What is an ODA and why is it critical to understand it

By the Leeham News Team

Feb. 14, 2024, © Leeham News: In Congressional hearings last week, the administrator of the Federal Aviation Administration (FAA) said the agency will retain an outside organization to review whether its oversight of Boeing needs to alter how this is done.

Administrator Mike Whittaker, who has only been on the job a few months, said the FAA may want to change its Organization Designation Authorization (ODA) process that oversees Boeing.

ODA Unit Members (Designees) are Boeing employees who report to the FAA. But for years, highlighted by the first 737 MAX crisis in 2018-19, complaints suggested Boeing exerted undue influence on its Designees to get what it wanted in the development, production, and oversight of its 7-Series airplanes.

Because of that crisis combined with multiple issues with the 787 production facility in Charleston (SC), Boeing’s ODA was suspended.

The FAA also has a problem: Boeing’s ODA was suspended. Congress has a problem: The FAA and Boeing appear to operate too closely together and have lost public trust.

What is an ODA and why does the FAA need to delegate work back to the companies being monitored using Designees? LNA takes a deep dive analysis into the ODA problems at Boeing and what can be done to restore confidence in Boeing, the FAA, Congress, and the flying public. This is the first of two articles.

Background of the ODA

The FAA doesn’t have the resources to do all the certification activities necessary to keep up with an expanding aviation industry. Their staff surveils the entire civilian aerospace industry for Continued Airworthiness, Modification, Manufacture, Certification, and Airspace Control as well as a myriad of other smaller missions.  Doing this without help is a virtual impossibility.

The FAA gets help using Designees for routine tasks allowing the FAA to focus its limited resources on safety critical certification issues as well as new and novel technologies. Designees come from private industry. They are experts in the aviation and medical communities who are familiar with the regulations and certification requirements necessary to issue a certificate. Individual Designees can either be a company employee or an individual consultant.

Examples of such experts might be mechanics, doctors, engineers, inspectors, and pilots. All designees must pass a rigorous screening process to be approved to act in the FAAs capacity in a limited scope. The FAA delegates to approved individuals and companies every task they do.  Think of it as a force multiplier in that private industry is doing a very significant amount of the FAA’s work.

Here’s a list of delegated functions

Certification of Aircraft

  • Engineering design
  • Manufacturing
  • Operations
  • Maintenance

Certification of People

  • Medical Examinations
  • Pilots
  • Mechanics
  • Parachute Riggers
  • Dispatchers
  • Knowledge Testing
What is an ODA, What’s a Designee and why do we care?

The ODA program is how the FAA grants compartmentalized designee authority to organizations or companies for specific types of work.  This is important to the FAA in that it leverages non-FAA payroll personnel of the company being monitored to act in the best interests of the FAA in the bulk of day-to-day operations.  ODA is not peculiar to Boeing.  Most ODA organizations do their jobs so well that you don’t know they exist, which is the way it should be.  There are so many designees in so many different ODA organizations that the American aerospace industry would stop if they weren’t there.  Delegation is far bigger than the media’s constant pointing at the FAA/Boeing relationship failure. It is a triumph in safety management as the rest of the industry operates as intended.

Having an ODA is a privilege and is not easily achieved. The ODA designation means that you are allowed to be the FAA on their behalf and do their work on your items.  This is a huge responsibility, and it is not lightly granted.  The FAA vets each ODA program, the designee employees, and periodically checks to verify compliance with the FAA’s directives and rules that need to be followed.

ODAs are compartmentalized by the work type. A company is only allowed ODA designee authority based on the following ODA types.  More than 140 ODA-designated organizations are spread among the following disciplines.  Delegation is far bigger than the media’s constant pointing at the FAA/Boeing relationship failure. It is a triumph in safety management.

ODA Descriptions

Type Certificate ODA

Holders of a Type Certificate ODA (TC ODA) may manage and make findings for type certification programs. In addition to the engineering and manufacturing approvals that are part of the certification program, a TC ODA holder may issue airworthiness certificates, but may not issue an original type certificate or amended TC.

A TC ODA is available to organizations holding a TC issued by the FAA.

STC ODA

Holders of a Supplemental Type Certificate (STC) ODA may develop and issue supplemental type certificates and related Airworthiness Certificates. An STC ODA is intended primarily for repair stations, operators, and manufacturers, but consultant groups with the required knowledge and experience may also qualify for an STC ODA.

PC ODA
Holders of a Production Certificate (PC) ODA may issue airworthiness certificates and approvals, determine conformity, perform evaluation leading to amendment of its production limitation record, and approve minor changes to its quality control manual. To qualify for a PC ODA, an applicant must be an existing Production Certificate holder or have applied for a TC and PC.

PMA ODA

Holders of a Parts Manufacturer Approval (PMA) ODA may issue PMA supplements based on test and computation approvals, STCs, or licensing agreements. Only existing PMA holders qualify for this ODA type.

TSOA ODA

Holders of a Technical Standard Order Authorization (TSOA) ODA may issue airworthiness approvals and determine conformity of articles, test articles and test set-ups in support of FAA-managed TC or STC projects. Only existing Technical Standard Order (TSO) Authorization holders qualify for a TSOA ODA.

MRA ODA

Holders of a Major Repair and Alterations (MRA) ODA may approve data for major repairs and alterations, issue airworthiness certificates and approvals, and perform aging aircraft inspections and records reviews. Repair stations and operators qualify for all functions available under MRA ODA. Consultant groups are only eligible for engineering approval functions.

AO ODA

Holders of an Aircraft Operations (AO) ODA may conduct certification or portions of the certification process towards issuance of a Rotorcraft External-Load Operator Certificate. ODAs for operational certifications may be expanded in future revisions of this order to include additional air operator, airman, air carrier, or air agency certification functions. An AO ODA is intended primarily for consultant groups, but experienced certificated operators may also qualify.

Narrowing the discussion

Let’s narrow the discussion down to what we as a group are most concerned with:  PC ODA.  When we look at the list of ODA holders, we see just how big the ODA program is and just how stunning Boeing’s ODA suspension was especially with the limited manpower the FAA had on hand to switch gears and take on the extra work.

PC ODAs are held by the following companies: Honeywell International, Rolls-Royce Lycoming Engines, Robinson Helicopter, Learjet Inc., Bell Helicopter Textron, Hamilton Sundstrand Corporation (now part of RTX Corp) , Textron Aviation Inc., The Boeing Company, International Aero Engines, Williams International, Pratt & Whitney, Cirrus Design Corporation, Sikorsky Aircraft Corp, GE Transportation – Aircraft Engines, Delta Engineering Corporation, Hartzell Propeller Inc. and Gulfstream Aerospace Corporation.

Virtually every major aerospace manufacturing company has been granted FAA PC ODA.  There is no possibility of the industry functioning without the delegation of FAA authority to them.  The FAA cannot staff all these locations with the personnel on hand.  The FAA has ultimate oversight of all of them but does so from the 30,000 foot level.

Other users of FAA services 

We also need to remember that there are tens of thousands of other users of FAA surveillance services.  These include small companies building aircraft parts where a PMA is involved.  Every pilot license, both commercial and private, relies on the FAA.

Delegation is critical to the accomplishment of the FAA’s mission, and without it, continued safe flight is not possible.

The Boeing problem

This brings us to the FAA’s big problem at Boeing.  Boeing, being the largest Production Certificate ODA with more than 1,500 employees in its ODA organization was “suspended” insofar as the FAA was issuing all the Certificates of Airworthiness to Boeing 737s and 787s.  This requires boots on the ground, boots the FAA is already short of.

The FAA had to shift personnel to do this increased workload from somewhere, and that somewhere is from every other user in the system.  Consultant Designees and Third Party firms have stepped up to increase their capacity, but the system is strained beyond reason.  The ripples through the industry are felt as a stretch out in the flow times needed for Non-Boeing users to get FAA approvals for their products and services.

The headlines may be about Boeing and the FAA, but that’s the tip of the iceberg.  The problems at Boeing are adversely affecting the entire industry as resources Boeing had normally supplied through their ODA are replaced by FAA personnel forcing Non-ODA users to wait in ever-stretching lines.

The needed change

In our next article, we will break down how delegation of FAA responsibility is handled by the industry, ODA holders vs everybody else and make the case that Boeing needs to be surveilled by a third-party ODA-esq private organization.  The re-establishment of the arm’s length connection between the FAA and Boeing is badly needed.  Congress is demanding change, the MCAS accident reports show a need for the recreation of a true arm’s length relationship between Boeing and its regulators.

 

59 Comments on “What is an ODA and why is it critical to understand it

  1. Does EASA work with (something similar to) ODAs?

    From the link below:

    “Certification Standards: The FAA and EASA have different certification standards for aircraft, engines, and other aviation products. EASA has more stringent requirements for environmental protection and noise reduction, while the FAA has a more flexible approach to certification. This can result in a different lead time and cost for aircraft manufacturers seeking certification from either organization.

    “Regulations: Both organizations have different regulations for the operation and maintenance of aircraft. The FAA has a more hands-off approach, allowing the operator to have more control over the maintenance of the aircraft. EASA, on the other hand, has a more prescriptive approach to regulation, requiring regular maintenance checks and audits by the regulatory body.

    “Approach to Safety: Both organizations have a strong commitment to safety, but they have different approaches to achieving this goal. The FAA has a risk-based approach, which focuses on identifying and managing the risks associated with aviation operations. EASA has a more prescriptive approach, with a focus on setting and enforcing specific standards.”

    https://flyingacademy.com/easa-vs-faa-understanding-the-key-differences/

    • How is the Airbus Mobile Plant handled in this regard? Its missing in the above list of FAA granted PC ODAs.

      Anyone can shed a light?

      Also, perhaps a worthwhile article for Leeham to pursue to do a comparison between EASA and FAA in oversight.

    • EASA has its equivalent, the DOA. It is true that both ODA and DOA are principally different animal, saying they both have different Certification Standards is really BS at all level.

      • And, yet, EASA has more stringent requirements as regards MCAS re-cert, and also appears to be more demanding as regards the 777X flight control software.

        • That is probably less of an FAA vs EASA basic objectives issue
          than due the subversion/collusion between Boeing and FAA.

          Though there is one detail I see as problematic about the FAA:
          Their “second hat” in “furthering US aerospace industry”.
          A direct detractor to their “safety and control” task.

          Beyond a range of nefarious “leveling(actually tilting) the table” to the US side applied to foreign products some efforts
          may have actually improved conformance and safety while Boeing was enabled to squeeze by.

          to use today’s wording: a supervisory escape.

        • Those are just the ones on the news. The reality is that each has its emphasis. Again, your perception is not reflecting the actual situation.

  2. Of relevance to the subject matter in this Leeham article:

    “Sen. Maria Cantwell to accelerate pace of aviation bills in wake of door blowout”

    “I think the days of trusting manufacturers, whether it’s Boeing or anybody else, to self-regulate are long behind us,” Duckworth said in an interview last week. “My feelings are that this is not the time for me to take my foot off the gas.”

    Cantwell said she hopes to hold hearings with representatives from the FAA and NTSB in March to be followed by hearings with Boeing representatives in April. She added she also intends to hold hearings on aviation consumer issues throughout the spring as well.

    “This is a chapter in this long saga about what we’re going to do to upgrade oversight of manufacturers,” Cantwell said. “This is a market, and markets need a policeman on the beat, they need rules and they need someone to enforce them. So we’re gonna find out how capable (the Transportation Department) is of doing that.”

    https://www.columbian.com/news/2024/feb/13/sen-maria-cantwell-to-accelerate-pace-of-aviation-bills-in-wake-of-door-blowout/

  3. You have to have the PC ODA’s for all the small deviations outside DWG tolerances that need FAA approved repairs in the build process. The FAA Designee must check that their repair/blend etc. does not violate aircraft SRM limits and get found in a heavy check down the line. Sometimes they make an approved marking next to the area with an approval number for the repair and the customer gets a list of the approved repairs done on his/her aircraft, ranging from bullet holes during the train ride west to whatever… You would like a system as they record item after item they could mark an item were a FAA auditor should come and doublecheck without Boeing knowing they have marked an item as such to remove any pressure to compromise. (Better FAA than NTSB showing up…)

  4. The Door Plug glitch, appears to be human error at this point.
    According to the Preliminary NTSB report, 5 rivets needed to be fixed, requiring the door plug to be removed, and reinstalled at Boeing.
    ===
    https://data.ntsb.gov/carol-repgen/api/Aviation/ReportMain/GenerateNewestReport/193617/pdf
    ===
    This doesn’t appear to be like Boeing intentionally hiding information (the MCAS system) from the FAA as in the 737-MAX MCAS disaster, which cost Boeing Billions in fines and additional costs.
    ===
    https://www.justice.gov/opa/pr/boeing-charged-737-max-fraud-conspiracy-and-agrees-pay-over-25-billion
    ===
    The reason for the missing bolts, the FAA is still researching, and will be asking the actual personnel that did the door plug reinstall at a later date. How much human error vs bad procedure (does the procedure clearly describe the bolts being put in place etc) and does the QA sign-off procedure mention the bolts, will obviously be found out and hopefully suggestions on how to avoid this in the future. My wild guess is that the door plug reinstall procedure was being done, and then interrupted, either by a shift change or some other event, and the placement of the bolts was overlooked as being done, when it wasn’t. Any inspection of the door work being down properly by another sign-off QA inspector must also have overlooked the 4 bolts? I’m assuming at least two people had to miss the bolts not being in place, either by the procedure not clearly referencing the bolts, or two independent inspection events both not checking to see the bolts being in place?
    This assumes that the bolts were in place from Spirit, which the preliminary report seems to indicate.
    ===
    “There were some light circular
    witness marks around the hole bores consistent with the presence of a washer at some time.”
    ===
    “To open the MED plug, the two vertical movement arrestor bolts and two upper guide track bolts had to be removed.”
    ===
    It will be interesting to find out what actually happened. And where are the original bolts that Boeing took out out of the door to replace the rivets?

    • Boeing management has made the company the subject of political theater. The FAA cannot inspect Boeing back to health. Jack Welch destroyed GE; his acolytes are killing Boeing and its customers.

      • Think it was Jack’s successor who did the most damage, GE is doing much better now with new owners/executives. Orders/deliveries and stock price are rising, debt sinking from $70bn to $19bn. In a few years time GE could buy Boeing for cash…

    • RD:

      While good points the most likely reason this occurred was there was no triggering item from the CMS system.

      I don’t know what the process is for getting the door plug back in place from when its been moved out and is hanging on the brackets (I call it the maint position)

      Per ThrowawayBoeing employee, the failure was that the maint position did not trigger a CMS item that then required a mechanic to install and a sign off.

      In short, as far as the build process went, it never happened.

      I think anyone who has looked for traffic when they want to pull out and simply did not see a vehicle coming gets that part. If I did not see it I am going to pull out thinking nothing is there. And yes I had that happen and I have not explanation, it was 30 years ago. The other guy did a beautiful job in seeing me, moving into another lane. All him and not me.

      How that failure of process came to be is not known yet.

      The fact it was not caught is both a Boeing failure and an FAA failure.

      That is compounded or cause that the gap existed that should not.

      Bad rivets in a supposedly inspected and aproved Door Plug goes back some time per the report and nothing was done about it.

      That puts dysfunctional on the whole process. Boeing and Spirit should have caught it and corrected it.

      The FAA should have seen it and acted – first would be to contact Boeing and ask, what is going on here?

      It should then be a flagged item that is followed up on until corrected and an understanding of why it was occurring (and not getting flagged) all the way back to the exit plug mfg.

      We have one failure that in turn was fed by another failure and the failure is the trigger failure was never caught or acted on.

      A Spirit employee reported out of compliance drilling around the window. That is good they did.

      But where are the inspections that monitor that and why was it not reported both sooner and caught by the inspectors.

    • “And where are the original bolts that Boeing took out out of the door to replace the rivets?”

      A very good source , told LNA readers a few weeks back , its Spirit employees at Renton who do the rework on the fuselages as they move down the assembly line. The top level quality control software can only be accessed by Boeing employees. So it could be because Spirit were dealing with the physical fix the handover to Boeing once it was done showed gaps in who was responsible for what.

      However the idea that a plane that is completed is done 100% to spec is a myth, theres a whole string of ‘non conformities’ or deviations that are approved by the certifier that are on the records , even when its handed over to the customer

      • ‘However the idea that a plane that is completed is done 100% to spec is a myth, theres a whole string of ‘non conformities’ or deviations that are approved by the certifier that are on the records , even when its handed over to the customer’

        I wonder if there is a line on a check sheet, with the words:

        “Bolts on MID CABIN door plug, behind installed interior, missing and to be installed later”

        and a nice little box, where you can make an X to denote that those bolts are missing.

      • Duke is correct in that you don’t get a clean aircraft out of production.

        Much like coming out out maint, there is always stuff that was missed though all the important bits should of course be attached properly.

        Its why there are pre delivery tests to confirm its all working and if there are items not working, noted and corrected.

        Something as simple as a cooling fan can either not work or failed after tests done initially.

        If the Coffee pot does not work that is not an aircraft safety issue. It still needs to work.

  5. I sort of understand that the FAA would need a lot of people, to check everything themselves. However, the system in place really means that manufacturers are controlling themselves. Greedy managers will take shortcuts, Boeing is the best proof for that.
    What I find most puzzling now is that apparently the rest of the US aviation industry is subsidising Boeing, as their own certifications get delayed. Boeing should not get away so easily and pay a higher price for their malfeasance.

    • Matth:

      Its a pretty strange aspect as you point out.

      Do all ODA work the same?

      And as Leeham pointed out, its working in other areas, why is it failing in the Boeing arena?

      I believe ODA is a good way to address the needs and those inspectors are paid by the mfg.

      The FAA would be providing a point of contact and nittty gritty is how many ODA report to a given FAA emplyee?

      Those FAA employees are a resource that can be shifted and the mfg is not paying them. I assume there is a process that ODA people report to another FAA employee (vacations, getting sick or a longer term illness)

      I agree you don’t want to disrupt a system in place but the need is here for doing that.

      The big question is why its not working at Boeing? And what needs to be done to ensure it does?

      In some areas it seems to be working better, the 787 shim debacle and no deliveries for 2 years as well as a slower walk on the 777X and the -7/-10.

      In others like the failure to have a get the anti ice fixed ASAP has failed. Lots of -8 and -9 are flying with that ticking issue.

  6. Good article but does NOT go back far enough to DER system versus/change/incorporation to DER/DRM at pushing of Boeing around 2004 largely due to SPEEA strike which shut down deliveries. Harry and acolytes made sure that would NEVER happen again. And move to Chicago had to do with Dennis Hastert and friends. The short version is/was that Management got a few subtle ways to ‘assist’ the designee to make the “right” decision. Also notable was the background of a few major players at that time who had MCDouglas experience.

  7. Boeing QC did at least spot the dodgy rivets in the door plug after the original manufacturer and Sprit failed to do anything about it.Maybe the giant eyeball painted on the window was a sort of unofficial system being employed to note the missing bolts and wasn’t fully understood by new employees.
    Far more worrying is the possibility of hidden flaws which are very difficult to inspect. I once worked in a helicopter maintenance facility where someone snapped of a very long tap in a gearbox and just sawed off the bolt rather than reporting the practically impossible to remove broken piece,this was only spotted the next time the gearbox was stripped down and xrayed.Bae systems delivered a warship a few years back to the Royal Navy where (owing to a miscalculation)someone didn’t bother with bolts at all and just stuck bolt heads on with sealant

    • Yea, I worked on a Oil Field Service ship (built in the US but last area of ops had been Singapore). Leaks in the heat exchanger that had been brilliantly painted over. Stopped the leak long enough to get it well on its way back to the US.

      The wing cracks in the A380 were found due to the Qantas engine blow up and they saw them because that area was wide open when it would be D check before it would have been looked at.

      If someone is going to deliberate do something, if they can make it look good enough you may not be able to catch it.

      It seems like Boeing had more than enough rivet issues that there should have been a back track to find out why and that did not occur nor did the FAA catch it.

      Its like Dr. Resaons Swiss Cheese had 3 pieces of cheese the holes line up for. That is shocking. It should not be able to happen.

  8. Last month BA delivered 27 aircraft, including 25 737 MAX.
    “It said customers it did not identify canceled orders for two 737 MAX while Spanish carrier Air Europa canceled an order for one 787 Dreamliner.”

    • While we are drifting somewhat off course here, its worth noting the Thai order for the 787s has resulted in Thai dropping the RR engines and going with GE.

      That will be the third carrier I know of that was a former RR enthusiast to dumping them.

      • Whereas other carriers apparently have no trepidation in ordering the A350: Qantas, AF-KLM, Turkish,…

        There’s a difference between a non-order and a cancellation.
        It may (at last) be occurring to some BA customers that they’re just never going to receive the aircraft that they ordered.

        • I wonder what the *actual* Boing MAX-7, MAX-10,
          and 777-X EIS dates will be, when all is said and done. Didn’t the MAX-7 first fly quite a few years ago?

          • Don’t hold your breath as regards the certification of the MAX 7/10. I suspect that it’s going to take years to get that nacelle overheating problem properly sorted out, now that exemptions are (temporarily) off the table. Just look how long the synthetic AoA sensor in the MAX 10 is taking to get greenlighted: remember that EASA *requires* all MAXs in Europe to be retrofitted with this sensor, and there’s still no sign of that happening. Even if the rest of the MAX 10 airframe can’t be certified, don’t you think that at least the sensor could be expedited? Nope…zero progress on that front.

            And how long has the 777X been waiting on a TIA — which is the *first* step toward formal certification? There’s a test frame flying around, but it just can’t seem to convince the FAA that the airframe design is now sufficiently mature to merit a TIA. It amazes me that Tim Clark can complain about the hot-weather performance of the RR Trent, while seemingly overlooking the fact that the 777Xs that he has on order don’t even have a TIA!

            https://aviationweek.com/shownews/dubai-airshow/boeing-outlines-777-9-certification-test-plan

          • MAX-7 was the platform to validate and certify the MCAS Mk2 stuff.
            I was surprised at the time …
            … that it was used at all ( OK, the short 7 should show the more pronounced underlying issue )
            …. that a not yet certified sub-type was deemed acceptable.

  9. Under Previous ODA, the employee reported to the FAA, not to Boeing.

    While not a solution by itself, it does get the employee out of the conflict cross hairs.

    That change was pushed by Boeing.

    Boeing should never be allowed to set the standards for new tech (the 787 battery debacle, reading it makes you want to cry). The FAA failed to stand up to that (after the burn ups it was given to the RTC (Radio Technical Committee) to come up with real tests and standards.

    I don’t buy 3rd party. The FAA may well need more people but it needs the direct link into the ODA designee’s so it can manage the process.

  10. Ooooh. This is a long one. Sorry. (:-/)

    First of all, the Alaska door plug is a manufacturing issue. The FAA oversees manufacturing. The FAA also oversees certification, which is what ODA is all about.

    The entire topic of ODA relates to certification, which is largely a design issue – very important, but not directly related to the door plug. The common thread between ODA and the door plug is Boeing leadership’s message on what kind of problem-solving culture they want to have. Everything flows from that.

    That said … the description of ODA in this article differs from my understanding of the history and operation of Boeing’s ODA. In particular:

    Prior to ODA, the FAA delegated authority to about 400 Designated Engineering Representatives, DERs, at Boeing.

    In this system, DERs were hand-picked by the FAA based on a history of trust and confidence in those individuals. In addition, each DER had a close technical relationship with an FAA certification engineer.

    DERs and their corresponding FAA engineer would meet in the workplace, go over designs and procedures, then review any tests, relevant data, drawings, interdependencies, and interpretations of the applicable Rules. This system had much greater resistance to “undue pressure” from design and production managers and better insulation from delivery schedule pressure. None of that happens under ODA.

    ODA emerged as part of the Reagan era political shift to smaller government, privatization, and deregulation. Congress mandated that the FAA delegate more authority to industry. Similar Congressional mandates applied to the FDA, SEC, Department of Agriculture for food inspection – “Get out of the way of business and let markets solve our problems.”

    The FAA delegates authority to the ODA as an organization. The basis for the delegation is a history of trust and confidence IN THE ORGANIZATION. The ODA chooses individual Authorized Representatives, ARs, who serve the function played earlier by DERs. The FAA can comment on ARs, but cannot approve them, nor disapprove ARs, nor can the FAA remove an AR for poor performance. AR’s answer to Boeing managers. Most ARs don’t know their FAA counterpart, may never have met their FAA counterpart, and typically do not have a technical relationship with their FAA counterpart.

    Under ODA, ARs may raise certification issues, which then get reviewed and possibly resolved by [Boeing] managers in the ODA, who may otherwise communicate with managers at the FAA, who would then involve FAA engineers [or not]. In the end, the AR and the FAA engineer rarely, if ever, communicate directly.

    Furthermore – and this one astonished me – the ultimate oversight provided by the FAA is to confirm that each certification test [or “finding of compliance”] required under the overall certification plan has been filed. This is purely procedural – “Do you have a finding of compliance” for each required step in the certification test plan?

    Over time, features within Boeing’s ODA slowly evolved, if that’s the right word. Project Administrators were originally responsible for technical coordination, and were expected to protect ARs from program pressure. That role gradually diminished, in parallel with erosion of lateral communication and coordination across technical functions. This had the effect of isolating ARs within the engineering community. I would nominate MCAS as a poster child for what goes wrong in that kind of engineering problem-solving culture.

    Both the DER and ODA systems are susceptible to “DER/AR shopping” where a manager who is disappointed with a certification outcome, can look for an alternative expert who is more sympathetic. Such shopping is much easier under Boeing’s ODA, since Boeing appoints ARs, Boeing interprets the qualifications to be an AR, and ARs have very little recourse to such pressure, compared to options that had been available to DERs.

    I am VERY skeptical of efforts to fix the ODA system. The attributes that made it politically attractive are exactly the attributes that make it susceptible to failure.

    If Senator Cantwell and Senator Duckworth want to revisit how Congress wants the FAA to delegate authority, I am all for it. Congress needs to say what the FAA should do. We got into this mess because the FAA has BEEN DOING what Congress wanted it to do.

    • Thanks very much for this deep-context comment.

      As an aside- pointedly underfunding Federal agencies-
      then further cutting their budgets when they can’t adequately do their jobs as a result of said cuts-
      precedes the Reagan Administration by a quite a ways,
      being in full swing during the Carter Administration
      and even before.

      Neoliberal hollowing-out has been a duopolistic, long-term project in This Great Nation.
      Our Rulers are doing great, though..

    • @Stan

      You stole my thunder but thank you for your clarifications on how things function at Boeing re: AR’s and ODA.
      I agree with you that with the Senator’s calling for refinement is pure political theater. I do agree that the FAA does need to have active involvement with how these people are selected.

      My last three years at Boeing I worked aviation safety and was in many meetings with the FAA. Where there problems with the ODA? Yes for sure, mainly with the ‘undue pressure’ requirements called for in the CFR. AR’s sometimes as well. Boeing cleaned this up after LOI’s from the FAA before the accidents in 2018 and 2019. You are correct these functions are selected, report to and paid by Boeing, but their sole responsibility is too the FAA. They work for the FAA foremost. Their Boeing badges actually say ‘FAA Rep’ on them.
      In 2019 the FAA audited the ODA organization and found many that technically were not qualified to fill the roles i.e. not certified airmen.

      My experience with the AR’s that I worked with was phenomenal and highly experienced engineers in their respective area. Does this mean there aren’t problems? Of course not. But after MCAS the FAA oversight grew exponentially and still remains today.

      Finally, addressing ODA and AR’s is a small step and I’m sure it’s functioning pretty good now. But focusing on this solely won’t address the lack of quality inspections and oversight…. Where most of us know the crux of the problem is.

      • Airdoc/Stan S:

        You guys really fill in those day in day out details.

        I have a question in regards to the ODA and per Airdoc.

        The quality failures have clearly been on going, if the contributer was right then at least a year.

        From a non aircraft mechanic or involved in that industry as much as I follow it, how does that relate to the ODA and AR working?

        From my perspective, its seems its failing at least in Renton.

        I more than agree you can’t inspect your way out of the problem, but I would have thought those would have been caught and Boeing forced to address it.

        So fully agreed at the heart is a management failure both at the Board and Executive levels.

        To me if it was working right those failures would have been caught, the FAA would have slowed down the line until they had or felt they had a handle on it.

        But changing the attitude that got Boeing to where it is has to start at the top. As you go down the chain there may be a bit of wiggle room but very little, they crush you.

        Something happened in Charleston that did not happen in Renton.

        A while back NASA made a comment that they thought they needed to keep a close eye on Space X because they were new at it, they thought Boeing knew better and we have seen how that turned out.

        • @TW

          Something that’s very important to keep in mind.
          The quality failures don’t have much to do with the ODA and especially the AR functions.
          These failures are clearly the fault of mgmt.. period to your point.

          The AR job is airplane specific certification to ensure they meet the CFR’s for a specific purpose as designed.
          The ODA is airworthiness.
          The FAA technically took over the airworthiness portion about 3 years ago and they still control it directly today for 737, not sure about 787.
          It’s a conundrum whereas the Boeing ODA’s technically work for the FAA yet the FAA doesn’t trust them. This is what self delegation gets you if it’s mismanaged.
          The implied trust was broken after the accidents and now post ASA1282 door plug.

          The ODA’s rely heavily on the quality personnel to tell them the airplane is ready to ticket.. it’s a cursory look over of the jet but the devil is in the paperwork details that the build is in compliance with all applicable engineering drawings. If all is in compliance the airworthiness ticket is issued. This document is posted on every jet/airplane as you enter the door… take a look at it sometime.
          The same works for the STC ODA world.

          Hope this helps.

          • Airdoc:

            It does sort of. I am famiar with the document, we had it in flying smaller aircraft and it was a common work document (Elevator Cert, Boiler Cert).

            The area I don’t get at all is the lack of action by anyone on on going failures like the various rivets.

            Its not that things like that don’t happen, people are not perfect and you are going to do a task like Rivets slightly wrong from time to time.

            I would hope that is a flag item in the paperwork, which then should get to a report to the FAA person in that chain of monitoring.

            I would think (silly me?) that something like a process gap would be caught as well.

            It continues to be mind boggling so much was missed that got to the Door Plug eject.

            Certainly where there is increased scrutiny a gap like that should stand out as a glaring light.

          • TW

            Nope. Some of these jets as they go thru the build process could have over 400 non conformities (doesn’t meet type design) then there are normal QA ‘pickups’ (Boeing slang for defect) for example a torn seat cover or a minor paint touch up… they can be in the hundreds. Now add in flight squawks as the crews test fly them for various reasons.
            It’s the quality management team that manages all this ensuring engineering dispositions are accomplished for non conformities, customers notified, flight sqawks addressed and bought off by the engineering test pilots. All pickups addressed.
            The jets coming out of storage is a huge paperwork issue alone.
            So in the end do the ODA’s worry about this, such as mis drilled rivets or a door plug removed? uh possibly. But they trust the paperwork system. That is quality job and manufacturing as well to ensure it’s completed. So at the end of the day the ODA when called looks this all over… just to ensure all the i’s are dotted and the T’s crossed. It’s impossible for them to look at everything and frankly that’s not their job.

            It’s not perfect for sure.

          • This reminds me of the Hot Work Permit system. The manager would not fill it out.

            He tried to set the place on fire due to defective equipment and it was not dealt with by the Client manager. But by golly the paperwork looked good (as the crew would get fired if they did what he did).

            One area in all this would be where in the process a process step (left Exit Plug handled the same as a right) gets dropped? Or was it always a hole?

    • The problem with Politico’s are they are political.

      I am less than impressed with Cantrel and Duckworth as both are saying things to both sides and they were not

      Where were they before this happened?

      • @TW In my experience, Cantwell and Duckworth are sincere. Cantwell can be very tough. Duckworth flew helicopters and lost both legs in combat. I can see why Calhoun folded after talking to her.

        • Stan:

          Unfortunate but all Policals have an iron in the fire to stay in their positions.

          John McCain military service and his conduct as a prisoner was beyond laudable.

          His politics end was not including a close link with Airbus.

          I fully respect Duckworth and her service and what she sacrificed for her country in that service. Unfortunately that then turns to politics and you have to give up your integrity to do so (which is what one very honest guy I worked with said, they make a liar out of you, check your integrity at the door).

          So no, I don’t give anyone in political arena a pass. I may think a person or a party policy is better but they all become beholden to money and its not us that has the money.

    • ‘A total of 735 commercial aircraft were delivered (2022: 661(1) aircraft), comprising 68 A220s, 571 A320 Family, 32 A330s and 64 A350s.’

      This is from 2019, when they hit their delivery high water mark:

      ‘A record 863 commercial aircraft were delivered (2018: 800 aircraft), comprising 48 A220s, 642 A320 Family, 53 A330s, 112 A350s and 8 A380s.’

      About 130 deliveries off that year, which was before all the issues.

      Not too bad at all.

      • A couple of notes on that.

        The A220 should be added into a lump single aisle group with the A320 series.

        And while an average is not a good metric for an increasing production it does frame things a bit and Airbus monthly average for the A320 series would be 48 (rounded up ) and A220 at 6 (rounded up) a month.

        So at least a rate of 54 Single Aisles a month.

        I keep seeing the desire for 2026 at 75 x A320 series a month but that skips a couple of years as to what the attempted ramp up actually is.

        And the start of the year slump skews the figures as well.

        • “And the start of the year slump skews the figures as well.”

          same for the supersize December numbers.
          We could “unskew” production figures by looking at a multi year 12month profile …

          first order fix probably is lumping adjacent December and January together and log the average for both.

          Can I find the per month numbers anywhere easy?

          • Uwe:

            I don’t have a link to it as I look it up when I want a snapshot and that is intermittent.

            As noted , Airbus delivered 68 x A320 series in Dec and then dropped to 30 for January.

            Using the average smooths that out but misses by at least a few with a ramp up going on and the figures changing from month to month.

            Airbus numbers for Feb will be interesting to see if they hit the average and over the end of the year hangover, or they still are working back up to a more steady number (or an increasing one)

            Boeing of course is stalled and its going to be 4-6 months as it plays out after they shot themself in the4 foot once again and vastly worse, had a perilously close escape from a crash for 177 passengers (not sure if that includes crew)

  11. @Stan Sorscher: «ODA emerged as part of the Reagan era political shift to smaller government, privatization, and deregulation. »

    The same thing could be said of Margaret Thatcher who adopted a similar political doctrine during the same period, but we only see the detrimental effects it had today. She privatized railroads, energy and water, to name a few service sectors, and all of them underperform today: Trains are now more expensive and the service is awful, many people cannot afford to warm or cool themselves properly, and they often drink sewage contaminated water. The rich are happy because they got richer but the poor are now miserable.

    What Reagan and Thatcher did was initially beneficial for their respective countries but made long-term damage that will be very difficult to repair. At Boeing the Reagan-Thatcher emulators were Condit-Stonecipher. Over a relatively short period of time they made investors happy but ultimately destroyed the company and its reputation.

  12. The number of DERs in the past few decades has plummeted, as the FAA has emphasized ODAs to the detriment of DERs.

    I hope this is reversed. The DER approach works well, and is much better suited for supporting actual innovation.

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