june 15, 2017 chicago, il - federal aviation administration · delegation and organization...

June 15, 2017 Chicago, IL

Delegation and Organization Procedures Branch AIR-160

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Table of Contents

Table of Contents

General Session Agenda

Engineering Session Agenda

Maintenance Session Agenda

Manufacturing Session Agenda

Acronyms

3

4

100

183

236

320

General Session 8:00-8:30 Welcome Scott Geddie – AIR 1608:30-9:00 Applicant/ODA Holder Unit Responsibilities Ralph Meyer – AIR 1609:00-9:15 Break 9:15-9:45 Compliance Philosophy Hillary Heintz – AIR-1609:45-10:15 Continuous Improvement Sarah Thatcher – AIR 16010:15-10:30 Break10:30-11:15 Order 8100.15C – A New Approach to Oversight S. Thatcher – AIR-16011:15-12:00 Order 8100.15B Change 2 Ralph Meyer – AIR 160

2017 ODA Seminar – FAA and Industry Session June 15, 2017 – Chicago, IL

Agenda

Federal Aviation Administration Federal Aviation Administration Applicant/ODA

Holder and Unit Responsibilities

2017 ODA Seminar Ralph Meyer, AIR-160

2 Federal Aviation Administration Applicant/ODA Responsibilities 2017 ODA Seminar

A Systems Approach to Oversight, Compliance and Continuous Improvement

Overview

• Accountability framework– Applicant responsibilities– FAA/designee responsibilities

• In terms of ODA…..



The Underlying Premise is…



Accountability Framework Applicants for a design approval have a regulatory obligation to:

Use means of compliance acceptable to the FAA Submit data that “Shows” that their designs are compliant

Design Approval Holders have an ongoing regulatory obligation to:

Maintain compliant designs with no unsafe features Report product failures, malfunctions, and defects

FAA promotes (not ensures) Aviation Safety by… Issuing regulations Specifying the certification basis Providing guidance regarding acceptable means of compliance Overseeing compliance Taking enforcement actions as necessary Issuing certificates and approvals; and Mandating corrective action as necessary



Accountability Framework in Part 21 • An Applicant is required to…

– Conduct all inspections and tests to show compliance of design and product (14 CFR 21.33(b)).

– Make all flight tests that the Administrator finds necessary (14 CFR 21.35(b)).

– Submit all data showing compliance (14 CFR 21.21(b)). – Provide a statement certifying compliance (14 CFR 21.20(b))

• The Administrator… – Finds upon examination of the type design that applicable

requirements have been met (14 CFR 21.21(b)1). – Makes any inspections and tests necessary to determine

compliance of applicant’s design and product (14 CFR 21.33(a)).



Accountability Framework-ODA

• 183.41 Applicability and Definitions ODA holder – the organization that obtains the authorization from the administrator, as identified in the letter of designation ODA unit – an identifiable group of two or more individuals within the ODA holder’s organization that performs the authorized function



Thus:

• ODA holder – entity authorized as a representative of the FAA to perform authorized functions

• ODA unit – individuals identified by the ODA holder who perform the authorized functions

• The ODA unit is part of the ODA holder – Not a separate entity



Again…..

• The ODA unit is part of the ODA holder – Not a separate entity

• When policy, etc. refers to the ODA holder, it includes the ODA unit. – It does not mean “theodaholderexceptfortheodaunit”



8100.15 Perspective • “ODA holder” is used to generally describe the

organization – including “ODA” unit authority• “ODA unit” is used when specifically addressing

FAA functions• The ODA holder might be a certificate holder in

some cases– Required to be certificate holder for many ODA types

• “ODA” is used only to refer the “authorization”, notan organizational element



What about the ODA administrator?

• Recognized as part of the unit in 183.51. – …must have within its ODA unit-

(a) At least one qualified ODA administrator…..and (b/c) staff to perform authorized functions

• Does ODA administrator have to perform functions? – Probably, definitely, maybe not. Regulations are unclear

• Administrator is FAA POC for all requirements – Performance of FAA functions – ODA holder requirements from part 183 – “Applicant” responsibilities



“The ODA”



8100.15 Perspective

• ODA procedures manual contains all required ODA holder processes – Its not an ODA unit procedures manual, although

many of the processes define ODA unit procedures….

– Has ODA holder requirements not directly related to FAA function/approvals

• Submittal of applications • Development and coordination of certification plans, etc.



Accountability Framework ODA Holders applying for a design approval have a regulatory

obligation to: Use means of compliance acceptable to the FAA Submit data that “Shows” that their designs are compliant

ODA Holders have an ongoing regulatory obligation to:

Maintain compliant designs with no unsafe features Report product failures, malfunctions, and defects

ODA holders (through their ODA units) promote (not ensure) Aviation Safety by…

Making findings of compliance Issuing certificates and approvals



Accountability Framework in Part 21 • An ODA holder is required to…

– Conduct all inspections and tests to show compliance of design and product (14 CFR 21.33(b)).

– Make all flight tests that the Administrator finds necessary (14 CFR 21.35(b)).

– Submit all data showing compliance (14 CFR 21.21(b)). – Provide a statement certifying compliance (14 CFR 21.20(b))

• The ODA holder, through its ODA unit… – Finds upon examination of the type design that applicable

requirements have been met (14 CFR 21.21(b)1). – Makes any inspections and tests necessary to determine

compliance of applicant’s design and product (14 CFR 21.33(a)).



Questions For You

• Is the ODA holder also the applicant? • Is the ODA holder or ODA unit authorized to

perform functions? • Where does the ODA holder’s authority

come from? • Where does the ODA unit’s authority come

from?



183 Requirements

• ODA holder – Comply with manual – Ensure other duties or interference does not affect

authorized functions – Cooperate with FAA oversight – Notify FAA if not meeting 183 requirements



183 Requirements

• ODA holder– Comply with manual– Ensure other duties or interference does not affect

authorized functions– Cooperate with FAA oversight– Notify FAA if not meeting 183 requirements– Service difficulty monitoring, reporting– Records retention



183 Requirements

• ODA unit – Comply with manual – Ensure other duties or interference does not affect

authorized functions – Cooperate with FAA oversight – Notify FAA if not meeting 183 requirements – Service difficulty monitoring, reporting – Records retention



Summary

• ODA holder is designee entity acting on the FAA’s behalf

• ODA holder is normally the applicant for design approvals



Questions?

Presented: Organization Designation Authorization (ODA) Seminar-Industry Session

Date: June 15, 2017

Federal Aviation Administration

Compliance Philosophy

2 Federal Aviation Administration A Systems Approach to Oversight,

Compliance and Continuous Improvement Compliance Philosophy 2017 ODA Seminar

Compliance Philosophy “The Compliance Philosophy is the latest step in the evolution of how we work with those we regulate. It focuses on the most fundamental goal: find problems in the National Airspace System before they result in an incident or accident, use the most appropriate tools to fix those problems, and monitor the situation to ensure that they stay fixed.” FAA Administrator Michael Huerta



Compliance Philosophy Success For the compliance philosophy to be successful the aviation community should: • Have an Open and Transparent Exchange of

Information with the FAA • Disclose Mistakes without Fear of Punishment • Identify and Acknowledge the Problem • Learn from the Mistake • Implement Fixes that Prevent a Reoccurrence



• Promotes the highest level of safety and compliance with regulatory standards.

• Requires using the most effective means to return a regulated entity to full compliance.

• Promotes an open, problem-solving approach to allow safety problems to be understood through the proactive exchange of information.

• Allows for the use of a less stringent means to gain compliance, when an entity is willing and able to take corrective action.

• Identifies that intentional or reckless noncompliances pose the highest risk to safe operation, and require strong enforcement.

Compliance Philosophy Overview



FAA Compliance Philosophy

FAA Order 8000.373 Establishes the framework and reinforces the discretion that public law and agency policy already provide for FAA program offices to take the most appropriate action to resolve safety issues in the NAS.

FAA Compliance and

Enforcement Program FAA Order 2150.3 Manages general guidance, as well as Enforcement Action (administrative and legal) guidance.

AIR/AFS Compliance and Enforcement Processes

Decision process for determining the appropriate action. - AIR: Business Process AIR-002-035. - AFS: Order 8900.1 Vol. 14; N 8900.325; N 8900.343. - ODA: Addressed initially by the OMT lead’s service offices guidance listed above.

FAA Policy Overview



New Policy and Procedures • Compliance and Enforcement Action decisions are focused

on observable behavior and the facts and circumstances of each case: - Does the entity consistently perform in a positive manner toward

regulatory requirements? - Does the entity understand or recognize its role in the

noncompliance? - Does the entity cooperate with FAA personnel to achieve

compliance? - Does the entity take the necessary actions to come into and maintain

compliance? - Are there repeated failures to take corrective actions or repeated

deviations? - Is the entity noncompliant in more than one area? Does it involve

multiple area/functions?



Additional Considerations

• The regulated entity must be “willing.” – Acknowledges responsibility for the deviation – Shares Information to help determine cause of the deviation – Promptly Implements or agrees to implement Corrective

Action

• The regulated entity must be “able.” – Possess the time & resources to correct the deviation – Has the ability to develop thorough and effective corrective

action – Has access to data, equipment, facilities, etc. to comply with

regulatory requirements and appropriately manage risk



Legal – 2150.3 Used to address noncompliances which may be intentional or reckless, and/or where compliance could not be achieved through administrative means.

Administrative – 2150.3 Used when a compliance action is not sufficient gain compliance, but the noncompliance does not warrant legal action.

Compliance – LOB Policy Used as the first means to gain compliance when a regulated entity is willing and able to take corrective action and legal action is not warranted (e.g., not intentional or reckless).

Used to promote regulated entities to proactively self-identify, disclose to the FAA, and correct noncompliances found.

Voluntary Disclosure Reporting Program

We encourage, support and promote performance, responsibility and accountability to obtain a safety minded organization. Allowing entities to resolve, events involving safety deviations /minor violations internally, within the context of their approved SMS.

We use regulatory tools such as enforcement, to sustain downward pressure to obtain compliance and discourage noncompliance.

How it fits together



What is the Voluntary Disclosure Reporting Program (VDRP)

• Used to allow Regulated Entities (PAH/DAH/ODA) tovoluntarily disclose noncompliances to the FAAwithout fear of punishment.

• Encourages entities to be proactive in identifying,disclosing, and correcting noncompliances.

• Ensures transparency and data sharing with theagency.

• Supports the Compliance Philosophy by promotingusing a non-enforcement means when an entity iswilling and able to correct noncompliances.



Changes to VDRP-Issuance of AIR AC 00-68 • AC 00-68 adopts the principles of the Compliance

Philosophy by creating a process that is separate from the Enforcement process.

• Creates an AIR specific means to disclose noncompliances based on risk. Introduces two methods to disclose, informally and formally.

• Includes the ability for not only PAHs, but ODAs and DAHs to disclosure regulatory noncompliances. – Now includes the ability to disclose issues identified

under Part 21, 26, 45, and 183.



Processing Voluntary Disclosures Informal Disclosures Formal Disclosures

• Used for non-systemic, less critical or easy to fix noncompliances.

• Streamlines the process by allowing for multiple noncompliances and corrective actions to be submitted at a single time.

• Requires an agreement place between the FAA and the regulated entity to establish timeframe, method, types of noncompliances disclosed.

• The entity is responsible for including a causal analysis and corrective action for each noncompliance disclosed.

• The FAA is responsible for conducting a sample verification of the noncompliances disclosed.

• Used for critical/ systemic and safety related noncompliances.

• Each individual noncompliance must be disclosed within 24 hours of the noncompliance being found.

• Follow 6 stage process that requires the entity to create a corrective action plan.

• Entity will submit the corrective action plan to the FAA to accept and verify corrective action.



Compliance Action • A new term to describe the FAA’s collection of non-

enforcement methods to correct unintentional deviations that arise from factors such as flawed system and procedures, simple mistakes, lack of understanding, or diminished skills.

• When an entity is willing and able to correct the issue. The FAA will utilize the following to request corrective action: – Verbal Counseling – Written request for improvements to systems, procedures, and

training programs.

• A Compliance Action is not an Adjudication nor does it constitute a finding of Violation.



Processing Compliance Actions Informal Compliance Actions Formal Compliance Actions • Informal Compliance Action can be used

if one or more of the following is true- Noncompliance is not systemic in

nature; Compliance can be achieved with

relative ease; Noncompliance was to an internal

procedure. • FAA notification can be verbal or written.

• The entity is responsible for providing a causal analysis and corrective action for each noncompliance.

• The FAA is responsible for tracking the action and verification of the corrective action.

• Formal Compliance Action is used- If the noncompliance does not meet

any one of the Informal Action criteria; or

For any safety concern.

• FAA notification will be in writing.

• The entity is responsible for providing a causal analysis and detailed corrective action plan for the noncompliance(s).

• The FAA is responsible for tracking the action, accepting the corrective action plan, and verification of the corrective action(s).



Not Eligible for Compliance Action

• Intentional or Reckless Deviations • Unwilling or Unable to Comply • Failure to Complete Corrective Action • Violations Involving Law Enforcement • Matters Involving:

– Certain matters of Competence or Lack of Qualifications to Hold a Certificate

– Unacceptable Risk to Safety



Administrative Actions • Should be used and processed in accordance with Order

2150.3, when an entity is unwilling or unable to gain compliance, or compliance was not achieved via compliance action

• Processing Administrative Actions Issue a letter of investigation (LOI). Require the regulated entity to complete a root cause analysis and

submit a corrective action plan (CAP). Issue letter of correction (LOC) to accept the CAP or close the case if

corrective action has been verified. Verify corrective action was implemented and is effective. Close action with a letter acknowledging completed corrective action

(LACCA).



Legal Actions • Processed in accordance with Order 2150.3, when legal action

is warranted, or when compliance could not be achieved by administrative means.

• Processing Legal Actions- Issue a letter of investigation (LOI), notifying the regulated entity of the

noncompliance. Create Statement of Case (section B). Recommended Sanction Collect evidence as items of proof (section C). Work with and assist regional counsel to issue sanction.



Questions

18Federal Aviation Administration A Systems Approach to Oversight,


Points of Contact For immediate questions or concerns contact your local Organization Management Team (OMT) Lead. For any questions regarding policy or applicability please contact: • Hillary Heintz, AIR Compliance and Enforcement

Program Manager, AIR-150, [email protected] • Christopher MacWhorter, AFS Compliance and

Enforcement Focal, AFS-230, [email protected]

Points of Contact For immediate questions or concerns contact your local Organization Management Team (OMT) Lead.

For any questions regarding policy or applicability please contact: • Hillary Heintz, AIR Compliance and Enforcement

Program Manager, AIR-150, [email protected]

• Christopher MacWhorter, AFS Compliance andEnforcement Focal, AFS-230,[email protected]

18Federal Aviation Administration A Systems Approach to Oversight,


mailto:[email protected]:[email protected]

Presented to:

By:

Date:

Federal Aviation Administration Continuous

Improvement

2017 ODA Seminar>

Sarah Thatcher, AIR-160

June 15, 2017

Presented to: 2017 ODA Seminar By Sarah Thatcher, AIR 160 Date June 15, 2017



Continuous Improvement 2017 ODA Seminar 2

• Continuous Improvement – Internal Monitoring – Self Audits – Notification & Reporting – Corrective Actions

Overview




• As part of continuous improvement, the ODA holder is expected to identify and be proactive in correcting system deficiencies and noncompliances. – Identify Issues via:

• Internal Monitoring • Self-Audits

– Correct System Deficiencies • Notification & Reporting • Corrective Action

Continuous Improvement




• The ODA holder must provide continued support for approvals or certificates – 14 CFR §§ 183.63 and 183.65.

• ODA holder must comply with all existing applicable reporting requirements in the FAA regulations – 14 CFR §§ 21.3

Internal Monitoring




• Required Annually to Assess: – Personnel

• Review of individual ODA unit members' work for accuracy • Evaluation of each ODA unit member using the processes

and criteria contained in FAA Order 8100.8 or FAA Order 8900.1

– Procedures • Evaluation of the procedures used to perform all authorized

functions and the other requirements of the authorization

– Compliance with Procedures • Evaluation of whether the ODA holder complies with its

procedures manual

Self Audits




Notifications & Reporting

• 24 Hours – Might result in an unsafe

condition

• 72 Hours – Requires corrective action. – Does not meet the

airworthiness standards. – Is an error made when

issuing an operational approval.

– Does not meet applicable operational certification requirements

• Service Difficulty Monitoring – For any approvals, authorizations, certificates issued or

acceptance of instructions for continued airworthiness (ICA) under an ODA, the ODA holder must notify the OMT lead of the following issues within:




• Self-Audit Findings – Personnel:

• Same Notification Process as Service Difficulty Monitoring • Voluntary Disclosure Reporting Program (VDRP), As Applicable

– Procedures: • Self-Audit Report

– Compliance to Procedures: • VDRP

• Self-Audit Report – The records generated as part of the Self-Audit Activities

• Submitted to FAA 14 calendar days after completion of audit

Notifications & Reporting




• The ODA holder must correct any noncompliances or discrepancies identified through: – Internal monitoring, – Self-Audit, – FAA surveillance activities, or – Otherwise directed by the FAA.

Corrective Action




• FAA’s Expectations – Ensure immediate actions have been taken to

preclude the continuation of the noncompliance. – Identify the “cause” of the noncompliance. – Ensure there is a plan to institute system or process

changes if necessary. – Ensure the timeframe to implement corrective action

is adequate – Validate the corrective action is effective

Corrective Action




• Service Difficulty Monitoring & Applicable Safety Findings from the Self-Audit – Within 30 Calendar Days from Notification

• Determine the cause of the condition • Determine whether the problem is systemic or isolated • Review the procedures that led to the approval and

determine if the procedures are adequate and if qualified ODA unit members performed them.

• Develop and propose corrective action – Implement the agreed upon Corrective Action – Validate the Corrective Action resolves the finding – Request FAA Verification of Corrective Action

Corrective Actions - ODA Tasks




• Self-Audit Findings disclosed via VDRP – Determine Cause of the Noncompliance – Submit Corrective Action Plan – Implement Corrective Action(s) – Validate the Corrective Action resolves the

Noncompliance and prevents recurrence.






• Compliance Actions – Informal

• Determine the cause of the condition

• Correct the condition • Validate Corrective Action

resolves the condition • Request FAA Verification

– Formal • Determine the cause of the

condition • Develop and propose

corrective action plan & receive agreement from FAA

• Correct the condition • Validate Corrective Action

resolves the condition • Request FAA Verification

• Enforcement Actions – Respond to the Letter of

Investigation (LOI) within the designated timeframe - typically 10 days.

• Determine the root cause of the condition

• Develop and propose corrective action plan (CAP)

– Receive agreement from FAA on the CAP

– Correct the condition – Validate Corrective Action

resolves the condition – Request FAA Verification

FAA Oversight Findings




• Review and Agree Upon Corrective Action Plans – Service Difficulty Findings – Compliance Actions – Enforcement Actions

• Conduct Investigations – Enforcement Actions

• Verify Corrective Actions – Service Difficulty Findings – Compliance Actions – Enforcement Actions

• Track Progress & Closure of Corrective Actions – Service Difficulty Findings – Compliance Actions – Enforcement Actions

Corrective Actions – FAA Tasks




• For more information, questions and comments, please contact: – Sarah Thatcher, AIR-160

• [email protected] • (817) 222-5285

Contact

2071 ODA SeminarIndustry daySarah Thatcher, AIR 160 Jun

>

Federal Aviation Administration 8100.15 Revision C

A New Approach to ODA Oversight

Presented to:

By:

Date:

e 15, 2017 2017 ODA Seminar – Industry Day

Sarah Thatcher, AIR-160

June 15, 2017

–

Overview

• Congressional Directive • Background • Revision C to 8100.15 • Rev. C Schedule


A Systems Approach to Oversight, Compliance and Continuous Improvement 2

8100.15 Revision C 2017 ODA Seminar Chicago, IL

–

Congressional Directive

• Report from Aircraft Certification Process Review and Reform ARC: – The ODA rulemaking preamble discusses ... expanding

organizational delegation, which shifts FAA oversight from a detailed product approach to a systems or process approach.

– FAA and company personnel have not shifted to an organizational approach.

– FAA oversight should be adjusted to recognize the maturity and actual performance of …

– The ARC believes the greatest increase in efficiency can be achieved with procedures that require a systems approach to certification, such as CDO and FAA risk-based oversight.




–

Background

• Current annual supervision requirements in Chapter 5 of 8100.15 are confusing.

• Want to have more flexibility in meetingoversight requirements based on riskdetermined from: – ODA performance – History

• There has been a long-term effort toimprove the requirements in Chapter 6 and Appendix C, for the DOIP




–

Revision C to 8100.15

• Order Structure • Changes Affecting the ODA Holder • FAA Roles and Responsibilities • Appendix C: Surveillance Criteria




–

Order Structure

• Chapter 1 – Generic Order Information • Chapter 2 – ODA Program Overview • Chapter 3 – ODA Applicant & ODA Holder

Responsibilities • Chapter 4 – FAA Roles and Responsibilities • Chapter 5 – ODA Types, Authorized Functions

and Program Requirements




–

Order Structure

• Chapter 3 – ODA Applicant & ODA Holder Responsibilities – Section 1 – Qualifications and Eligibility – Section 2 – Procedures Manual Content – Section 3 – Application, Selection, & Appointment – Section 4 – ODA Holder Responsibilities and

Continued Eligibility – Section 5 – Continuous Improvement




–

Order Structure

• Chapter 4 – FAA Roles and Responsibilities – Section 1 – Application, Selection, & Appointment – Section 2 – Organization Management – Section 3 – Organization Surveillance – Section 4 – Organization Reauthorizations,

Suspensions, and Terminations




–

Changes Affecting the ODA Holder • Internal Audit Program • Corrective Action • ICA Function Code & Processes • Unit Member Selection • Training • Aging Airplane Inspections • Reporting to the FAA




–

Changes Affecting the ODA Holder Internal Audit Program

• Defined New Requirements and Procedures Manual content for the Internal Audit Program. – Evaluations and Criteria – Audit Staff – Scheduling and Planning Audits – Documentation – Reporting




–

Changes Affecting the ODA Holder Corrective Action

• Defined New Requirements and Procedures Manual content for the Corrective Action System. – Cause of Condition Determination – Corrective Action Plans – Corrective Action Implementation – Corrective Action Validation – Corrective Action Reporting




–

Changes Affecting the ODA Holder Corrective Action

• ODA Identified Issue • FAA Identified Issue– ODA Holder reports to – FAA Notifies ODA

FAA via Holder• Internal Audit Report – ODA Holder Corrects• Unsafe Condition the Issue using the

Reporting Process Corrective Action• VDRP Procedures

– ODA Holder Corrects • Including Verificationthe Issue using the and Reporting

ProcessesCorrective ActionProcedures – FAA Verifies

Implemented CorrectiveAction




–

Changes Affecting the ODA Holder ICA Function Code

• Redefined the ICA Function Code (8180/11180/13180) – Perform Review and Provide Concurrence of

Acceptance of ICA. • Defined Qualification requirements for UMs

who will perform this Authorized Function • New procedures are defined for the

redefined ICA function code




–

Changes Affecting the ODA Holder UM Selections & Training

UM Selection Training • Updated Requirements

and Procedures Manualcontent for Unit MemberSelection.– Applicable to both new unit

members and existingdesignees.

• Updated Requirements forEquivalent Training– Manufacturing Unit Member

Training Only




–

Changes Affecting the ODA Holder Aging Airplane Inspections & Reporting

• New Requirements andProcedures Manualcontent for AgingAirplane Inspections.– Ties ODA requirements to

aging airplane inspectionrequirements in 8900.1.

• Internal Audit Report– New for All ODA Types

• Corrective Action Report– New for All ODA Types

• Design Change ActivityReports– Added STC ODA holders

• Manufacturing Activity Report– Updated the Format of the Report

in Appendix A• No Changes to these Reports

– Air Operator ODA Activity

Aging Airplane Inspections Reporting




–

FAA Roles and Responsibilities

• Organization Management• Organization Surveillance

Action• Required FAA Involvement in Corrective




–

FAA Roles and Responsibilities Organization Management • These are activities where an OMT is

actively involved– Guide and interact with the ODA holder– Ensure manual procedures are reviewed and approved,– Confirm appropriate unit members are being proposed

and added to the ODA unit, and– Effectively manage FAA involvement in ODA Programs.– Monitor incoming work activity reports, internal audit

results, and corrective actions.• Performing organization management

enables identification of wheresurveillance may be necessary.




–

FAA Roles and Responsibilities Organization Surveillance

• Systems Approach, based on:– Compliance with approved procedures– The organization’s performance when carrying out

authorized functions• Two Types of Surveillance Activities

– System Compliance Surveillance Activity• An audit of the ODA holder’s compliance to manual

procedures and processes using the criteria in FAA Order8100.15, Appendix C, Section 2.0.

– Authorized Function Performance Surveillance Activity• A performance assessment of the ODA holder’s use of their

authorized functions using the criteria in FAA Order 8100.15,Appendix C, Section 3.0.




–


• AVS Risk Based Decision Making Process: ODA Oversight – Process which is Internal to the FAA – Determines the Surveillance Window for the ODA Holder – Defines the minimum number of surveillance activities

that the OMT completes within that window.




–


• Communicating Surveillance Results – The OMT will process all noncompliances and all

unsatisfactory performances in accordance with the applicable compliance or enforcement procedures.




–

FAA Roles and Responsibilities Organization Surveillance Additional FAA Involvement in Corrective Actions

• Potential Unsafe Condition • Potential Unsafe Operator – Any noncompliance to an – If an ODA unit approval or

Airworthiness Standard certificate issuance results in a – OMT Lead will notify ODA potentially unsafe operator or

holder immediately an operator not meeting certification standards – OMT must investigate using

FAA Order 8110.107, MSAD – OMT Lead will notify ODAholder immediately

– Must take certificate action in accordance with FAA Order 2150.3

The ODA Holder is responsible for correcting the noncompliance or unsatisfactory performance which led to the above determinations




–

Appendix C: Surveillance Criteria

• (3) Separate Sections with Different Evaluation Items – Procedures Manual Evaluation – System Compliance Audit – Authorized Function Performance Assessment




–

Appendix C: Surveillance Criteria Procedures Manual Evaluation

• These items help determine if the procedures in the manual meet the requirements of the regulation and order.

• Evaluation Items have a direct link to 14 CFR §183.53




–

Appendix C: Surveillance Criteria System Compliance Audit

• Evaluating the ODA Holder’s compliance to their 14 CFR 183 regulatory requirements and their FAA Order 8100.15 policyobligations

• Evaluation Items have a direct link to one of the following regulations: – 183.53 – 183.57 – 183.63 – 183.65




–

f cus 0

Qua it~

Appendix C: Surveillance Criteria Authorized Function Performance Assessment

• This is an assessment of the ODA Unit’s decision making as a designee. – Evaluation Items will be bucketed by the definitions

of the functions, regardless of ODA type. – Evaluation Items are defined by what the FAA’s

performance expectation of an individual function.




–

Rev. C Schedule

• Pilot Program – Exercise Order Changes and Risk Model – 3 Participants have been selected from a list of 15 volunteers. – Deviation Memos Issued and Kick-Off Meetings: March 2017 – Pilot Program Wrap-Up: September 2017

• Rev. C coordination is expected to begin Q1 ofFY2018 – After assessing initial pilot program feedback – Concurrent Internal/public comment periods

• Issue 8100.15 Rev. C by the end of FY2018 – AIR-160 expects to conduct outreach with formal training – Allow 1-Year for ODA Procedures Manuals to be Updated




–

Questions




–

Contact

• For more information, questions and comments, please contact: – Sarah Thatcher, AIR-160

• [email protected] • (817) 222-5285




mailto:[email protected]

2017 ODA SeminarRalph Meyer Air-160

FFededereralal AAvviiatatiioonn AAdmdminisinisttrraattionion Order 8100.15B

Change 2

2017 ODA Seminar Ralph Meyer, AIR-160

Implementation

• Issued 9/6/16 • Effective Oct 7, 2016 • Must incorporate any needed manual

revisions by April 8 2017

2Federal Aviation Administration Order 8100.15 B Change 2 2017 ODA Seminar

A Systems Approach to Oversight,

Compliance and Continuous Improvement

8100.15B Chg 2

• Eliminates language restricting delegation of noise/emissions

• Allows ODA holder to provide in-house training “equivalent” to ODA seminars – Training program agreed to by AIR-140/AFS-600

• Clarify FAA OMT and “ODA Unit Member training requirements” – Requirements hosted on internet, Google it up.

• Clarifies that part 183 non-compliances may be self-disclosed and processed under VDRP




8100.15B Chg 2 (Cont’d) • Revises corrective action processes to align with

changes to Compliance and Enforcement Program – All discrepancies and violations handled under the same

process – Corrective action processes defined in AIR or AFS compliance

and enforcement policy – Informal means provided to address CA – ODA holder required to investigate/develop CA as required by

OMT – OMT discretion on when to require corrective action

• Formal notification/investigation only required for systemic issues not adequately addressed by “simpler” methods




8100.15B Chg 2 (Cont’d)

• Requires auditing training and on-line OMT courses for OMT members and inspection members – Dec. 2017

• Clarifies that each OMT member must complete a supervision record annually

• Clarifies that each evaluation item must be assessed by all technical disciplines, not all members of OMT

• Revises suspension/termination procedures – Suspension appropriate when specific actions can be taken to

correct performance




8100.15B Chg 2 (Cont’d) •Standardizes TC/STC/PMA language regarding FAA project participation

Discretionary Mandatory • Performance issues • Areas not authorized or

allowed • Insufficient Demonstration of Ability – ELOS provisions – Regulatory changes – Rulemaking, special

conditions – Policy changes – AEG operational suitability, – New/Unique Design features

MMEL, crew training, etc. – New means of compliance • Service Difficulties • Areas critical to safety

– Does not restrict delegation of high-risk rules




8100.15B Chg 2 (Cont’d)

• Provides for recognition of applicant showings on ODA projects-TC/STC – Allowed for activities involving low or medium risk

regulations as determined by risk tool • Have previously obtained approval based on that activity • Previously used means of compliance • Same person makes showing or relies on a documented

process




8100.15B Chg 2 (Cont’d)

• Eliminates most restrictions on prototype alteration locations-TC/STC/PMA – ODA holder must evaluate location – Significant projects per 21.101 must be

accomplished at FAA certificated facility – Others may be conducted at any location

determined appropriate by ODA holder – subject to requirements of state of registry




8100.15B Chg 2 (Cont’d)

• Provides for recognition of applicant showings on ODA projects-TC/STC/PMA – Allowed for activities involving low or medium risk

regulations as determined by risk tool • Have previously obtained approval based on that activity • Previously used means of compliance • Same person makes showing or relies on a documented

process




8100.15B Chg 2 (Cont’d)

• Allows for TC ODA approval of additional AMOCs – AMOCs applicable to a number of products operated

by a single operator – AMOCs in areas other than structures for minor

deviations or alternate service instructions not related to the unsafe condition, for example

• Relocating system hardware • Moving wires to alternate splices




8100.15B Chg 2 (Cont’d)

• Allow STC or PMA projects to be completed without submittal of PNL

• Eliminates use of FAA Form 8130-13 for requesting geographic expansion authority for MRA ODA




8100.15B Chg 2 Changes

• Eliminates restriction on ICA delegation for security-related projects

• Allows for additional STC projects to be completed without submittal of PNL

• Provides for STC ODA reissuance of STCs to correct administrative errors, incorporate name changes or replace lost certificates

• Clarifies that MRA ODA engineering UMs may conduct compliance inspections needed for data approval




Subsequent Policy Changes • Use of FAA Forms

– Deviation Memo, AIR-100-17-160-DM09 – May customize certain internal use forms

• FAA Form 8100-1, Conformity Inspection Record • FAA Form 8110-1, Type Inspection Authorization • FAA Form 8110-31, Type Inspection Report • FAA Form 8110-26, Supplemental Type Inspection Report

– Customize other forms for IT purposes • FAA Form 8100-9, Statement of Compliance with

Airworthiness Standards • FAA Form 8100-11, Statement of Completion • FAA Form 8100-12, Production Limitation Record (PLR)

Report




Questions?




2017 ODA Seminar – FAA and Industry Session June 15, 2017 – Chicago, IL

Agenda

Engineering Session

1:00 – 1:30 Congressional and OIG Activity......................................... Ralph Meyer – AIR-160

1:30 – 2:15 ODA Policy and Activity Update........................................ Ralph Meyer – AIR-160

2:15 – 2:30 Break

2:30 – 3:15 ODA Scorecard Initiative .................................................... Jon Mowery – AIR-160

3:15 – 3:30 Break

3:30 – 4:00 AIR Transformation and Recognition of .......................... Kevin Kendall – AIR-160 Applicant Showing Only

4:00 – 4:30 Questions/Wrap-Up/Exam

FFededereralal AAvviiatatiioonn AAdmdminisinisttrraattionion Congressional and

OIG Activity 2017 ODA Seminar Ralph Meyer, AIR-160

Overview

• Status of ODA-related activities and improvements

• ODA-related draft legislation

2Federal Aviation Administration Congressional and OIG Activity 2017 ODA Seminar



Section 312 ARC Recommendations -Completed

• FAA/GAMA/AIA Action Plan • FAA Audit Training • Delegation Expansion – ICA • Delegation Expansion – Noise • Delegation Expansion – Emissions • Sequencing Improvements




2015 OIG Audit

• ODA staffing and oversight • 2 recommendations on staffing

– Identify needed changes to FAA labor tracking tool to account for ODA

– Utilize the tool to identify office-level staffing shortages

• 7 recommendations on oversight




Oversight Recommendations

• Develop and implement system-based evaluation criteria and risk-based tools to aid ODA team members in targeting their oversight – Addressed by new oversight approach planned for

rev. C-March 2017 – Significant changes to FAA’s ODA oversight

processes and ODA holder self-audit procedures




Oversight Recommendations (Cont’d)

• Clarify guidance to ODA oversight staff on the minimum oversight requirements for each oversight team member – Complete. Memo issued Dec, 2015

• Provide guidance on data that ODA team members should be analyzing on an ongoing basis, enhance its national summary of biennial audit results to include more specificity, and disseminate it to ODA teams to use in planning their oversight – Complete. Memo issued September, 2016




Oversight Recommendations (Cont’d)

• Clarify guidance to engineers and inspectors on actions to take in response to self-audits and develop a process to validate that the audits are being used to identify trends that warrant a need for oversight – Complete. Memo Issued August, 2016

• Provide guidance on the level of sampling required to achieve effective oversight of company personnel performing key aircraft certification functions, and issue sampling guidance to field offices – Complete. Memo Issued August, 2016




Oversight Recommendations (Cont’d) • Develop agreements and a process for sharing

resources to assure that ODA personnel performing certification and inspection work at supplier and company facilities receive adequate oversight – Complete. Policy Memo issued March 22, 2016, Initial Agreements

established July, 2016

• Require annual assessments of audit training provided to ODA oversight personnel for effectiveness and report the results of the assessment on an annual basis to the Aircraft Certification Management Team – On going. Initial report issued Feb, 2017




Draft FAA Reauthorization

• Congress working on FAA reauthorization – S.2658 passed by Senate April 19, 2016 authorizes

through Sept 2017

• ODA program impacted proposed reauthorization language




FAA Reauthorization-ODA Impacts

• ODA formally recognized in statute • Title 49 USC § 44736. Organization

designation authorizations • Requires FAA to

– Require a procedures manual – Delegate fully to the ODA holder each of the

functions specified in the manual – Conduct oversight activities




FAA Reauthorization-ODA Impacts (Cont’d)

• Requires ODA holders to – Perform functions in accordance with the manual – Make the manual available to the ODA unit – Cooperate fully with FAA oversight





• With respect to existing ODA holders, the FAA shall – In an expeditious matter, consider revisions to the ODA

holder’s procedures manual – Delegate fully to the ODA holder each of the functions specified

in the procedures manual, unless the Administrator determines, after the date of the delegation and as a result of an inspection or other investigation, that the public interest and safety of air commerce requires a limitation with respect to 1 or more of the functions; and

– Conduct oversight activities





• FAA must create a centralized ODA policy office within 120 days – Provide oversight and ensure consistency of FAA audit

functions across the agency – Improve FAA and ODA holder performance and ensure full use

of authorities delegated under the ODA program – Develop a more consistent approach to audit priorities,

procedures, and training – Review a random sample of limitations on delegated

authorities to determine if the limitations are appropriate – Ensure national consistency in the interpretation and

application of the requirements of the ODA program and in the performance of the ODA program





• FAA must convene expert review panel of not more than 20 people within 60 days – ODA holders, manufacturers, safety experts, FAA labor

representatives

• Survey, assess and make recommendations within 180 days – Whether ODA processes function as intended – Best practices and lessons learned by ODA holders and FAA – ODA-related FAA personnel performance incentives – ODA training for FAA and industry – Impact of ODA program on FAA resources and ability to certify

products




Major Impacts

• Significant workload associated with establishing policy office, expert panel and reports

• Reconsider ODA authorities and limitations in light of mandate to fully delegate




Questions?




FFededereralal AAvviiatatiioonn AAdmdminisinisttrraattionion ODA Policy and

Activity Update 2017 ODA Seminar Ralph Meyer, AIR-160

Overview

• Policy updates • Future activities

2Federal Aviation Administration ODA Policy and Activity Update 2017 ODA Seminar



Recently Issued Policy

• Find on the internet at rgl.faa.gov • Examples in handout at end of presentation




http:rgl.faa.gov

Recently Issued Policy

• 3/31/17 Use of FAA Forms – Deviation Memo, AIR-100-17-160-DM09 – May customize certain internal use forms

• FAA Form 8100-1, Conformity Inspection Record • FAA Form 8110-1, Type Inspection Authorization • FAA Form 8110-31, Type Inspection Report • FAA Form 8110-26, Supplemental Type Inspection Report

– Customize other forms for IT purposes • FAA Form 8100-9, Statement of Compliance with Airworthiness

Standards • FAA Form 8100-11, Statement of Completion • FAA Form 8100-12, Production Limitation Record (PLR) Report




Recent ODA Policy

• 3/28/16 – Extension for UMs required to complete Flight Test, Mech Systems, Propulsion/Powerplant Training – UMs have until Sept 2016 to attend the training

• 3/21/16 – EWIS ICA Approval – Creates new function code for approval of EWIS ICA




Recent ODA Policy (Cont’d)

• 12/21/15 - Designee Support of Repairs/Alterations Involving Lithium Batteries – Instructions and limitations for ODA holders

approving repair/alteration data

• 8100.15 – Deviation-ODA Approval of AMOCs – Allows for AMOCs approving multiple products

operated by a single operator





• 8100.15– Deviation-ODA Approval of AMOCs – Allows TC ODA to approve deviations/alternate

service instruction AMOCs in areas other than structures

– Specific allowances provided in procedures manual – Incorporated in 8100.15B Change 2





• 8100.15 – ODA Requirements for prototype installation locations – No longer any “facility” requirement unless

“significant” per 21.101 – ODA holder must assess location – Allows installations at any location determined

appropriate by ODA holder-conformity of install – Subject to regulations of State of Registry or others

responsible for airworthiness





• 9/30/2015-Guidance on use and recognitions of applicant showings on ODA projects




Recent ODA Policy (Cont’d) • 8100.15- PNL Requirements for STC ODA

– May allow STC ODA to issue STCs without submitting PNL

• Must still comply with CPN or other coordination rqmts • Satisfactory performance on projects of similar scope

– PNL still required: • Significant per 21.101 - New AML STC • Items on directorate issues list, unless dispositioned for

reuse on previous issue paper • Equivalent safety provisions, exemption or special condition • Novel or unusual design feature or MOC not previously

used • Affecting AD




Other Initiatives

• DER training program changes – Individual courses to be released as developed – Will be able to pick from a list of eligible courses

• Required core courses based on authority • Other elective courses chosen within discipline

– Yearly or biennial tuition-take as many courses as you like

– Implement in June/July 2017 – All engineering UMs must register in system within

90 days of implementation




Part 21 Rulemaking

• Part 21 changes planned for publication in 2020

• NPRM planned for 2018 – New Requirements for design approval holders – Design Organization Certificates – SMS Requirements for some Certificate Holders – Other part 21 cleanup/revisions




Part 21 Rulemaking-Schedule

• Issue NPRM 2018 • Issue Rule 2020




Questions?




ue Date ,..

05 /08/2017

0 /2.4/2. 017

03/31/2017

03/29/2017

03/06/2.017

03 /06/2.017

02/22./2017

02/22/2. 017 02/1 7/2.017

01 /24/2017

Policy :Numbe1· ,..

PS-ASW-27/2.9-07

AIR.100-17- 160-PM02

AIB.- 100-17-160-DM09

AIR.100-17-130-PM0l

A IR -100-17-140-GM03

AIR-100-17-140-GM04

PS-A IR-2.1 .16-02. Re,;-_ 2.

PS-ANE-33 .75 -01 PS-ASW-2.7 .2.9-14

AIRW0-17-110-G1 Wl

Subject ,..

Pofrcy Statement on Certi:fication of Engine Inlet Barrier Fi ter (IBF) InstaHati:ons .in Rotorcraft Changes to FAA Ord-er 8100.8D Techntcal Re,current Training R,e,quirements for DER.s, Eng ineering ODA Unit memb ers , and Aircraft Certification P·ersonnel \\ho Manage Designe,es Deviation to FAA Order 8100.15B ReC])nirements for u.s,e of FAA Forms Airborne Electronic Hardwar,e and Ci.vi Aircraft / Systems Devdopment Assuranc,e Pro cesses Pian Up cfat,e Il\11FOR!i"\AATION: FAA Order 8120.23A, Certificate Manag,ement of Production Approval Holders :Il:N7FOR!iviATION: ,eLMS Differences Ov,ervie\v Training ass,ociated \,ith the Release of Revision A to FAA Order 8120.23 Establishment of Spec ial Conditions for Aircraft Systems In.formatton Security Protection Gu ~cfance for Safety Analysis, § 3 3 _ 7 5 Flight Data Monitoring Sy.stem Sofu,are and Airborne Ele,ctron.i:c Hard\ur·e Development Assuranc,e LeveI Cancellation of FAA Order 1110 .1 3 3, Certifica ion Proc,e.s.s Study (CPS) Respons,e Aviation Rulemaking Committee

Recently Issued Policy (Cont’d)




/05 /2016 AIR.-1 00- l 6-160-DM21

11/29/2016 AIR.-100-16-110-·PMl 6

11 /1 5/2016 A IR. I 00-16-140-DM20

11/10/2016 A IR.100-16-140-·P1 HS

11/08/2016 AIR.100-16-110-DMl 7

11 /08/2016 AIR.I 00-16-110-DMl 8

11/08/2016 AIR.100-16-110-G_ B 1

10/17/2016 AIR.-100-16-160-PMl 3

L-enm cauon !t'fooess ~mcy ,~ t'~) Kcespons,e Aviation Rulemabng Comm.i.tte,e Dev i.a i.on t,o FAA Order 8000_95 Design e,e Manag,ement Policy, "\oiume 8 Chap er 4 , paragraph 5 _ Clarification: L tissing Requirement from Sample '.fochnica l Stand!ard Order Authorization (TSOA) Letter in Order 815 0_ lC Deviation t,o FAA Order 811O_100B, Spe,cia l AinMorthi.ness :Information BuUe in, for Op ion to Indude No i:fica i.on of Interim Conectiv,e Action for nsafe Condition C arification Regard ing A tem ati.ve M,ethod of Complianoe (Ail me) '.fomplate D ev.iation f.o FAA Order 813 0 _ 3 4 C Am, orthiness Certification of nmanne,d! Aircraft Systems and OptionaH) Piloted Aircraft Dev.ia i.on to FAA Order 8130-34 C, Ai.n., orthiness Gerti:fic ation of nmanned! Aircraft Sy stems and Optionally Piloted Aircraft Clarification of FAA Order 8110-4C, Type Certification, par_ 4 -19_d _, Original Product s,ection_ Limited Designa ed Ai.n.vorthiness Repr,es,entative-Manufactnring (DAR-F) Program for Accrndi.te,d! Distributors





/07/2016

10/06/2016

09/29/201 6

09/21/2016

09/2 lt ... 016

09/13/2016

08/25 /2016

08/25/2016

AfR.- 100-14-13 O~GM2 7

PS-AIR-21 -1601

Arn.-100-16-140-D1 ns

AIB.100- 16-160-PMl 1

A IR.100-2016-AIR- 110-P1 1-10

A]R.100-16-11 O-PM08

AIB.100- 16-160-PM06

AIB.100- 16-160-PM07

Effo-ct of AD S-B Out .insta Uat~on on R\ SM and TCAS n Certification FAA Order 811 O. 2D, Parts Manu:factur,er Approval Procedlure.s - -se of Parts _. fannfacturnr Approval (Pll 1A) :for Minor Modifica ~on Art~cles onProduc·s Dev.ia ion to FAA Order 8120 .23 , Change 3, Certificate Manag,ement of Production Approval Holders Guidanc,e on Data tha Should be Considlernd \Vhen Conducting ODA Ov,ersight Revision ofFigurn A-1 in Appendix A of Order 811 0 .112A, Stand.ardlized Procedurn for 1 • - s a e:,e of]ssue Papers and Devdopment ofEquivat.ent Lev,els of Safot) i?vfomornndums Designated Engin eering Rceprns,enta• iv,e (DER) authorit)• :for Parts Manufachuer Approval (PiMA) critical parts .approval Guidanc,e on Ac ~ons o Takie in Rcespons,e to Organization De.signa· ion Authorization 100DA) Self-Audits Guidanc,e on th,e Lev,el of Sampling Rcequir,ed for Organization De.signa ion Authorization 100DA) Supervision





/09/2016

08/08/2016

07/1 9/2016

0 / 11 /2016

06/30/2016

06/30/2016

06/30/2016

06/2 /2016

AIR-100-16-140-GM22

PS-Al\T}..4-2 5-2 0

AIRl O 0-16-11 O~GJ\.U 0

AIRl 00-16-140-GMl 9

AIRl 00-16-110-DMl 2

AIRl00-16-110--P_ [04

AIRl 00-16-110-PMOS

AIRl 00-16-11 O-DM04

·-· ... r - - . - - ·- -· -

Undue Burden Tr.ainm.g Associated with the Rdea_s,e ofF.4..4 Order 8100.llD .and AC 21-55 High-Energ • '\Vide-. .i\rea Blun ]mp.act for Composite Strndures Su_sp e cted. 1 · - nap proved. Parts Tr.ansi ~on Project ji\fan.agemen Plan Chan2:e Addendum to .~ccomp.an .· · the &evi,e\ii. .and. Coordin.ahon of Dr.aft FAA Order 8120.23A, Certificate _ fanagemen of Produc ion Approval Holders Deviation to FAA Order 813 0.2.1 Regarding Preposi ioned. Prodluds .and .4rt.ide U e of Block 12 on the Authorized. &e1ea_s,e Certificate F.4..4 Form 813 0-3 .Jun ·orthiness . . . . ' . Approval Tag Shipment of Proto ·p e Products .and Arbdes with he Authorizied Rd e.a_s,e Certi:fica e, FAA Form 813 0-3 Ainvorthiness Approval Tag Issuance of the Author.izied Release Certi:fica e . . . . . ., FAA Form 8130-3 Ain:vorthine , Approval Tag .and PAH Issuance of At thor.izied Rd e a_s,e Documen for Export





/24/2016 0 /1 9/2016

05 /1 0/2016

0 /28/2016

0 /22/2016

0 /21/2016

0 /21/2016

0 /1 5/2016

AIR.100-16-110~G~ i 16 AIR.100-16-110-,G H4

AIR.I 00-16-110-DMl 0

AIR.I 00-16-11 O-PM02

PS-ACE-23-·08-Rl

AIR. I 00-16-11 O-PM03

AIR.I 00-16-11 O~GM09

AIR.I 00-16-11 O~GMl 0

AIR. I OO - l 6-l 40-D]vrn9

PAH Tusuance of Authorized Rdeas,e Documents. Revised Fed eral Avia ~on Admm.istration (F A..4) Form 8110-1 T · pe :Inspe,c ion Authoriz-:ation (TLA..) Devia ion to FAA Ord!er 81 · 0.2-A Production Approval :iProoe,dure Cfarifica ~on ofConformi · Insp e,c ion Re,quir,ements for New Surplus Articles on the Authoriz1ed Rdeas,e Certi:fica e, FAA Form 8130-3 , A.in, ortbiness Approval Tog R,epfaoement of vacuum Driv,en Attitud e ]indicators in 1 CFR Part 23/CAR 3 .i%.irpfanes Previously Approv,e,d Parts Manufachuer Approval (PJ!\[A) Data

,e\v F,e,dl1eral Aviation Admm.istration (F.4..4) Form 8110-31 T ·pe Inspe,ction Report (TIB.) Revis,ed FAA Form 8110-2.6 , Suppfomenta.l T ·pe linspedion &eport (S .. IB.) Devia ~on to Order 8 20.23 Change 3 Certifica e Ma11agement of :iProduc ion Approval HoMer (PAHs ), for office part~cipa ing rn pha51ed impfomenta ion of Order 812 0. 2 3 &evision A

06





/08/2016

04/0 /2016

03 /31/2016

03 /28/2016

03 /22/2016

PS-ANJvI-2 5 -19

AIB.100-16-140-D_ W6

PS-A IB.-21.8-1602

Arn.100-16-160-D.l ms

AIRl 00-16-160-GM06

implementation of Order 812 0. 2 3 &evision A Flight,cre1.v Proce,cl!ures for Addrnss.ing Firn Hazards .in the Flight Deck Deviation t,o Order 812 0. 2 3 Certificate Manag,ement of Production Approval Holders for \\i.a.iv,er ofQuabt) System Audit Quali:fication Crndentia[s to fombers of the International Suppber ( ;:,ontrol Ambt Team Approv .a [ of . -on-Requir,ed Sa:fet), Enhancing Equipment (NORSEE) Deviation t,o FAA Order 810 0. 8D: Ext,ension for fuctividu.a[s &equir,ed t,o Complete Flight J:est, Mechanical S ·stems, .and Propulsion/Powerpiant R,ecurr,ent J:ed1mca.l Training Agreements. for Sharing &esource eecl!ed for Org.an.iza ion. Designation Authorization ~ODA) Supervision.

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2017 ODA Seminar

Chicago, IL

June 15, 2017

ODA Scorecard Initiative 2017 ODA seminar Chicago, IL June 15, 2017

2 Federal Aviation Administration

ODA Scorecard Initiative

ODA Seminar – Chicago, IL, June 15, 2017



Overview

• ODA Scorecard Philosophy • Scorecard Objectives • Overview & Plan • Scorecard in Detail






ODA Scorecard Philosophy • Partner with our applicants so our mutual performance

consistently meets each others expectations and work toward Company/ODA self management

• Focus FAA involvement in projects that have areas inside the ODA authorization that are high risk or are inherently governmental. – Work toward reducing FAA involvement through training and demonstrated

company ODA performance

• Foster a working relationship that meets or exceeds expectations or demonstrates a trend towards improvement – If not green-green identify challenge areas in the Scorecard

• Utilize Scorecard results to identify areas for improvement and increased delegation – Deliberate FAA/Applicant collaborative actions plans should be developed to

enable tracking improvements






Why an ODA Scorecard?

• Certification Reform Mandate by Congress – FAA has implemented the reforms identified by the

FAA Modernization and Reform Act of 2012 – Industry and Congress have indicated that the

benefits have yet to be realized • Desire to optimize ODA

– Improve consistent approach across the service – Better utilization of resources – More useful metrics






ODA Scorecard Initiative • Measure mutual performance • Opportunity to engage in productive dialogue • Will help distinguish between local difficulties and national

issues • Scorecard intended to facilitate ODA/OMT working together

and plan for the future • Initial focus is on TC and STC ODA types • Recognize that each ODA/OMT is unique

Purpose: Improve the usefulness of ODA delegation

from a joint FAA and Industry perspective. A tool to help facilitate Certification Reform






Objectives of ODA Scorecard • National/Executive-Level Use

– Enhances dialogue with industry groups and Congress

• Supports productive national discussion about efficiency and effectiveness of the ODA system

• Enables use of data to point to areas where national policy improvements may be needed

• Helps differentiate between national and local issues

– Enhance dialogue between FAA offices • ACO Manager review and sharing of best practices • Address national issues for continuous improvement • Training, policy changes, Standards Staff support, etc.






Objectives of ODA Scorecard • Local/Office Manager-Level Use

– Enables dialogue with local ODA holders • Supports productive local discussion about the FAA’s

management of program activity and ODA holder compliance

• Enables the use of data to point to areas where performance improvements of the FAA and Company/ODAs may be needed

– Scorecard provides objective evidence • Measures performance of both the FAA and Industry

– Encourages open dialogue and positive relationship building by capturing data important to both






Objectives of ODA Scorecard • Local performance improvements (FAA or

Company) – Typically indicated by yellow or red ratings – Should be viewed as an opportunity to improve the

FAA’s & Company’s ODA program – Use the scorecard data and dialogue to identify

contributing factors. For example: • Policy and Guidance • Internal Procedures • Personnel Issues




A Sy