With the changes last year to the FAA’s compliance philosophy, listening to frontline workers when they raise safety concerns has become even more critical for aviation businesses. In terms of FAA enforcement, the new philosophy makes clear that aviation entities that find and correct their own problems will fare much better than entities that don’t when it comes to FAA legal enforcement. Legal enforcement generally involves civil penalties or punitive certificate suspensions, but can also include cease-and-desist and emergency remedial orders. The policy, announced in June last year, states that when deviations from regulatory standards occur, “the FAA’s goal is to use the most effective means to return an individual or entity that holds an FAA certificate, approval, authorization, permit or license to full compliance and prevent recurrence.”
I highlighted the most effective means because here lies the crux of the new philosophy. [To be fair, the philosophy isn’t totally new. Elements of it can be found in the agency’s Voluntary Disclosure Program for air carriers, repair stations and manufacturers and the Aviation Safety Action Programs for some air carrier and repair station employees.] If an aviation entity or its workers violate the FARs for reasons such as “flawed procedures, simple mistakes, lack of understanding or diminished skills,” the FAA is going to give you an enforcement pass if you have a program to do “root cause analysis and training, education or other appropriate improvements to procedures or training programs…which are documented and verified to ensure effectiveness.” Basically, this means finding your own problems, figuring out why they happened, fixing them and then making sure that your fix worked. Of course this enforcement philosophy ties in with the FAA’s emphasis on using safety management systems to do exactly this: identify hazards, assess risks and ensure that mitigation measures are effective. SMS programs have been adopted by operators large and small, although they were only recently mandated for Part 121 airlines.
With more than 40 years experience in the aviation industry, The Honorable John Goglia, was the first and only Airframe and Powerplant mechanic to receive a presidential appointment to the National Transportation Safety Board (NTSB). He served from August 1995 to June 2004.
As a Board Member, Mr. Goglia distinguished himself in numerous areas of transportation safety. In particular, he was instrumental in raising awareness of airport safety issues, including the importance of airport crash fire and rescue operations and the dangers of wildlife at airports. He played a key role in focusing international attention on the increasing significance of aircraft maintenance in aviation accidents. He pressed, successfully, for greater integration of civilian and military safety information, becoming a featured speaker at national aviation symposiums attended by military leaders and major defense contractors. He is a leading proponent of airplane child safety seats.
Prior to becoming a Board Member, Mr. Goglia held numerous positions in the airline industry. He started as a mechanic for United Airlines and eventually joined Allegheny, which became USAir. Additionally, he was involved for more than 20 years as a union flight safety representative on accident investigation teams. There, he developed a safety program for his union, the International Association of Machinists, and was its representative for NTSB investigations. For twelve years, he operated his own aircraft service company.
Numerous prestigious groups have recognized Mr. Goglia’s contributions to aviation safety. Aviation Week & Space Technology awarded him a coveted 2004 Laurel for his outstanding service as an NTSB Board member. The Society of Automotive Engineers presented him with the Aerospace Chair Award for outstanding leadership in 2003 and the Marvin Whitlock Award for outstanding management accomplishment in 2002.
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