Now that I am in my own house again after six years, I am beginning the process of reengaging in activities that I enjoyed when I mailed in my last mortgage check seventy-two months ago, one of which is to take part in a local 5K. There is something to be said for building up your endurance from a few ¼-mile laps around the track to 3.1 miles of non-stop running; it tests your mettle, challenges persistence, dismisses procrastination and forces one to realize the most soul-searching fact that one must face at least once in life … Man, am I getting old.
It is difficult to slide back into the game, especially when you make life-changing moves across the country and back again, while some changes hardly affect your life, like going on vacation across the country and back again. But when your job alters dramatically, restricts your effectiveness, with no return-to-normal date in sight, it is unsettling to say the least; the Return becomes the Goal, when you can again do what you do best, be what your career has developed you to be: a Positive Force.
To the average Federal Aviation Administration (FAA) aviation safety inspector (ASI), it is their career to be a positive force for safety. Telling ASIs they cannot – will not – conduct certificate surveillance or when on-site inspections are required, do them virtually, is the equivalent of hobbling them. The FAA ASIs I have worked with do not drive a desk; they are in their environment: on a plane, in a hangar, walking the ramp, chatting it up with certificate holders, promoting safety; that is what they do best.
The FAA has stated that it will be going back to pre-COVID services, very likely in March – fingers are crossed. After two long winters of COVID-19 (shouldn’t it at least be COVID-21 or -22 by now?), regulators are cautiously raising their heads out of a management-imposed underground existence. Like Gobblers Knob’s Punxsutawney Phil squinting in a February early morning dawn, looking for his own shadow, the FAA managers will arise from the bunkers and allow inspectors to reengage the industry, face-to-face. And then, like the famous Sciuridae marmot, many FAA managers will back down their home office holes, overflowing with M&Ms, Hostess Cupcakes and disposable Keurig K-cup coffee; the managers will sigh, taking solace in the current Administration’s ‘sit-back-and-wait’ approach that communicates that everything will be, “… just okey-dokey, fine” – even when it won’t.
Is this an exaggeration? It may be cynical, but not far from being accurate. Since the aviation community became engulfed in COVID scare tactics as a means to ‘save us’, regulatory agencies like the FAA have practiced a torpid attitude toward their responsibilities. Will the FAA’s two years of ‘be-COVID-safe-and-engage-as-little-as-possible’ approach to aviation safety have long term negative effects on the aviation industry and safety? You betcha. Any agency with as much responsibility as the FAA has cannot pull back without crippling the progress it made and stunting its forward progress.
In a recent symposium I attended – virtually, of course – the general agreement was that we have the safest aviation industry … EV – ER; it would be impossible for us to slide backwards from this lofty position. Yet, FAA inspectors on the front line, as well as some that have retired, share my uneasiness. They, too, feel something will shake this industry to its core, that this mislaid self-congratulatory back slapping with the harsh reality of safety … or lack thereof … is all a facade.
We were fooled; we have been hushed into false refuge, a complacency that has duped us into thinking that the skies will always be safe and that we are beyond reproach. Why? Because people in authority said so, that’s why. Is this reality? To be clear, the FAA has been on a two-year self-imposed hiatus, hiding from COVID boogeymen, as if concealing oneself in a basement or home office, retaining six-foot separations and porous masking, could ever guarantee protection from microscopic viruses. The FAA was unseen; they have not been ‘kicking the tires’, diligently keeping the aviation industry on its toes.
The 4th century Roman military writer, Vegetius, once stated in his work, Epitoma rei militaris, “Si vis pacem, para bellum,” translated: “Let him who desires peace, prepare for war.” What is missing is the word ‘always’ before “prepare for war.” If Vegetius were alive today and worked for the aviation industry, he’d say, “Let he who desires safety, [always] prepare for danger; carelessness; complacency; ignorance; etc.” In other words, we can’t walk away from our responsibilities and not expect an opposite reaction. We should have been, must always be, diligent … always.
The industry has also been lulled into a false notion that since accidents had decreased, all is well in Aviation Land; no worries; move onto other business. It is highly likely that, while the aviation industry rested on its collective self-confidence, the unwatched in the industry have continued to cut corners, replacing safety with saving money. That is the reality that has evaded regulators and accident investigators for decades, that human nature will find a way, will fill the oversight vacuum with strategies they would not employ if the FAA were 100% attentive. Passenger traffic down? Lay off ramp people needed for safety. Never realized storing aircraft for three months would result in pickling them for two years? We’ll just get some exemptions or get with engineering. Training put on hold for months? The Training department will figure out something.
It is beyond the pale that anyone, associated or unassociated, with aviation could think that the last two years of distancing from the industry, allowing industry to be ‘on its own’ would not, could not produce any kind of safety environment but one of deep concern. Regular on-site surveillance has become almost non-existent due to mismanagement … and I do mean mis[sing] Management, for regulators and the certificate holders. Where investigations that demanded face-to-face interviews, first-hand observations and personally checking important documentation, such as training records, revised manuals and tool tracking, the FAA workforce were expected to conduct these oversight responsibilities virtually, trusting to the certificate holder to be forthcoming with all questions and concerns.
Two years ago, trust without verification did not, would not, could not, happen; this approach defied everything the FAA stood for. Investigations demanded ASIs’ physical presence; paper documents necessitated visual verifications that could not be performed over a teleconference or virtual meeting format. Trust was earned – often daily – not meted out in place of performing one’s obligation. The FAA’s role was as the regulator, a tremendous responsibility that should never be compromised for any reason. Did FAA management make itself obsolete by requiring ASIs to do their safety-intensive jobs from miles away, jobs for which each ASI is, and always have been, passionate about?
Is this question an exaggeration? Hardly. The B737-MAX was splashed across headlines for months following the Lion Air and Ethiopian Air accidents. The MAX received more attention when the FAA was excoriated for approval failures. Then, after public condemnation receded, the FAA testified on the Hill last Fall that Boeing somehow used inexperienced engineers (OOPS!) for certifying aircraft a-a-and the FAA didn’t notice. What?! So, the FAA missed big certificate holder problems in its own backyard – Boeing. Why would anyone think that certificate holders’ airplanes, pilots, employees, contractors, etc. would receive adequate virtual oversight from ASIs half a country away?
Not only has the chasm between the regulator and the regulated become almost unbridgeable, but the FAA’s own inner checks-and-balance systems have fractured, and worse, vanished altogether. FAA management allowed safety programs that kept its own efficiency go stale or flatline. In 2007, the FAA became International Organization for Standardization (ISO) 9001 certified. Past FAA administrations managed to keep this ISO 9001 certification – not easily acquired – by regularly conducting internal audits that guaranteed standardization and efficiency. ISO 9001 ensured that seven regions of the FAA operated as one, not seven regions operating as seven FAAs, as it will return to. Have these programs survived? Were they shelved or simply eliminated because, you know … COVID?
Have the increasing number of inspector retirements or inspectors leaving to return to industry hurt? Are new inspectors being hired in time and numbers to replace the departing inspectors? Probably not. New inspectors have to be trained, beginning with a three-month indoctrination. Then there are months of on-the-job training events before an inspector can solo, all the while the industry gets further and further away from safety. Since departures outnumber hiring, when will manpower return to pre-COVID norms?
It was never clear, at least not to me, how maintaining the exceptional oversight of aviation safety had anything to do with COVID; there were – and are – ways to be careful and work around health concerns. People fly every day, in a confined metal tube, sitting inches from their neighbor with ineffective masks. But safety surveillance cannot be accomplished? Did restricting ASI ramp or hangar surveillance outside in the fresh air make sense? Those misuses of time and opportunity will be telling to see how aviation safety will suffer. Two years ago, the industry kept regulators busy, busy, busy. Can regulators ever return to that type of endurance again?