DOT-OIG Report Criticizes FAA’s Repair Station Oversight

The DOT Inspector General’s Office has released a report that is critical of the FAA’s oversight of repair stations.

The Report follows-on to earlier DOT-OIG reports that were issued in 2003 and 2008 and addressed FAA oversight of repair stations.

The 2003 Report explained that the auditors had found non-compliances at repair stations and attributed those non-compliances to lack of effective FAA oversight.

In 2008, DOT-OIG concluded that the FAA was not effectively focusing its inspection resources on those repair stations providing the highest volume of repairs.  DOT-OIG felt that this caused deficiencies at repair stations to go undetected or reoccur.  They also felt that this prevented FAA inspectors from obtaining sufficient data to perform comprehensive risk assessments.

The most recent report in the series was issued May 1, 2013.  The Report acknowledges that FAA has created a risk assessment tool, but found that it is not being well-used for a variety of reasons, including conflicting guidance, ineffective checklists, narrow data pools for conducting risk assessment and lack of FAA inspector training.  DOT-OIG opined that “As a result of FAA’s insufficient oversight, some repair stations may not be operating in full compliance with Federal aviation regulations.”

To enhance its oversight of repair stations,DOT-OIG recommend that FAA:

  1. Modify its oversight system so that all inspection elements are considered in inspector risk assessments of repair stations.
  2. Implement a risk-based system appropriate for oversight of foreign repair stations.
  3. Modify the risk assessment tool so that inspectors can document changes to their surveillance plans as soon as they are made.
  4. Develop a control that will ensure inspectors prioritize inspections to those repair stations determined to have increased risk.
  5. Enhance training for inspectors so they understand the importance of using the available tools for assessing and trending risk.
  6. Develop the Repair Station Data Package and provide training to all inspectors on how to use it.
  7. Develop a standardized checklist that all inspectors can use to improve the consistency in the way they perform and report their inspection findings.
  8. Provide training for inspectors to improve their review and acceptance of repair station corrective plans.
  9. Provide training to inspectors on how to conduct comprehensive post-inspection briefings and require them to issue a draft report of tentative findings to repair station officials at the conclusion of inspections.

In response, FAA pledged to offer training to its workforce, and improve the capabilities and performance of the risk-based analytical tools available to inspectors.

DOT-OIG was pleased with most of FAA’s remedial plans but remained concerns about three areas:

  1. FAA stated that it will conduct recurrent training to improve the use of the risk assesment tools, but DOIT OIG noted that this did not help the fact that FAA inspectors continue to complete mandatory inspections instead oftargeting resources where they are needed based on risk.  DOT-OIG felt that additional training would be helpful, but it would not address the fact that FAA guidance requires only seven inspection elements to be assessed for risk while the other nine are inspected annually, regardless of risk.
  2. FAA also relied on training as a remedy to the failing in the risk assessment tool, and DOT-OIG felt that this would be inadequate because some of the design-based failings and limitations of the risk-based system needed to be modified.
  3. Finally, DOT-OIG expressed concern that “FAA still lacks a method for verifying whether inspectors actually meet the requirements” especially in light of the audit finding that showed that “many inspectors do not effectively prioritize their inspections based on risk.”

Entitled “FAA Continues To Face Challenges in Implementing a Risk-Based Approach for Repair Station Oversight,” the report is available online.

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About Jason Dickstein
Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Aircraft Fleet Recycling Association and the Modification and Replacement Parts Association.

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