By the Leeham News Team
Analysis
Feb. 21, 2024, © Leeham News: In part one, LNA looked at the Organization Designation Authorization, more commonly known as the ODA, what it is, and why it is so important to industry.
The ODA is an organization that is granted the privilege to operate as the Federal Aviation Administration (FAA) on selected work package types. ODAs are composed of “unit members,” the FAA term for people doing ODA work.
Boeing and many other aerospace companies in the US use ODAs. Airbus uses similar people under a different designation issued by EASA, Europe’s regulator. Boeing’s ODA authority was restricted by the FAA in the aftermath of the 737 MAX crisis that led to the 21-month grounding of the global fleet.
The FAA is reconsidering Boeing’s ODA authority.
There are two types of unit members: Designees and others who do ODA work without formal FAA signature authority.
Credit: Federal Aviation Administration.
An example of how a Type Certification (TC) ODA organization uses these two different talent pools can be seen through the Certification process where detailed analysis done by the group is approved (signed off) by an ODA unit member who is a Designee. The FAA suspended Boeing’s “ticketing authority” for the 737 and 787 following the MAX crisis and quality concerns on the 787 production line. Ticketing authority is one ODA mission.
Boeing’s ODAs
Boeing currently has four ODA types: Major Repair and Alterations (MRA), Production Certificate (PC), Supplemental Type Certificate (STC), and the TC. Boeing’s ODAs dwarf the industry in size, volume of work, and complexity of work.
Part of the FAA’s problem with Boeing is that Boeing’s innovations drive leading-edge rule-making. The FAA’s bench isn’t deep enough to do a great job on new technology.
Take, for example, the Boeing 787 battery fires early in that program. The FAA didn’t inject a fire protection/containment specification into the “electric jet” when the original TC was issued. The people on the program missed it. The FAA missed it, too, because their people were a step behind Boeing. This isn’t peculiar to Boeing. Some manufacturers push their technology beyond the feds, but their ODAs respect the process and the FAA has had great successes there.
The second part of Boeing’s ODA process woes appears centered on the fact that the number of full-time ODA unit members is a small fraction of the ODA unit. When those “part-time” ODA unit employees aren’t working an ODA package, they are working Boeing’s normal work packages. This fractionalization of the management reporting sets in place the ability for Boeing to exert pressure on the employees by the non-ODA management chain which has the bulk of the say-so in the employee’s performance reviews and compensation. There have been internal complaints about pressure and criticism from outsiders about the conflicts of interest, whether real or perceived.
The third part of the Boeing ODA management problem is the inability of Boeing’s leaders to drive a top-down change in the culture. Critics charge that Boeing appears to give lip service to Boeing’s code of conduct. The first three items listed, if followed, could have left Boeing in a far better place than they are today.
- I commit that: I will comply with all applicable laws, rules, and regulations. If I do not understand them, I will seek guidance.
- I will prioritize safety, quality, and integrity above profit, schedule, or competitive edge. If I see something that raises a safety concern, I will speak up immediately.
- I will engage all regulators—including employees who act under delegated authority—and customers with candor, transparency, and respect at all times.
Fixing the ODA system
So how is this fixed?
The country needs its #1 exporter to get healthy and deliver planes. The supplier base needs to have stable work that a healthy Boeing can supply. Airlines need product and the flying public needs safe airliners to restore their faith in flying.
It comes down to creating a Third Party Boeing ODA unit. This is an exceptionally difficult thing to do. The FAA’s thin bench is an industry problem. There is a void in qualified ODA unit managers industry-wide. These can’t be created overnight, and even if they could, they would need time to get up to speed.
Boeing’s ODA units could function as designed if a way can be found to prevent the undue pressure on ODA unit members. This is a specific people problem. About the only way out is to hire consultants to do the ODA management tasks.
A Modest Proposal.
ODA Management skillsets necessary to get Boeing back on track only exist inside other ODA units at other companies. Boeing’s ODA cannot be fixed overnight, but a safety net can be erected by turning over the day-to-day ODA management to an already existing Consulting ODA.
If a Consulting ODA is interposed inside the Boeing ODA, separating Boeing’s managers from positions where they can exert undue influence on ODA unit members, Boeing’s ODA gets healthy almost immediately.
This gives Boeing’s ODA unit time to get its act back together, but more importantly, allows Boeing’s culture time to return to a trustworthy state. This gives the FAA the arm’s length relationship it needs to be a true regulator and should satisfy Congresses lingering fears about the Agency’s overly close relationship with Boeing.
Few candidates, however
A look through the existing ODA directory shows few candidate Consultant ODAs that may be positioned to do this. If the FAA could place one of these existing ODAs inside Boeing’s ODA with full ODA oversight, immediate changes in the operations could be expected. The FAA would now be listening to a consulting ODA instead of Boeing directly, restoring the arm’s length relationship demanded by Congress.
The FAA could direct the consultant to drive their needs back through Boeing. It solves the problem of standing up a new company from scratch. Boeing would be on the hook for the cost of the surveillance, but one would expect this path to be among the most efficient choices out there.
The FAA can direct the Consultant ODA to make changes instead of directing Boeing. This is not simple, and it would be a lot of work, but understanding the complexities and sheer size of the problem makes this seem like the path of least resistance to a place where the public trust and safety focus can begin quickly.
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