO said that the database the FAA Office of Aerospace Medicine uses to monitor the activities and performance of AMEs could serve as a model for the offices that lack comprehensive databases on designee activities. Although this database was designed to simplify processing airmen medical certification information, the office of Aerospace Medicine also uses it to extract information on the status of aviation medical examiners and monitor their activity levels.
“Careful consideration of such opportunities is important,” the GAO report said, “both because of the central importance that the designee programs hold for the FAA as well as the agency’s plans to expand the use of organizational designees, which will further transform the FAA’s role to that of monitoring the performance of organizations rather than overseeing the individuals who perform the certification activities.”
The GAO pointed out that Transport Canada identified the need for standardized oversight practices and frequent audits of its designees as important components of its programs.
The GAO discovered that FAA offices do not always identify and remove inactive or poor-performing designees expeditiously, which may be the result of reluctance on the part of managers, engineers and inspectors to take disciplinary action. FAA policy calls for providing counseling, remedial training or limiting or terminating designees’ authority for insufficient work activity and poor performance.
The GAO recommended that the FAA establish a program to evaluate all designee programs, placing a priority on the 12 programs that have not been evaluated; develop mechanisms to improve compliance with existing policies concerning designee oversight; and upgrade its databases, even if it means charging fees to designees to defray the costs of such efforts.