4
Issues to Be Addressed in Staffing Models

The committee identified the unique challenges and issues that must be addressed by the staffing models for aviation safety inspectors (ASIs) by reviewing documents and gathering the perspectives of a wide array of stakeholders—including ASIs themselves. From this background material, we identified factors affecting demand for ASIs that result from the unique aspects of the Federal Aviation Administration (FAA) as an organization and from the external aviation environment. In this chapter we first briefly review the information we obtained from stakeholders and ASIs, and then we provide our assessment of major factors that should be considered when developing a model designed to guide the ASI staffing process. Many of the factors discussed in this chapter involve FAA human resource issues rather than those typically regarded as manpower issues, to which this study was primarily directed. As explained in Chapter 1, despite the directed emphasis on manpower planning, we think it essential that the human resource deficiencies be addressed in order that an intelligent manpower modeling effort can be undertaken.

Issues Raised by Stakeholders

The committee heard from representatives of numerous groups that are directly affected by the ASI workforce. (See Chapter 1 for a list of stakeholder representatives who addressed the committee.) The committee’s sampling from these stakeholder groups revealed several points of agreement on perceived problems, along with some areas of



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Staffing Standards for Aviation Safety Inspectors 4 Issues to Be Addressed in Staffing Models The committee identified the unique challenges and issues that must be addressed by the staffing models for aviation safety inspectors (ASIs) by reviewing documents and gathering the perspectives of a wide array of stakeholders—including ASIs themselves. From this background material, we identified factors affecting demand for ASIs that result from the unique aspects of the Federal Aviation Administration (FAA) as an organization and from the external aviation environment. In this chapter we first briefly review the information we obtained from stakeholders and ASIs, and then we provide our assessment of major factors that should be considered when developing a model designed to guide the ASI staffing process. Many of the factors discussed in this chapter involve FAA human resource issues rather than those typically regarded as manpower issues, to which this study was primarily directed. As explained in Chapter 1, despite the directed emphasis on manpower planning, we think it essential that the human resource deficiencies be addressed in order that an intelligent manpower modeling effort can be undertaken. Issues Raised by Stakeholders The committee heard from representatives of numerous groups that are directly affected by the ASI workforce. (See Chapter 1 for a list of stakeholder representatives who addressed the committee.) The committee’s sampling from these stakeholder groups revealed several points of agreement on perceived problems, along with some areas of

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Staffing Standards for Aviation Safety Inspectors disagreement on how the FAA should approach the ASI staffing situation. We heard from stakeholder communities that include those who are overseen and inspected by the ASIs, the ASIs themselves (including their union representatives), and the FAA management, so it should not be surprising that perspectives differed substantially on a number of points. Our purpose in this section is to summarize, not to evaluate, the comments, concerns, and suggestions presented to the committee by various stakeholder groups—regardless of the level of agreement across groups. The section is generally organized around the issues identified rather than the groups identifying them. However, because the committee conducted numerous interviews with ASIs representing a wide range of functional roles and geographical locations, we summarize those interviews separately. Many of the issues identified by stakeholders mirror those listed as concerns in the discussion of the origin of the study in Chapter 1. General Comments Stakeholders generally agreed on one very important aspect of the ASI workforce: most ASIs are dedicated to their mission and serve their customers well. The issue of the proper staffing levels and distribution of ASIs is a distinctly different question from that of the competence of individual members of the ASI workforce. In addition, industry trade group representatives uniformly welcomed the oversight of knowledgeable ASIs, acknowledging that it can help them maintain safety and reliability in their operations. At the same time, many aviation industry representatives noted that it is in their own best interests to maintain high safety standards, and that they would do so whether or not they were being inspected by the FAA. Finally, the aviation community generally accepts the use of designees, noting that they are for the most part competent, appropriately used, and vital to the efficiency of the system. That is, given a regulatory environment that mandates certain inspections, reviews, and audits, the system could not function at current ASI staffing levels without the use of competent designees. Perceived Problem Areas Stakeholders representing various groups in the aviation community identified a number of perceived problems with current ASI staffing and human resource management, often illustrating specific cases in which the number of ASIs or their collective technical capacity was deemed inadequate.

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Staffing Standards for Aviation Safety Inspectors Staffing Levels and Distribution. Many stakeholders were reluctant to comment on the overall level of staffing required for ASIs. There was some indication from stakeholders that this reluctance stems from recognition that the overall number of ASIs is driven by budget constraints. However, they were much less reluctant to comment on the distribution of ASIs across offices (and, in some cases, even within offices), noting that staffing levels may not be appropriate to changing local workloads. Specifically, there were assertions that industry changes sometimes have not been accompanied by corresponding changes in FAA assignments and office locations. Other stakeholders believed that the number of ASIs is adequate for everyday workload but not for peak demand. For example, if a regulatory change requires modifications to manuals and procedures by a large number of carriers or repair facilities at the same time, staffing levels are inadequate to handle the surge in demand occasioned by the requirement that ASIs review and approve the changes. The result is lost productivity on the part of the carrier or repair facility while waiting for review and approval. Some stakeholders also raised concern about the FAA’s ability to focus ASI resources in areas of greatest need. That is, even if overall numbers of ASIs are sufficient, the FAA may not have available a sufficient number of appropriately skilled ASIs in the right place to resolve a specific problem. ASI Knowledge and Training. While noting that most ASIs are highly skilled in one or more specific aspects of the job, stakeholders also noted that their technical knowledge and experience are sometimes insufficient for getting jobs done properly and in a timely manner. Specifically, the match between individuals’ technical knowledge and the particular kinds of facilities and operations they oversee is not always optimal. For example, in the case of emerging avionics systems or agricultural aviation operations, ASIs may not be fully familiar with the equipment or operations for which they are responsible. At the same time, some ASIs lack the knowledge and skills to use data-based tools and systems like the Air Transportation Oversight System (ATOS), the Aviation Safety Action Program, or Flight Operational Quality Assurance. Some stakeholders believe that the knowledge mismatch problem and the problem of ASIs keeping current on new technologies are exacerbated by excluding them, on ethical or other grounds, from free technical training that is offered by organizations under FAA oversight. We note that the U.S. Government Accountability Office (GAO) has addressed the issue of ASI training— including the issue of ASIs receiving training from industry—in its September 2005 report, Aviation Safety: FAA Management Practices for Technical Training Mostly Effective; Further Actions Could Enhance Results (U.S. Gov-

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Staffing Standards for Aviation Safety Inspectors ernment Accountability Office, 2005). The GAO found that the FAA had improved its technical training management practices, but it also noted that FAA training management and inspectors differ in their assessments of how well the inspectors’ technical training needs are being met. One of its recommendations was that the secretary of transportation should direct the FAA to review its policies on acceptance of free training from the aviation industry and implement methods to ensure compliance with those policies. Other Problems. Almost all stakeholder representatives addressed the questions of ASI staffing levels, and the distribution, knowledge, and training of ASIs. Many representatives pointed out other areas of concern as well. A number of industry groups raised a concern about the effectiveness of FAA oversight of outsourced maintenance and other outsourced work. Questions were raised about whether the number of inspectors was keeping up with the growth of outsourcing. In particular, concerns were expressed over how the language and cultural barriers that are unique to international outsourcing (“offshoring”) are being addressed. However, some stakeholders observed that the quality of aircraft maintenance at many overseas facilities is currently superior to that performed at many U.S. facilities. Therefore, the proposition that outsourcing maintenance to overseas facilities is a risky endeavor should not be accepted without question. Regardless of whether outsourcing poses any questions of quality, the logistics of covering the geographic area and the cultural differences add to the inspector workload. On another topic, most stakeholders endorsed the use of designees to increase the efficiency of their operations; however, some groups noted that the use of designees, who charge fees, for tasks formerly performed at no charge by an ASI may impose financial burdens on general aviation customers. Finally, several stakeholders noted that some ASI job descriptions are not accurate or current, and the problem is increasing with the changing aviation and safety oversight landscape. Needs Identified by Stakeholders In the course of their discussions with the committee, stakeholders identified a number of actions that they believed would help the FAA in managing the ASI workforce. These were not confined to manpower management. In general, stakeholders endorsed the idea that the FAA needs enough ASIs, properly trained and deployed, to address peak and emerging work demands, as well as to carry out routine processes. There was wide agreement that ASIs need continuing technical training on new sys-

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Staffing Standards for Aviation Safety Inspectors tems and equipment, and that ASIs need to better understand the various kinds of businesses and operations they oversee. Some stakeholders noted that many ASIs need better training on the oversight process itself, and that ASIs need to have new knowledge, skills, and abilities and a “systems view” to work with new system safety oversight tools. Finally, some stakeholders believe that the FAA needs better job descriptions and knowledge, skills, and abilities inventories for ASI jobs. ASI Perspectives The committee was briefed by a number of ASI representatives during several of its meetings. In addition, 39 ASIs and managers in 7 locations, including various types of offices, were interviewed (see Chapter 1 for details) so that committee members could gain a firsthand understanding of these jobs, along with the perspectives of the professionals performing them. Most of the issues raised by the ASIs can be grouped under three headings: (1) training and socialization issues, (2) workload issues, and (3) designee issues, and they are summarized in that manner below. Individual ASIs also identified a number of idiosyncratic concerns that are summarized under a fourth heading (other issues). What follows is therefore a purely descriptive listing of information gathered from the ASI briefings and field interviews with no attempt to evaluate or judge the validity of the views expressed. Training and Socialization Issues Little overlap is allowed between a retiring or transferring ASI and his or her replacement. Typically the departing ASI must leave before the new one can start the job. Thus there is a gap between the time one leaves and the other begins, as well as a decreased level of effectiveness during the time the new ASI is learning the job. The time needed to become proficient in a particular ASI assignment is lengthy, but ASIs must begin performing their jobs as soon as they are assigned, despite skill deficiencies that could be improved with training. The time to master the job varies with the background and experience of the individual as well as the availability of training. Given wide variations in technology and facilities, prior ASI experience may not necessarily give an ASI the necessary knowledge to do his or her new job; some ASIs reported that it takes a minimum of two to three years to become fully proficient on the job. Aviation technology is rapidly evolving, and many ASIs find it difficult to identify appropriate standards for the new technology or to keep up with changes.

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Staffing Standards for Aviation Safety Inspectors Several ASIs mentioned that technology is changing faster than guidance for the use or maintenance of that technology is developed. Training may not be available in a timely fashion. Some ASIs mentioned that they were not trained on aircraft or equipment for which they were responsible. Others indicate they received their training secondhand from other ASIs. Others received their training from the companies that manufactured the equipment, despite some FAA uncertainty about the circumstances under which ASIs should attend such training. Some of the training that is provided by the FAA is perceived to be time-consuming and of minimal value. The training is often “one size fits all” and disregards the needs of individual ASIs. Some ASIs noted that the manufacturers and the airlines that they oversee are often the best source of training on the latest technologies, yet taking advantage of these training opportunities may be prohibited by rules and regulations or ethical considerations due to an apparent conflict of interest. Some hinted at a conflict of interest (e.g., receiving training on the operation of an aircraft from a school under the ASI’s supervision); others saw no problem with receiving training from vendors. Some ASIs reported that online training often cannot substitute for or replace on-site training, and therefore providing on-line training is not sufficient to adequately train ASIs in some content areas. Not all ASIs share a good understanding of the risk management or system safety approach that is implemented in ATOS and other new FAA systems. It appears that some ASIs believe that a risk management approach increases the amount of paperwork exponentially and therefore places additional time demands on them at the expense of inspection activities that they consider more critical. In a similar vein, other ASIs reported that the only way to ensure safety is to perform frequent surveillance, and that the risk management approach leads to possibly dangerous compromises. Regardless of whether this observation is accurate, the fact that many ASIs believe this suggests that they lack knowledge of, and/or confidence in, the tools at their disposal to perform risk management. The reluctance of many ASIs to accept the preventive or risk management approach suggests that, if this approach is the way of the future, the FAA must do a better job of training and socializing ASIs so they are committed to this philosophy. Some ASIs noted that since the risk management approach requires a different mentality and set of qualifications from those traditionally sought, future ASI recruitment should be revised accordingly. For example, a background in quality assurance/control might be accorded a high priority in the qualifications list.

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Staffing Standards for Aviation Safety Inspectors Workload Issues Many ASIs believe there is more work expected of them than can be done in the 40-hour work week allocated. Most agree that while all required items are completed, some planned items are not accomplished, and a large number of demand items (e.g., investigations of accidents or complaints) are difficult to manage because the ASI does not know how many he or she will get or how long each will take to resolve. Some believe they have too many designees and cannot supervise them all effectively. Despite the limits on time worked, many ASIs do “off-the-clock” work. The work program does not provide adequate time for administrative activities, including paperwork. The work program covers fieldwork but not important administrative activities like cataloguing and updating manuals or creating documentation related to ISO 9000 certification now being pursued by Aviation Safety (Federal Aviation Administration, 2006). The system does not take into account unconventional demands on the ASIs’ time. For example, the filming of an action movie often involves use of airspace and requires special oversight by the FAA. Planning and coordination for these events take a significant amount of time. Few options exist to manage the workload. The number of people that can be hired is constrained, as are the number of hours worked. In general, overtime work is not allowed, and ASIs may not carry more than 40 hours of compensatory time. Many ASIs noted they were not able to take the compensatory time they had already accrued. Several ASIs in operations reported that the FAA staffing system places too much emphasis on number of aircraft to determine workload, while ignoring other critical factors such as the age of the fleet. For example, cargo airlines often have older fleets that require additional surveillance beyond that required by the newer aircraft that passenger airlines tend to use. Staffing is often inadequate at peak times. ASIs in some locations noted that additional surveillance was needed at peak times (e.g., Thanks-giving), but additional personnel or hours were not available. The priority of work items is sometimes unclear. Work programs often have activities that must be accomplished in a year but are neglected for unexpected items that arise during the year that seem to have higher priority. The amount of paperwork is immense, and there is little clerical assistance in most offices to assist with the management of documents.

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Staffing Standards for Aviation Safety Inspectors ASIs are required to complete their own paperwork for tracking time and tasks as well as manage paperwork for an array of citizens who need certification, authorizations, and waivers or who must report accidents. ASIs use a number of reference materials (e.g., Inspectors’ Handbooks 8700, 8400, 8300; Federal Aviation Administration, 1994, 2003, 2004a, 2004b, 2005b) that must be updated. Keeping manuals current is a time-consuming task that ASIs are not always able to do in a timely fashion. Guidance for ASIs shows up in a number of places ranging from the inspectors’ handbooks and handbook bulletins to manufacturers’ specifications. Ensuring the most current information is sometimes difficult. The FAA’s time and task tracking systems are difficult to use for a variety of reasons and take more time than necessary in the opinion of some. These difficulties sometimes result in inaccurate reporting. The Program Tracking and Reporting Subsystem (PTRS) and the Labor Distribution Reporting (LDR) system require separate entries of the same or similar information, so ASIs spend a significant amount of their time in redundant data entry activities. PTRS tracks completed tasks. LDR tracks the way individuals use their time. In addition, there are written documents for time and attendance, sick leave, etc., that require completion and signature. A better integration of these systems so that they could all share the same database might solve this issue. The codes for the LDR system are extensive and can be viewed only 10 at a time. Users cannot back up in the system—only move forward. Travel by car to inspection sites can be time-consuming, and resources for faster transportation by air are not available. Some ASIs complained that they do not have access to FAA aircraft even when a flight was going to their destination. Others indicated they were required to drive and had little time left for their work once they arrived at their destination. Geography and the associated travel time is a major factor in the amount of time available for inspections at some flight standards district offices. If ASIs were able to perform more of the aviation education activities included in the work program outlined in Order 1800.56F (Federal Aviation Administration, 2005a, p. 6), general aviation safety could be improved, according to many ASIs. Suggestions ranged from public seminars to more surveillance and presence at air shows. Higher priority tasks leave little time for such activities. ASIs often have a sense of never being caught up with their work.

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Staffing Standards for Aviation Safety Inspectors Many ASIs believe the FAA headquarters is overly reactive to outside pressures and creates work by not considering the broader implications of the actions it takes. In addition, there is a strong belief that the FAA in general and the Flight Standards Service (AFS) in particular is a top-down organization in which decisions are made at the top without a genuine understanding of the issues and the ramifications. Individuals exercising political influence can place enormous pressure on an FAA office or an individual ASI with the result that work priorities are altered. Designee Issues1 The level of oversight of designees may be inadequate in some cases. The ASIs often worry about their supervision of designees and believe they do not have enough time to observe and coach the less capable designees. Consequently, some designees may not be doing as good a job as they should. ASIs use proxies that may not be as good as actual observations for evaluating designees. For example, when ASIs don’t have the time to observe all their designees, they may monitor the proportion of examinees passed and failed by a designated pilot examiner. An excessively high pass rate may indicate that the designee’s standards are inadequate. Similarly, if a designee regularly gives unqualified approval to maintenance of aircraft that appear to require complex maintenance activities, the ASI may assume the designee is not reviewing the work with sufficient care. The extent to which these reviews are adequate is not known. Some ASIs observed that the number of designees is an incomplete index of the amount of work required to oversee designees. Certain designees, such as freelance agents authorized to certify pilots, require extra time because they work only during the weekend, have other unusual schedules, or work in multiple locations and, in general, are more difficult to track and monitor. Some ASIs perceived a move toward the privatization of their work and believed that this will result in the loss of their jobs and poorer enforcement of standards. 1 Note that the Government Accountability Office was tasked to study the use and oversight of designees. Its October 2004 report (GAO 05-40) can be found at http://www.gao. gov/new.items/d0540.pdf.

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Staffing Standards for Aviation Safety Inspectors Other Issues Concerns of a more idiosyncratic nature expressed in the interviews involved the amount of authority ASIs have (or do not have), coordination across offices, privatization, and ATOS. Below are some specific examples. ASIs sometimes lack the authority to handle problems immediately. For example, ASIs have no legal authority to arrest someone or even demand that an individual return his or her certifications. They must use the Enforcement Investigative Report process and the court systems. In one example provided, an ASI noted that he had filed a safety recommendation against a manufacturer. The manufacturer and its designee did not want to adopt the recommendation, and the FAA did not require that they do so. Insurance companies are often perceived as the most powerful force in aviation safety. Coordination among government offices is sometimes lacking. For example, some ASIs noted problems certifying foreign pilots through the Transportation Security Agency and the lack of guidance or a clearly specified process for doing this work. Others noted that the National Transportation Safety Board has delegated nonfatal accident investigation to the ASIs in the FAA. ASIs voiced concern that the move away from hands-on inspection in favor of a remote, data-based systems approach (i.e., ATOS) is flawed and will ultimately have safety consequences. Some have documented cases of violations in ATOS-certified aircraft and operations that were not uncovered in the systems review. Despite all the issues and problems that ASIs raised, they also noted that the ASI job is among the highest paid positions in the federal government (GS 13 or 14) and that competition for positions in some locations is fierce. Major Drivers Behind ASI Staffing Needs In the previous sections, we summarized what we heard from stakeholders and ASIs. There was general agreement in the areas of training needs, issues of geographic distribution, and impacts of peak demands caused by regulation changes. The committee balanced what we heard from the stakeholders with what we read or learned from the FAA and other sources in forming a general understanding of the unique requirements or challenges involved in the development of any ASI staffing model. ASI human resource demands, both the required number of inspectors and their qualifications, are driven by a combination of factors,

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Staffing Standards for Aviation Safety Inspectors some of which are related to the changing U.S. and global aviation landscape and others to policies and changes inside the FAA. Factors External to the FAA: The Changing Aviation Landscape The changing U.S. and global aviation landscape has important implications for ASI staffing. The following five features of that changing landscape are expected to be important drivers of future ASI staffing needs: introduction of advanced flight deck and air-ground technologies, increasing number of variants and derivatives of aircraft and systems, continuing growth in regional carrier and general aviation operations, outsourcing and offshoring of maintenance; and new manufacturing tools and techniques. Introduction of Advanced Flight Deck and Air-Ground Technologies. With the introduction of more complex airborne and ground-based technologies, not only at major carriers but even at the level of general aviation, the need for ASI training and specialization increases, especially in the areas of avionics and operations. ASIs need a thorough understanding of the design, capabilities, and operation of these systems. These new training requirements will take time away from actual inspections and may lead to a demand for more inspectors in the future. Also, it will be important for inspectors to be aware of potential problems with human-automation interaction and human factors design principles. Increasing Number of Variants and Derivatives of Aircraft and Systems. Since aircraft manufacturers need to be responsive to customer needs and preferences, an increasing number of derivatives or variants of certain aircraft types continue to enter the market. As an example, six currently available variants of the Boeing 777 are listed on a Boeing web site (Boeing, 1995). Inspectors need to spend time learning about those new aircraft configurations because the presence or absence of components and their interactions can affect risk levels and create overall safety concerns. One frequent comment was that some form of “differences training” should be provided. Yet we heard from ASIs that technology training opportunities for ASIs have been limited in the past, and if a more appropriate level of training were provided, the additional training time would reduce the availability of ASIs to fulfill oversight responsibilities and maintain the current level and timeliness of service to customers.

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Staffing Standards for Aviation Safety Inspectors Continuing Growth in Regional Carrier and General Aviation Operations. One of the many changes under way in the aviation industry is the especially fast growth in regional airline activity. According to the Regional Airline Association, regional airlines carried approximately 134.7 million passengers in 2003, an increase of more than 100 percent over 1994 (http://www.raa.org/news/Industry_Fact_Sheet.cfm, accessed May 11, 2006). The FAA projects 155.9 million enplanements for regional carriers in 2006 and forecasts that this growth will continue at an annual average rate of 4.3 percent in revenue passenger load from 2006 to 2017, reaching 250.4 million enplanements in 2017 (Federal Aviation Administration, 2006). General aviation, still recovering from losses in activity after September 11, 2001 (9/11), is projected to continue growing as well. The FAA forecasts that the U.S. general aviation fleet will grow from 214,591 aircraft in 2005 to 252,775 in 2017, and that hours flown by general aviation aircraft will increase from 28 million in 2005 to 41 million in 2017, a 3.2 percent annual growth rate (Federal Aviation Administration, 2006). These segments of the aviation industry can require more labor-intensive oversight than major carriers, because they are comprised of many small organizations and individual owners/operators. Another challenge associated with further growth in general aviation is the large number of different aircraft models and the fact that owners can tailor the equipment on board to their preferences. Thus inspectors need to know many different aircraft, and for each aircraft model they are likely to encounter a variety of avionics/systems configurations and need to understand whether and how well those components work together. Outsourcing and Offshoring of Maintenance. The weakened economics of the airline industry, in combination with fast-rising fuel prices and increased safety measures since the events of 9/11, create a challenging business environment for air carriers. In order to stay viable, they need to look for ways to cut costs. At least one cost-cutting measure—the outsourcing of maintenance—has implications for ASI staffing demands. According to the U.S. Department of Transportation inspector general’s report (2005), the percentage of outsourced maintenance for most major air carriers has increased in recent years. In September 2004, nine ATOS carriers reviewed by the inspector general contracted out 53 percent of their aircraft maintenance expense (pp. 7-8). Much of this outsourced work is performed in areas outside the United States, such as El Salvador, Hong Kong, and Singapore. These offshoring practices can generate a range of issues. In order to directly oversee offshore maintenance facilities, ASIs would need to travel extensively, reducing the amount of time available

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Staffing Standards for Aviation Safety Inspectors for other responsibilities. Also, in order to effectively oversee these facilities directly, ASIs need a full understanding of the work culture and language of the countries in which maintenance is being performed. In response to these and other challenges, AFS has established international field offices in some locations. The FAA also has implemented agreements with other national and regional aviation regulatory authorities that ensure that they set and enforce quality standards equivalent to those of the FAA, so direct ASI oversight can be reduced (see, for example, Order 8100.14a, Federal Aviation Administration, 2005f). Still, many stakeholders are concerned about oversight of some of these facilities. A December 2005 report by the inspector general on the outsourcing of maintenance to noncertified maintenance facilities, both domestic and foreign, questions the adequacy of the FAA’s current oversight of such facilities (for example, AV-2006-031, U.S. Department of Transportation Office of Inspector General, 2005). Another issue in offshore maintenance is that the maintenance manuals for U.S.-manufactured aircraft and components often are published in English only, presenting a challenge for technicians whose first language is not English. This may require even stricter oversight of such maintenance than would be needed if technicians were using manuals written in their native languages. New Manufacturing Tools and Techniques. The introduction of new manufacturing tools and techniques affects the required number and, even more importantly, the required skills for manufacturing inspectors who are responsible for administering and enforcing safety regulations and standards for the production or modification of air carrier and general aviation aircraft. For example, inspectors need to have a thorough understanding of software tools like CATIA, which are increasingly used by aircraft manufacturers. CATIA is an example of a commercial software suite that supports all stages of product development, from conceptualization through computer-aided design (CAD), computer-aided engineering (CAE), and computer-aided manufacturing (CAM). Factors Internal to the FAA: Changing Policy and Business Practices and the Aging Workforce Four areas of change within the FAA appear particularly noteworthy with respect to their implications for future ASI staffing needs: increasing use of designees, shift to system safety approach, regulatory changes, and ASI attrition and retirements.

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Staffing Standards for Aviation Safety Inspectors Increasing Use of Designees. Designees, the individuals or companies that are authorized by law to conduct tests, examinations, and inspections on behalf of the FAA, can reduce an inspector’s workload by assuming some of his or her basic responsibilities. At the same time, however, they create new oversight tasks and challenges for inspectors who are responsible for ensuring the quality of the designees’ work. In view of the already rather large and increasing number of designees and their geographical distribution, the net effect of growth of the designee program on the ASI job is likely to be qualitative—that is, an ASI role that becomes more supervisory in nature—rather than quantitative—that is, a reduced number of ASIs. Shift to System Safety Approach. As noted throughout this report, the FAA’s move to a system safety approach has profound implications for both quantitative and qualitative ASI human resource needs. The System Approach for Safety Oversight (SASO) Program is intended to provide an umbrella for all FAA safety oversight responsibilities. It was introduced in hopes of reducing the number of air carrier and general aviation accidents and improving the job training and quality for aviation safety personnel while leading to significant savings for the FAA and the aviation industry (SASO Mission Need Statement, Federal Aviation Administration, 2001). One element of SASO encourages increased information- and tool-sharing between the aviation industry and the FAA to support the early detection and identification of risk factors. Another goal of SASO is to identify early on and support changing training requirements for FAA personnel. One important safety oversight program that falls under the SASO umbrella is the Air Transportation Oversight System. ATOS is a relatively new data-driven and risk-based air carrier oversight process that was first implemented at 10 major carriers in 1998. ATOS requires inspectors to analyze operational data to identify areas that pose the greatest safety risks for a particular carrier and focus their inspections on those areas (Order 8400.10, Appendix 6, Federal Aviation Administration, 2005d). The main differences between the traditional surveillance and safety inspection system and ATOS are that the traditional approach focuses on completing a prescribed number of inspections, relies on individual inspector expertise, and is based on checking carrier compliance with regulations. In contrast, under ATOS, inspectors develop and revise specific surveillance plans for each carrier, analysts review air carrier data to identify areas of risk that the inspectors should target, and the focus is on safety vulnerabilities rather than compliance with regulations. Thus, the new approach is anticipatory and preventive in nature and requires a

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Staffing Standards for Aviation Safety Inspectors much greater degree of flexibility and tailoring of oversight activities. It also calls for inspectors to develop new skills to be able to develop, execute, and monitor the effectiveness of carrier-specific surveillance plans in collaboration with data analysts. Regulatory Changes. Regulatory changes have an impact on ASI workload and staffing requirements as well. For example, new FAA regulations that became effective in 2005 (FAR Part 121, Amendment No. 121-130, Federal Aviation Administration, 2005a; FAR Part 129, Amendment No. 129-41, Federal Aviation Administration, 2005b; FAR Part 135 Amendment No. 135-81, Federal Aviation Administration, 2005c) now require that all aircraft of defined types undergo an inspection and review after the 14th year in service and at specified intervals thereafter. These inspections help ensure the adequate and timely maintenance of an aircraft’s age-sensitive components. As the number of aircraft falling into this category grows, more field inspectors may be needed to accomplish or to oversee these inspections. Many regulatory changes require revisions in procedures and supporting manuals for manufacturers, maintainers, or operators of specific aircraft. All such documentation revisions must be reviewed and approved by ASIs. These tasks can impose major burdens on their time. ASI Attrition and Retirement Rate. Between 2003 and 2005, the FAA ASI workforce was downsized by 231 safety inspectors. While the staffing level in the Office of Aviation Safety is expected to increase by about 80 in 2006, this growth would still leave it below the FY 2004 staffing level. The median age of all AFS ASIs in FY 2003 was 54, with only 32.6 percent under age 50 (staffing tables provided by Robert Caldwell, AFS 160).2 As these aging inspectors retire, requirements to hire and train new ASIs will increase. These staffing changes contribute to the workload challenge already faced by ASIs and will need to be considered in any model that determines future staffing needs. Viewed differently, the need to recruit many new inspectors can be seen as an opportunity to develop and apply new ASI job descriptions and qualifications to match evolving FAA practices. 2 A statement presented by Michael Fanfalone representing Professional Airway Systems Specialists to the House Aviation Subcommittee on April 11, 2002, states that “43% of the inspector workforce is eligible to retire by 2006.” He attributes that figure to an FAA report: FAA’s Workforce Planning and Restructuring, June 4, 2001 (Fanfalone, 2002). The committee has been unable to locate that document to verify the statement.

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Staffing Standards for Aviation Safety Inspectors Factors Internal to the FAA: Human Resource Management Practices The committee’s first goal was to “critically examine staffing standards for FAA Aviation Safety Inspectors and the assumptions underlying those standards.” In the process of fulfilling the second element of our task, which directed us to “gather information about the ASI job series,” we detected a number of qualitative issues related to current human resource management practices that were intrinsically linked to the determination of ASI demand. The human resource management practices we are concerned with include ASI job design, recruitment, selection, training, and development. Undoubtedly, some modifications of current practices may have implications for work rules, compensation, and labor relations matters, which our tasking explicitly directed us to exclude. We do not discuss any of those potential implications, but we do describe how human resource management practices outside of manpower management may relate to staffing models and standards. We believe that the synthesis of staffing-related issues presented here is consistent with the spirit of our tasking. We should note that, in accordance with our task, we did not undertake a direct examination of the FAA’s recruitment, selection, or training practices, but instead report on issues related to each of these staffing-related functions as they were shared with us in the process of gathering information about the ASI job series. Our findings are therefore based on a relatively small sampling of available data sources—convenience samples that cannot be regarded as representative—so our depiction of the focal issues should be interpreted with this qualification in mind. New Knowledge Demands of System Safety Approaches. Order 1800.56F (Federal Aviation Administration, 2005g) enumerates the flight standards work functions to be completed by AFS personnel. These work functions fall under the categories of surveillance, investigation, certification, and aviation education. Order 1800.56F advocates a “system safety concept of oversight” (section 6-f, page 4), which goes beyond a mere “checklist” inspection and annotation of observed deficiencies and instead calls for an integrated assessment of system status. Indeed, Order 1800.56F points out that “surveillance is a tool to provide information for performance assessment and risk management” (p. 5). The order calls for inspectors “to target their safety surveillance based upon risk and/or safety assessment,” and it advocates a data-driven approach aided by information systems, such as the Safety Performance Analysis System (SPAS). The investigations function also calls for higher order analytic skills as it aims to determine “causal factors of potential or actual problem areas” (p. 5).

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Staffing Standards for Aviation Safety Inspectors Our interviews with ASIs revealed a lack of comfort with or confidence in this system approach to risk assessment among some incumbents. It appears that some ASIs still see themselves as traditional inspectors, perceiving that any approach to their job other than direct-contact, field surveillance represents a compromise that endangers aviation safety. This unwillingness to embrace the system safety and risk assessment approach may suggest a number of problems. For example, tools like SPAS may simply be difficult to use and require retooling to make them more user-friendly. Some ASIs may simply not know how to extract valuable information on trends and probabilities from the data-analytic tools available to them (e.g., SPAS), while others may not know how to make inferences from the data produced. Others may have difficulty transitioning from an environment of wide surveillance activities to one of prioritized surveillance. Other ASIs may doubt the accuracy of the data input into systems like SPAS and thus lack confidence in any decisions based on the analysis of those data. We learned from our interviews with job incumbents and other stakeholders that individuals enter the ASI job series from a variety of backgrounds. It appears that those individuals whose prior experience has been limited to routine repairs or installations under close monitoring or supervision from others may have an insufficient understanding of how entire systems work, and they may be unprepared to engage in preventive risk assessment following the system safety approach. Thus, some ASIs may benefit from training and development programs intended to sharpen their ability to understand causal relations among system components, identify trends in the data gathered through surveillance activities, and, overall, think in probabilistic terms when assessing risks. In contrast, individuals with prior experience in managing quality assurance of large and highly distributed aviation operations appeared to be most receptive to, and capable of performing under, the premises of the systems approach to risk assessment. Such prior experience and background may thus be weighted favorably in future ASI recruitment and selection programs. The value of incorporating this or any other prior experience in a selection procedure, however, should not be taken for granted until the appropriate validation study is carried out. Implications for ASI staffing: If individuals are not comfortable with changing job requirements, the FAA may not be able to staff optimally until all individuals are fully trained, understand, and accept the new work expectations. New Skill Demands. Order 1800.56F (p. 6) also states that aviation education is one of the primary functions of AFS. Many of our interviewees pointed out that performing the job successfully required a collaborative

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Staffing Standards for Aviation Safety Inspectors approach to aviation safety, as opposed to an adversarial approach focused on policing the industry. In this collaborative role, ASIs serve as facilitators who educate the aviation community and the public at large on aviation safety. The set of interpersonal and communication skills required to perform their educational functions in a collaborative manner may be improved on the job or through training and development programs. However, interpersonal and communication skills can be difficult to develop, and therefore the recruitment and selection of individuals with at least a minimum level of such competencies may facilitate their further development. Implications for ASI staffing: The FAA may not be able to staff optimally until individuals with the requisite interpersonal and communication skill levels (achieved via either training or selection) are in place. New and Continuing Technology Knowledge Demands. Some ASIs and some stakeholders highlighted the difficulties inherent in finding and accessing relevant training programs that will help them update their knowledge of aviation technology. Some ASIs also pointed out that internal training manuals and training programs are often too basic or do not keep up with the latest innovations in the field. Budgetary restrictions and the FAA’s discomfort with having ASIs attend training provided by the manufacturers, the airlines, or any of the other entities that they serve (due to potential conflicts of interest) were deemed to be additional roadblocks in their ability to keep abreast with knowledge in their field. Some stakeholders noted that technical obsolescence impairs or at least slows down the ability of ASIs to serve those who employ the latest aviation technologies. This finding has potential implications not only for ASI training and career development, but also for whether an effective system is in place to detect and respond to their training needs. Implications for ASI staffing: The FAA may not be able to staff optimally until individuals with the requisite knowledge levels (achieved via either training or selection) are in place and may need to include more time for continuing technical training when determining staffing levels for some ASI positions. Lack of Performance Criteria for ASIs. The FAA informed the committee of its explicit intention to transition to performance-based management, asking us to look at performance-based versus engineered staffing standards. But any superiority of performance-based over engineered standards (i.e., standards derived from detailed task analysis) is critically dependent on how performance is defined and measured. Moreover, a measure of staffing outcomes, presumably based on the performance of the ASI workforce, is needed to determine the validity and utility of any

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Staffing Standards for Aviation Safety Inspectors ASI staffing model and its outputs. However, the FAA has not developed acceptably explicit performance measures for ASIs. The committee was told by FAA staff that there had been an attempt to use ASI productivity statistics as a measure of performance, but that it had been unsuccessful. Most ASIs report that they make sure that they accomplish all of their high-priority (required and planned) work and most other surveillance work; others admit that the planned items can be significantly delayed or even omitted on occasion. However, they complain that there are not enough person-hours to do those tasks as well as they would like, and they have very little time for discretionary tasks, such as safety education. This finding suggests that a measure of work quality or thoroughness, rather than merely a count of tasks accomplished, may be needed to reveal shortfalls in ASI staffing. Implications for ASI staffing: Clearly, neither definition nor measurement of performance is a simple matter for the ASI job domain, but both will be critical to the development of a useful staffing model. Summary The material presented in this chapter represents both a compilation of the information gathered in the course of the committee’s investigation and a synthesis of that information designed to assist developers of any future modeling effort. Thus it constitutes the basis for the evaluation of existing models and the conclusions reached in Chapter 3, and it also underlies the findings and recommendations summarized in Chapter 5. In order to understand the ASI staffing situation in its totality, the committee thought it necessary to gather information from multiple sources: official documents and records, stakeholders external to the FAA, various levels of FAA management, ASIs at their workplaces, and union representatives. While recognizing that these perspectives would not be completely congruent, we expected that there would be enough convergence to establish the major facets of the staffing problem and to judge the extent to which current and alternative approaches would be capable of satisfying the growing inspection demand. Both expectations were realized. There was disagreement on a number of mostly lesser issues but substantial agreement on the limitations of current models, current staffing practices, major workload drivers (internal and external to the FAA), and institutional constraints (notably budget limitations). Moreover, there was broad agreement that the long-standing trend of growing demand and static supply cannot continue much longer without serious consequences; hence a major correction is long overdue. Operating on this premise, the committee directed its attention to identifying deficiencies in current practices (problem areas), the major

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Staffing Standards for Aviation Safety Inspectors drivers of present and future demand, and other challenges that would need to be met in order to effect systemic improvement. As noted in the last chapter, this analysis convinced us that the most cost-effective approach would be development of an entirely new ASI staffing model. Whereas Chapter 2 provided guidance on the formal properties that should be considered in developing such a model, this chapter completes the picture by identifying the substantive aspects of the ASI staffing situation that must be accommodated in it. One recurrent theme, introduced in Chapter 1 and sustained through the report, is that no modeling effort, however well conceived, can succeed without the development of defensible human resource management elements—in particular, meaningful performance measures, accurately maintained job descriptions with matching requirements, and the institutional commitment not only to implement the model properly but also to maintain it. It is essential that FAA management recognize the interdependence of human resource and manpower planning functions and appreciate the fact that investment in either alone cannot achieve much in the way of improved staffing, system efficiency, or performance. The commitment must involve both concurrently. Moreover, in view of the changing aviation environment, it must be a sustained commitment.