Insiders Share Tips on Creating a Positive Rapport With FAA Inspectors

Be prepared. Be nice. Above all, be professional. These are the keys to building and maintaining a good relationship with the people at the FAA – which is critical to any business aircraft operator.

FAA inspectors are “not there to make your life easier for you,” said David Norton, partner and head of aviation practice at Shackelford, McKinley & Norton, LLP, in Dallas. “They’re there to keep the flying public safe. They have a very difficult job, and they’re understaffed. They’re not going to spend time correcting your mistakes.”

Norton and another subject matter expert, Keith Allen, director of training & standards at Overland Park, KS-based Airshare, offered a few general tips for operators to keep in mind:

• “First impressions are important,” Norton said. If you make a bad one, primarily by not being knowledgeable and professional, “it’s going to be really hard to dig out of that hole.”
• “Know what the rules are,” Norton said, “both as they apply to you and what FAA will follow.”
• “Do your homework and be sensible,” said Allen. “Have a plan of action. Don’t be afraid. As long as you’re willing to be cooperative and work with the FAA, you’ll be OK.”

Where to Find the Procedures

The agency has made the procedures its safety inspectors need to follow when overseeing general and commercial aircraft operators clear. Those procedures are found in FAA Order 8900, referred to by the acronym FSIMS (for Flight Standards Information Management System), and at the FAA’s Dynamic Regulatory System (DRS) – a comprehensive online resource containing all regulatory guidance material from the Office of Aviation Safety.

DRS comprises a database of over 2 million regulatory guidance documents comprising more than 65 types from a dozen repositories, with pending, current and historical versions of all of them along with their revision history, updated every 24 hours.

FSIMS is the backbone of “the procedures they have to follow,” Norton said, giving FAA inspectors guidance “on how to interface with the regulated party.”

FAA inspectors, in other words, are subject to as many restrictions as operators, so well-versed operators should also familiarize themselves with FSIM guidance aimed at inspectors and other agency personnel.

Engagement and Trust

Allen said the agency has come to recognize – and recognized formally nearly a decade ago – that there was excessive confrontation between operators and regulators.

Now, the FAA puts emphasis on positive concepts such as engagement, root-cause analysis, transparency, information exchange and trust. “Our approach to compliance stresses a collaborative problem-solving approach,” the agency said, “where the goal is to enhance the safety performance of individuals and organizations.

“An open and transparent exchange of information requires mutual cooperation and trust that can be challenging to achieve in a traditional, enforcement-focused regulatory model,” FAA said.

Considering Honest Mistakes

The agency also describes its approach to compliance as one that furthers an evolution toward a “just culture.”

“A ‘just culture’ allows for due consideration of honest mistakes… But even unintentional errors can have a serious adverse impact on safety, so we must ensure that the underlying safety concern is fixed every time.”

Read more about “just culture” on the FAA Compliance Program website.

In addition, Allen said FAA inspectors “are focused on education.”

He also pointed out that agency examiners themselves are subject to oversight. Operations inspectors, for example, are required to maintain a 90-day pilot-in-command currency. So, it’s in an examiner’s interest to follow procedures that are clearly set out in the DRS.

Allen – a former FAA inspector – remembers a check flight where a pilot for a Part 135 charter operator undergoing review returned to the hangar before the multiple examination points were met. An engine-out test was not performed.

“I had my checklist,” Allen said. “He had no plan of action.” The point: have a plan of action.

Distributing the Workload

Keep in mind that, in the wake of the pandemic, the FAA has shifted to a distributed system allowing agency FSDOs (Flight Standards District Offices) to begin certifying an operator even if that operator is located elsewhere.

With nearly 80 FSDOs nationwide, operators might consider requesting insight on FSDO workload – if it starts taking longer to receive required documents. Also consider exploring the possibility of asking the local FSDO to share their work with other FSDOs to expedite document processing.

Overall, it’s important to remember that FAA inspectors are public servants. Understand what their job is and what their responsibilities are. “If you make life easy for your safety inspector,” Norton said, “you have a better chance of getting what you need.”