Boeing fined $1.25m for ODA violations. Justified?
Full disclosure; at moment of writing this is a fine proposal, not an imposed fine.
What are ODA violations?
What is ODA?
ODA stands for Organisation Designation Authorisation.
An ODA is a person authorised by the FAA to approve certain product designs or part of designs, tests or other certification activities WITHIN an organisation that produces Aviation related products.
The delegation of responsibility by the FAA to the prospective ODA is based on credentials and demonstrated competence.
FAA Order 8100.15B describes the processes and procedures of ODA programs.
The order describes te processes of selection, approval and organisation and individual eligibility of ODA's.
Different types of organisation can apply for an ODA. There are TC (type certificate) holders, STC (Supplemental Type certificate) holders, but also PMA (Product Manufacturing Authorisation) holders that can apply for assignment of one or more ODA's in their organisation as delegate for the FAA.
The order describes the eight different ODA programs:
Type Certification (TC) ODA
Production Certification (PC) ODA
Supplemental Type Certification (STC) ODA
Technical Standard (TSO) ODA
Major Repair, Alteration and Airworthiness (MRA) ODA
Parts Manufacturer Approval (PMA) ODA
Airman Knowledge Testing (AKT) ODA
Air Operator (AO) ODA
In below extract of FAA Order you can find the matrix of functions for the above categories of ODA's
The ODA's are managed by the OMT (Organisation Management Team) of FAA personnel, this includes oversight of individual ODA's.
The order states:
"c. Assessing Performance.
(1) Review of the Organization’s Work. As determined necessary, the OMT must review the ODA unit’s work and data for accuracy and completeness. The OMT will take into consideration the amount of the review on the organization’s experience, the safety impact of the work being reviewed, the quality of work performed on previous projects, and the ODA unit member performing the function. Previous service difficulties or errors should be considered when deciding the amount of review needed. The OMT must review samples of completed project records, such as airworthiness, conformity, compliance, ICA and type design data. For operational approvals, the OMT must review samples of completed certification files, including all associated records required for certification. If the OMT requires personal meetings or inspections with the ODA holder or unit, they should coordinate them through the ODA administrator
(2) Review of Self-Audits. The OMT must review the self-audit reports generated by the ODA holder for possible trends and items requiring corrective action. The OMT lead must coordinate the review with the other OMT members as appropriate, and coordinate corrective actions in accordance with paragraph 5-6 of this order if necessary. The OMT must ensure that self-audits address all of the ODA holder’s authorized functions, and that the ODA holder performs them annually.
(3) Verifying compliance with procedures. The OMT must verify that the authorization holder complies with the approved procedures manual and referenced internal processes. "
As can be concluded from the above, the oversight is rather high level as opposed to technical detail.
A company like Boeing has many ODA's employed to support type certification work, but also fleet support work.
Give the complexity and technically advanced activities of type certification, ODA'a must reasonably be immersed in the technical details and design and test protocols for type certification and production. Realistically, this is simply a requierement for effective and efficient progress in modern commercial large aircraft production.
However, the recent fire storm that followed the two fatal accidents with 737-8 (MAX) aircraft revealed that certain certification steps were breached or not satisfactorily complied with.
The public and political scrutiny and potential massive legal fall out made that people went public with their initial concerns and a number of (ex) Boeing employees started publicly expressing very outspoken opinions. Obviously this raised grave concerns and both FAA and Boeing were forced provide full disclosure and the focus shifted to the integrity of the ODA programs versus commercial management pressure to bring a product to market in a certain timeframe.
The allegations were that certain management units within the company excerted undue pressure on ODA's and a number of ODA's reported to managers that were not in the ODA program.
This indicated changes in organisational discipline and certification accountability.
Boeing claims, it has corrected the reported shortcomings in the ODA program.
Meanwhile the pendulum of public opinion is swinging to the other side and there are claims that all certification and approval activities should be carried out by FAA itself and not by individuals employed by the organisation.
Either way; the validity of approvals and certification process steps are highly dependent on the culture of integrity in the organisation and the persons approving. With the complexity of activities there must be deeply technical knowledge with the individuals approving, irrespective of them being employed by the organisation itself or directly by the certifying agency.
It must be recognised that the person approving can not stop or nudge a conformity approval without support of the organisation. Hence the input of management in the certification process is essential to its integrity.
Let's remember the Japanese seat manufacturer Koito Industries that presented falsified test data to get their products approved. As this severe breach of integrity came to light in 2010, all Koito products were banned by Airworthiness Directives and caused a logistical wave in the commercial operators community with very high costs involved.
Koito Industries had been, to that point in time, a well respected player in the aircraft seat manufacturing community and had been producing aircraft seats since 1959. After the scandal, both Boeing and Airbus banned Koito Industries seats from their aircraft.
As spectator is is difficult to judge whether or not the fines to Boeing, proposed by FAA are justified. However it is in the interest of all parties in aviation to take the ODA program seriously and keep its integrity intact and create or maintain an organisational culture that supports the ODA program as the consequences of breaches can be grave
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