a

GAO

United States Government Accountability Office

Report to the Ranking Democratic 

Member, Subcommittee on Aviation, 

Committee on Transportation and 

Infrastructure, House of Representatives

October 2004 AVIATION SAFETY

FAA Needs to 

Strengthen the 

Management of Its 

Designee Programs

GAO-05-40
www.gao.gov/cgi-bin/getrpt?GAO-05-40.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact JayEtta Z. 

Hecker, (202) 512-2834, heckerj@gao.gov. 

Highlights of GAO-05-40, a report to 

Ranking Democratic Member, 

Subcommittee on Aviation, House 

Committee on Transportation and 

Infrastructure 

October 2004

AVIATION SAFETY

FAA Needs to Strengthen the 

Management of Its Designee Programs 

The safety of the flying public and 

the reliability of the nation’s 

aircraft depend, in part, on the 

Federal Aviation Administration’s 

(FAA) regulation and certification 

of the aviation industry. FAA 

delegates the vast majority of its 

safety certification activities to 

about 13,600 private persons and 

organizations, known as 

“designees,” which are currently 

grouped into 18 different programs. 

Among other tasks, designees 

perform physical examinations to 

ensure that pilots are medically fit 

to fly and examine the 

airworthiness of aircraft. 

GAO reviewed (1) the strengths of 

FAA’s designee programs, (2) the 

weaknesses of those programs and 

factors contributing to those 

weaknesses, and (3) potential 

improvements to the programs. 

GAO recommends that FAA: (1) 

establish a program to evaluate all 

designee programs, giving priority 

to those programs that have not 

been evaluated, (2) develop 

mechanisms to improve 

compliance with existing designee 

oversight policies, and (3) upgrade 

its databases to provide complete 

and consistent information on all 

designee programs and the extent 

to which oversight is occurring. 

FAA officials generally agreed with 

our recommendations, but 

expressed concerns about our use 

of an expert panel to identify 

weaknesses in the programs. 

The key strength of FAA’s designee programs is their ability to leverage 

agency resources. Allowing technically qualified individuals and 

organizations to perform 90 percent of certification activities enables FAA to 

better concentrate its limited staff resources on the most safety-critical 

functions, such as certifying new and complex aircraft designs. For the 

aviation industry, designee programs enable individuals and companies to 

obtain required FAA certifications—such as approvals of aircraft designs—

in a timely manner, thus reducing delays and costs to industry that might 

result from scheduling direct reviews by FAA. For example, officials from 

Boeing told us that using designees has added significantly to the company’s 

ability to improve daily operations by decreasing certification time. 

Inconsistent FAA oversight and application of program policies are key 

weaknesses of the designee programs. FAA headquarters has evaluated only 

6 of the 18 designee programs over the last 7 years. FAA conducted the 

evaluations on an ad hoc basis and lacks requirements or criteria for 

periodically evaluating these programs. FAA uses these evaluations to 

determine whether designee programs are complying with agency policies. 

In addition, FAA field offices do not always oversee designee activities 

according to agency policy. For example, a recent FAA study found that 

inspectors were not reviewing designated pilot examiners’ work on an 

annual basis as policy requires. Potential reasons for inconsistent oversight 

include (1) incomplete databases that FAA uses to manage its oversight of 

designees, (2) workload demands for FAA staff that limit the time spent on 

designee oversight, and (3) the lack of adequate training for FAA staff who 

oversee designees. While we did not find a direct link between inconsistent 

oversight of these programs and specific safety problems, the lack of 

consistent oversight limits FAA’s assurance that designees perform their 

work according to federal standards. 

Opportunities exist for FAA to improve (1) program oversight to ensure 

consistent compliance with existing policies by FAA staff and (2) the 

completeness of databases used in designee oversight. For example, FAA 

could evaluate more of its field offices and designees—efforts modeled 

partly on the assessments conducted by some FAA regional offices—to 

ascertain the extent to which policies are being followed. 

Aircraft Undergoing Certification at Organizational Designee Facility 
Page i GAO-05-40 Designee Programs

Contents

Letter 1

Results in Brief 3

Background 6

Designee Programs Leverage FAA Resources and Provide Industry 

with Timely Certification Reviews 12

FAA’s Lack of Consistent Oversight of Designee Programs Is 

Affected by Incomplete Data, Workload Demands, and Lack of 

Training 15

FAA Has Potential Opportunities to Improve Designee Programs 34

Conclusions 39

Recommendations for Executive Action 41

Agency Comments 41

Appendixes

Appendix I: Objectives, Scope, and Methodology 45

Appendix II: Experts Participating on GAO’s Panel 51

Appendix III: Roles and Responsibilities of Designees 53

Appendix IV: Survey Instrument and Results 55

Appendix V: GAO Contacts and Staff Acknowledgments 68

GAO Contacts 68

Staff Acknowledgments 68

Bibliography 69

Tables Table 1: Comparison of Designee Programs Administered by Three 

FAA Offices 10

Table 2: Experts’ Ranking of Top Strengths of the Designee 

Programs 12

Table 3: Experts’ Ranking of Top 5 Oversight Weaknesses 20

Table 4: Experts’ Ranking of Top Ways to Improve FAA’s Designee 

Programs 36

Table 5: Organizations Interviewed by GAO During Site Visits 46

Table 6: The Number of Panelists Participating in Each Phase and 

Response Rate 50

Table 7: Experts’ Responses to GAO’s Survey 55
Contents

Page ii GAO-05-40 Designee Programs

Figures Figure 1: FAA Offices That Manage the Different Designee 

Programs and Numbers of Designees (as of May 2004) 7

Figure 2: Designees Support FAA Throughout the United States 14

Abbreviations

AME Aviation Medical Examiner

DAS Designated Alteration Station 

DER Designated Engineering Representative

DOT Department of Transportation

DPE Designated Pilot Examiner

FAA Federal Aviation Administration

GAO Government Accountability Office

NVIS National Vital Information Subsystem

ODA organization designation authorization

PTRS Program Tracking and Reporting Subsystem

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. It may be reproduced and distributed in its entirety without further 

permission from GAO. However, because this work may contain copyrighted images or 

other material, permission from the copyright holder may be necessary if you wish to 

reproduce this material separately.
Page 1 GAO-05-40 Designee Programs

United States Government Accountability Office

Washington, D.C. 20548

A

October 8, 2004 Letr

The Honorable Peter A. DeFazio

Ranking Democratic Member

Subcommittee on Aviation

Committee on Transportation and Infrastructure

House of Representatives

Dear Mr. DeFazio:

The safety of the flying public and reliability of the nation’s aircraft 

depends, in part, on the Federal Aviation Administration’s (FAA) regulation 

and certification of the aviation industry. Although FAA staff perform many 

activities crucial to maintaining the safety of air transportation, since the 

1920s, FAA has depended on congressionally authorized designee 

programs to help the agency ensure that the aviation industry meets certain 

safety standards. FAA’s designee programs authorize about 13,400 private 

individuals and about 180 organizations nationwide, known as “designees,” 

to act as representatives of the agency to conduct many safety certification 

activities, such as administering flight tests to pilots, inspecting repair work 

by maintenance facilities, conducting medical examinations of pilots, and 

approving designs for aircraft parts. These designees are currently grouped 

into 18 different programs and are overseen by three FAA offices—Flight 

Standards Service, Aerospace Medicine, and Aircraft Certification 

Service—all of which are under the Office of the Associate Administrator 

for Regulation and Certification. Given the vastness of the U.S. aviation 

industry, designees enable FAA to carry out thousands of certification 

functions each year. FAA staff1

 are responsible for overseeing the work of 

individual designees and ensuring that organizational designees (also 

referred to as “delegations”)—companies such as repair stations that have 

been delegated the authority to perform inspections of aircraft that have 

undergone major repairs—have systems in place, including staff and 

procedures, to perform the delegated functions. Organizational designees 

are responsible for overseeing their employees who perform the delegated 

functions. Based, in part, on congressional direction, FAA plans to change 

its designee programs within the next several years so that the agency can 

rely more on organizational rather than individual designees.

1

Those staff are safety inspectors in Flight Standards Service, engineers in Aircraft 

Certification Service, and flight surgeons in Aerospace Medicine.
Page 2 GAO-05-40 Designee Programs

In response to your request, this report addresses the following questions: 

(1) What are the strengths of FAA’s designee programs? (2) What are the 

weaknesses of the programs and the factors that contribute to those 

weaknesses? and (3) What can be done to address the identified 

weaknesses or otherwise improve the programs?

To address these questions, we obtained and analyzed information from a 

variety of sources. We identified 62 aviation experts with knowledge and 

expertise in FAA’s designee programs, who participated on a Web-based 

panel that provided the group’s views on the strengths and weaknesses of 

the designee programs and ways to improve the programs. An initial list of 

experts was identified through referrals by FAA officials, the National Air 

Traffic Controllers Association, the Professional Airway System 

Specialists, and the Aerospace Repair Station Association and through 

citations in the literature on aviation. We then asked these initially 

identified experts for additional experts. We continued this process until 

we had about 10 to 20 experts in each of four categories: (1) designees, (2) 

FAA inspectors and engineers, (3) independent experts and university 

academics, and (4) private sector and aviation industry associations. We 

obtained the experts’ views by employing an iterative and controlled 

feedback process for obtaining individual views and then allowing each 

participant to respond to the entire panels’ comments.

In addition, we obtained and analyzed information from FAA databases 

that maintain records on designees for fiscal years 1998 through 2003. We 

assessed the reliability of the databases and found the data sufficiently 

reliable for the types of analyses that we conducted for this report—

including nationwide analyses of the number of designees by program, the 

geographical location of designees, and the number of designees per FAA 

staff responsible for designee oversight. However, we found that specific 

data needed for oversight were not found in some databases, as we discuss 

later in this report. We also conducted semi-structured interviews with FAA 

officials, representatives of FAA inspectors and engineers who oversee 

designees, and designees in Seattle, Atlanta, Los Angeles, and Oklahoma 

City to obtain information on FAA’s oversight of designees. We also 

interviewed officials from Transport Canada (the Canadian civil aviation 

authority) to obtain descriptive information on their designee programs. In 

addition, we reviewed past studies of FAA’s use of designees by us, the 

Department of Transportation’s (DOT) Office of Inspector General, and 

others. We conducted our work from April 2003 through October 2004 in 

accordance with generally accepted government auditing standards. 
Page 3 GAO-05-40 Designee Programs

Additional information on our methodology and the experts who 

participated on our panel are found in appendixes I and II.

Results in Brief Designees perform more than 90 percent of FAA’s certification activities, 

thus greatly leveraging the agency’s resources. By permitting nearly 13,400 

technically qualified individuals and about 180 organizations to perform 

thousands of certification tasks each year, FAA officials believe that the 

designee programs allow the agency to concentrate on what it considers to 

be the most critical safety areas, a view shared by our panel of experts. For 

example, while designees conduct routine certification functions, such as 

approvals of aircraft technologies that the agency and designees have had 

previous experience with, FAA focuses on new and complex aircraft 

designs or design changes. In addition, the use of designees expands FAA’s 

access to technical expertise within the aviation community. For the 

aviation industry, the designee programs enable individuals and 

organizations to obtain required FAA certifications—such as approvals of 

the design, production, and airworthiness of aircraft—in a timely manner, 

thus reducing delays and costs to the industry that might result from 

scheduling direct reviews by FAA staff. For example, officials from an 

aircraft manufacturer told us that the use of designees has added 

significantly to the company’s ability to enhance and improve daily 

operations by decreasing certification delivery time and increasing the 

flexibility and utilization of company resources. In addition, designees are 

convenient to the aviation industry due to their wide dispersal throughout 

the United States.

FAA’s inconsistent monitoring of its designee programs and oversight of its 

designees are key weaknesses of the programs. For example, while FAA 

has evaluated 6 of its 18 designee programs over the last 7 years and has 

plans to evaluate 2 more, it has no plans to evaluate the remaining 

programs because of limited resources, according to a program official. 

FAA conducted these evaluations on an ad hoc basis usually at the request 

of FAA headquarters directors or regional office managers. The agency 

does not have requirements or criteria for periodically evaluating these 

programs. FAA uses these evaluations to determine whether designee 

programs are being carried out in compliance with agency policies. 

However, FAA has not implemented some recommendations from these 

evaluations. For example, a 2000 evaluation of designated alteration 

stations recommended that FAA establish a process to periodically assess 

the effectiveness and applicability of existing oversight policies concerning 

designated alteration stations and consider feedback from FAA field offices 
Page 4 GAO-05-40 Designee Programs

and designees as part of that process. The agency has not implemented this 

recommendation. In addition, we found that FAA field offices do not 

consistently implement agency policies on monitoring, selecting, and 

terminating designees. For example, inspectors in one region were not 

reviewing designated pilot examiners work on an annual basis and 

conducting oversight as required by agency policy. The primary goal of 

FAA’s standards and policies, and its oversight of designees, is the safety of 

U.S. aviation. While we did not find systematic safety problems associated 

with FAA’s oversight of designees, the agency’s inconsistent oversight limits 

its assurance that the designees’ work is performed uniformly in 

accordance with those standards and policies. Finally, we identified several 

factors that may have hindered FAA’s ability to systematically monitor the 

designee programs and consistently apply designee oversight policies. 

First, FAA’s oversight is hampered, in part, by the limited usefulness of 

some agency databases that are designed to capture information on 

designees. While all the databases have descriptive information on 

designees, such as their types of designations and status (i.e., active and/or 

terminated), the databases lack complete and consistent information on 

designees’ performance and do not provide a comprehensive picture of 

whether FAA staff are carrying out their responsibilities to oversee 

designees. Second, the workload demands on FAA staff may limit the time 

they spend on designee oversight. Finally, FAA does not require refresher 

training for all staff who oversee designees, thereby increasing the risk that 

some staff do not retain the information, skills, and competencies required 

to perform their oversight responsibilities.

Opportunities exist for FAA to address these weaknesses by improving (1) 

oversight of the designee programs to ensure consistent compliance with 

existing policies by FAA inspectors, engineers, and flight surgeons and (2) 

the accuracy and comprehensiveness of computerized information on 

designees so that the databases can be more useful tools for designee 

oversight. Those opportunities were identified by experts on our panel and 

our review of practices within FAA and procedures adopted by other 

countries in administering their programs. For example, FAA could more 

consistently conduct internal evaluations of its field offices and designee 

programs—evaluations modeled in part on the assessments performed by 

some regional and program offices—to ascertain the extent to which its 

policies and procedures are being followed. FAA’s internal review of 

designated pilot examiners in one regional office could provide a model for 

evaluations that could be performed by other FAA regions and for other 

designee programs. The review, which was based on (1) a comprehensive 

statistical analysis of designee activity in the region, (2) a survey of pilots 
Page 5 GAO-05-40 Designee Programs

who were tested by those designees, and (3) audits of designee files and 

surveillance reports by FAA inspectors, provided a reasonable method to 

assess program outcomes, identify the root causes of the lack of 

compliance with agency policy, and develop corrective action plans to 

address the root causes. Accurate, comprehensive data on FAA oversight 

and designee activities are integral to monitoring and evaluating the 

programs. The database used by FAA’s Office of Aerospace Medicine to 

monitor the activities and performance of aviation medical examiners 

provides information and uses that could serve as a model for the other 

offices—Flight Standards Service and Aircraft Certification Service—that 

lack comprehensive databases on designee activities. Although this 

database was designed to simplify the processing of airmen medical 

certification information, Aerospace Medicine uses it to extract 

information on the status of aviation medical examiners and monitor their 

activity levels. Careful consideration of such opportunities are important 

both because of the central importance that the designee programs hold for 

FAA as well as the agency’s plans to expand the use of organizational 

designees, which will further transform FAA’s role to that of monitoring the 

performance of organizations rather than overseeing the individuals who 

perform the certification activities. Transport Canada, which expanded its 

use of organizational designees in the late 1980s, identified the 

establishment of standardized oversight practices and frequent audits of 

Canadian designees as important components of its programs.

To improve management control of the designee programs, and thus 

increase assurance that designees meet FAA’s performance standards, we 

recommend that the Secretary of Transportation direct the FAA 

Administrator to establish a program to evaluate all designee programs, 

giving priority to those programs that have not been evaluated, and develop 

mechanisms to more consistently monitor and improve compliance with 

existing designee oversight policies, including identifying and sharing best 

practices among FAA programs and field offices. We also recommend that 

FAA strengthen the effectiveness of its designee databases by improving 

the consistency and completeness of information on designees activities 

and performance and FAA oversight. FAA officials generally agreed with 

these recommendations. However, the agency expressed concerns about 

our methodology for obtaining expert opinions of the designee programs. 

Further information is provided in the “Agency Comments” section of this 

report.
Page 6 GAO-05-40 Designee Programs

Background FAA has relied on designee programs since the 1920s to help the agency 

meet its responsibility for ensuring that the aviation industry meets FAA’s 

safety standards.2

 The programs authorize private persons and 

organizations, known as individual and organizational designees, 

respectively, to act on behalf of the agency to perform many activities to 

ensure the safety of air transportation. Of the nearly 13,600 designees 

nationwide, approximately 13,400 are individual designees and about 180 

are organizational designees, as of May 2004. These designees are grouped 

into 18 different programs and are overseen by three FAA offices—Flight 

Standards Service, Aerospace Medicine, and Aircraft Certification 

Service—all of which are under the Office of the Associate Administrator 

for Regulation and Certification. Figure 1 shows the 18 different designee 

programs, the number of designees, and the FAA offices that manage them.

2

Title 49, U.S.C. 447702(d) provides FAA’s legislative authority to use designees and Title 14, 

C.F.R., Part 183, sets out the types of designations FAA may issue and the process for 

selecting designees.
Page 7 GAO-05-40 Designee Programs

Figure 1: FAA Offices That Manage the Different Designee Programs and Numbers of Designees (as of May 2004)

Designees perform a large percentage of certification activities on behalf of 

FAA, such as determining whether aircraft designs, manufacturing, and 

maintenance meet specific safety standards and certifying the competency 

of persons that operate aircraft. FAA policy calls for the agency to delegate 

activities by evaluating the risk involved with such delegation; assessing 

whether the aviation industry has the experience to perform designated 

tasks; and delegating activities with defined standards, processes, and 

Office of

Flight Standards Service

Office of 

Aerospace Medicine

Associate Administrator for 

Regulation and Certification

Individual Designees

4,945 Aviation Medical Examiners

Individual Designees

1,269 Training Center Evaluators

1,140 Designated Pilot Examiners

762 Aircrew Program Designees

423 Designated Airworthiness 

Representatives (maintenance)

385 Designated Mechanic Examiners

40 Designated Parachute Rigger 

Examiners

33 Designated Aircraft Dispatcher 

Examiners

22 Designated Flight Engineer 

Examiners

2 Computer Testing Designees

Organizational Designees

47 Organizational Designated 

Airworthiness Representatives 

(maintenance)

12 Special Federal Aviation 

Regulations No. 36, Repair 

Stations

Individual Designees

2,725 Designated Engineering 

Representatives

1,249 Designated Manufacturing 

Inspection Representatives

359 Designated Airworthiness 

Representatives (manufacturing)

Organizational Designees

86 Organizational Designated 

Airworthiness Representatives 

(manufacturing)

31 Designated Alteration 

Stations

6 Delegation Option 

Authorizations

Office of

Aircraft Certification Service

Source: FAA.
Page 8 GAO-05-40 Designee Programs

oversight procedures. FAA policy also states that some tasks are not 

delegated. For example, FAA does not permit designees to make rules, 

conduct surveillance or enforcement activities against aircraft 

manufacturers and airlines, or issue and modify aircraft type and 

production certificates.

Individual and organizational designees’ roles and responsibilities vary 

according to program. For example, individual designees, such as 

engineering designees, evaluate whether aircraft designs meet FAA safety 

standards, designated mechanic examiners administer practical tests to 

mechanic applicants, designated pilot examiners administer practical tests 

to pilot applicants, and aviation medical examiners certify that pilots are 

medically fit to operate aircraft. Most individual designees can charge 

service fees to applicants. Most organizational designees perform similar 

activities as individual designees, but the organization holds the 

designation rather than the employees who work for them.3

 The 

organization is responsible for managing, overseeing, and training its 

employees who perform the delegated functions. Organizational designees 

must develop procedures manuals that describe how the organizations will 

comply with FAA requirements and describe their internal evaluation 

processes, including internal auditing procedures. An example of an 

organizational designee is a designated alteration station, which is a 

company that can issue supplemental type certificates, which are required 

for aircraft that have been modified from their original design. Further 

information on the roles and responsibilities of the various types of 

designees are presented in appendix III.

FAA policy calls for selecting and appointing designees based on several 

factors, including designees’ experience and qualifications, FAA field or 

program offices’ ability to oversee designees, and the need for particular 

types of designees. Although the selection and appointment policies and 

procedures differ somewhat for different designee types, these policies 

generally call for specific and thorough technical reviews of the designee 

applicants’ qualifications, including verifying the applicants’ work 

experience, testing the applicants’ knowledge and skills, and examining onthe-job performance. According to FAA policy, FAA officials or flight 

surgeons evaluate the applicants’ experience and qualifications and 

3

Such employees, who actually perform the delegated activities, are referred to as 

“authorized representatives.”
Page 9 GAO-05-40 Designee Programs

determine whether to appoint or deny the applicant’s request for 

designation.

FAA’s field and program offices are responsible for supervising, monitoring, 

and tracking designees’ activities to ensure that designees are performing 

their authorized functions in accordance with the appropriate regulations, 

policies, and procedures. FAA policy states that its inspectors, engineers, 

and flight surgeons should ensure the integrity of the designee programs by 

evaluating designee performance, interacting with designees on a regular 

basis, and evaluating technical data prepared by designees. For instance, 

FAA inspectors are expected to oversee designated pilot examiners by 

verifying their attendance at required training seminars and meetings, 

ensuring that they have developed and implemented a plan of action for the 

practical tests they conduct on pilot applicants, observing annually at least 

one practical test administered to a pilot applicant, and verifying that the 

designee has sufficient work activity to justify continuance of the 

designation. By comparison, FAA inspectors and engineers are expected to 

oversee organizational designees by ensuring that the organizations’ 

procedures manuals comply with FAA policies on approving the design, 

production, and airworthiness of aircraft and assessing the technical 

capabilities of the organization. In addition, FAA officials are expected to 

provide guidance and oversight of organizational designees by participating 

in many aspects of major approvals. For instance, FAA officials provide 

guidance and oversight for projects involving new aircraft design concepts 

and technology.

Most designees’ appointments are effective for 1 year, with the exception of 

individual and organizational designated airworthiness representatives, 

who are appointed for up to 5 years and all other types of organizational 

designees, whose appointments do not expire. FAA can terminate 

designees for various reasons, including insufficient work activity, 

unacceptable performance, lapse of qualifications, and lack of FAA need or 

ability to manage them. Designees can generally appeal FAA’s decision to 

terminate them, except when the decision to terminate has been based on 

FAA’s lack of resources to manage them. Table 1 compares aspects of 

designee oversight, including how designees are selected and terminated, 

among the three FAA program offices with designee responsibilities.
Page 10 GAO-05-40 Designee Programs

Table 1: Comparison of Designee Programs Administered by Three FAA Offices

Source: GAO analysis of FAA information.

a

Aircraft Certification Systems Evaluation Program evaluations were designed to determine if FAAdelegated facilities are complying with the requirements of applicable federal regulations and the 

procedures established to meet those requirements.

Program areas 

Office of Aircraft Certification 

Service

Office of Flight Standards 

Service 

Office of Aerospace 

Medicine

Designee selection Local FAA panel reviews designee 

applicants’ qualifications and makes 

appointment.

National selection board (National 

Examiner Board) reviews designee 

applicants’ qualifications and 

creates a list of qualified 

candidates.

Field office managers make 

appointment from the list of 

qualified candidates.

FAA regional flight surgeons 

review the qualifications of 

designee applicants and make 

appointments.

Designee oversight FAA inspectors or engineers are 

required to annually witness the 

performance of designees.

FAA is required to conduct a technical 

evaluation and an Aircraft Certification 

Systems Evaluation Programa

evaluation of delegated organizations 

every 2 years.

Organizational designees are required 

to perform and document selfevaluation activities.

FAA inspectors are required to 

conduct annual surveillance of most 

designees.

Organizational designees are 

required to perform and document 

self-evaluation activities.

FAA regional flight surgeons 

are not required to conduct site 

visits of designees, but are 

required to assess designee 

performance in order to renew 

authorizations.

Database used to 

monitor designees

Designee Information Network Program Tracking and Reporting 

Subsystem and National Vital 

Information Subsystem

Airmen Medical Certification 

Information Subsystem

Training for 

designees and FAA 

staff who oversee 

designees

Designees are required to attend initial 

indoctrination and refresher training 

every 2 years.

FAA staff are required to attend initial 

training in areas of specialization and 

take the Delegation Management 

Course. Refresher training is not 

required for staff.

Organizational designees are 

responsible for training authorized 

representatives who perform delegated 

functions.b

Designees are required to attend 

initial indoctrination and refresher 

training every 2 years.

FAA staff are required to attend 

initial training in areas of 

specialization. A specific training 

course on designee oversight has 

not been developed. Refresher 

training is not required for staff.

Organizational designees are 

responsible for training authorized 

representatives who perform 

delegated functions.b

Designees and FAA staff are 

required to attend initial 

indoctrination and refresher 

training every 3 years.

Termination of 

designees

Field office managers terminate 

designees.

Field office managers terminate 

designees.

Regional flight surgeons 

terminate designees.
Page 11 GAO-05-40 Designee Programs

b

Training covers such areas as functions delegated to the authorization, the organization’s processes 

and procedures, and FAA policy and guidance material.

FAA has proposed expanding the number of organizational designees and 

reducing the number of individual designees by creating an organization 

designation authorization (ODA) program. The ODA program would allow 

FAA to expand and standardize the approval functions of organizational 

designees and expand eligibility for organizational designees, including 

organizations not eligible under current FAA rules. Organizational 

designees under the current programs would be phased out during the first 

3 years of implementing the new program, and the organizational designees 

would be expected to reapply for an ODA. FAA issued a Notice of Proposed 

Rulemaking for the ODA program in January 2004. While FAA has received 

many comments in opposition to the proposed program including several 

that raise concerns that the proposed program would provide less specific 

and less technical oversight by FAA and would, over time, reduce the safety 

of the flying public, FAA has also received comments that the proposed 

program would improve the effectiveness of the agency’s oversight of 

designees.

In addition, FAA has been mandated to develop and implement a certified 

design organization program, which would affect some designees currently 

responsible for approving the design and production of aircraft, and 

aircraft parts and equipment.4

 Under this program, certain organizational 

designees that design and produce aircraft parts and equipment would no 

longer be designees, rather they would conduct their approval functions 

under a newly created FAA certificate. As a certificate holder, the certified 

design organizations would be subject to more formal processes when FAA 

grants or revokes the certificate. FAA would develop those processes as 

part of its requirement to develop a plan to implement a certified design 

organization program by 2007.

4

Public Law 108-176, Vision 100 – Century of Aviation Reauthorization Act, requires FAA to 

develop a plan for implementing a certified design organization program by 2007.
Page 12 GAO-05-40 Designee Programs

Designee Programs 

Leverage FAA 

Resources and Provide 

Industry with Timely 

Certification Reviews

Designees perform more than 90 percent of FAA’s certification activities, 

thus greatly leveraging the agency’s resources and enabling staff to 

concentrate on other areas of aviation safety, according to our panel of 

experts, FAA and industry officials, and FAA staff who oversee designees. 

The approximately 13,600 designees augment FAA’s workforce of about 

4,100 inspection staff who are responsible for ensuring industry’s 

adherence to FAA regulations. According to FAA officials, designees are 

crucial to the certification process by conducting routine activities, thereby 

allowing the agency to target its direct involvement to the most critical 

certification functions. For example, designated airworthiness 

representatives and designated manufacturing inspection representatives 

routinely support company efforts to perform design enhancements by 

conducting design conformity inspections in accordance with established 

procedures, while FAA’s Aircraft Certification Service focuses on new and 

complex aircraft designs or design changes. This information is consistent 

with the strengths of the FAA’s designee programs identified by our expert 

panel. Table 2 shows the top five strengths identified by our expert panel. 

There was considerable agreement among the experts on these strengths. 

All were identified as a “great” or “very great” strength of the designee 

programs by most of the panelists. No more than 2 of the 62 participating 

experts felt that these strengths had “no” importance toward 

accomplishing FAA’s safety responsibilities. (See app. IV for additional 

strengths identified by our expert panel.) 

Table 2: Experts’ Ranking of Top Strengths of the Designee Programs

Source: GAO analysis of expert panel information.

Note: Rankings based on responses from 62 experts and the frequency of responses indicating a 

“great” or “very great” strength.

According to all of the private industry experts on our panel and many of 

the other panelists, the use of designees allows the aviation industry and 

Ranking Strength

1 Use of designees expands available FAA resources.

2 Use of designees allows for more timely approvals than by not using 

designees.

3 Use of designees expands available technical expertise and specialization.

4 Designees provide greater scheduling flexibility and access to the public.

5 Use of designees enables FAA staff to concentrate on other areas of aviation 

safety.
Page 13 GAO-05-40 Designee Programs

others to obtain more timely approvals and issuance of aircraft 

certifications than would be possible if FAA staff were solely responsible 

for those tasks. The designee programs provide more timely service to the 

aviation industry, while assuring the airworthiness of aeronautical products 

by utilizing aviation industry expertise to perform many certification 

activities under the oversight of FAA, according to agency officials. In 

addition, the designee programs provide the industry with greater 

scheduling flexibility and access to aviation safety-related services, such as 

access to aircraft and pilot certification services. For example, Boeing 

officials told us that the use of designees has added significantly to the 

company’s ability to enhance and improve daily operations by providing 

consistent certification processes, decreasing certification delivery time, 

and increasing the flexibility and utilization of Boeing resources, which 

could reduce costs. Many experts on our panel also concurred that the 

designee programs are convenient to the aviation industry, as aviation 

organizations are able to control their production deadlines and not depend 

on FAA’s schedule for certification and approval. Figure 2 shows the 

geographic distribution of designees and their wide dispersal throughout 

the United States.
Page 14 GAO-05-40 Designee Programs

Figure 2: Designees Support FAA Throughout the United States

Additionally, the use of designees expands FAA’s access to technical 

expertise within the aviation community, as many designees are industry 

experts. Forty-six of the 62 experts on our panel thought this was a “great” 

or “very great” strength of the designee programs, including all of the 

experts from the aviation industry. For example, designated engineering 

representatives review thousands of calculations, tests, and data involved 

in aircraft designs, on behalf of the agency to ensure compliance with FAA 

regulations. Other designees, such as designated manufacturing inspection 

representatives and designated airworthiness representatives, are 

technical experts in the “production conformity”5

 or inspection of certain 

aircraft products or parts and issue certificates or approvals for engines, 

propellers, and other aircraft parts. Still other designees are aviation 

medical examiners—physicians who have been delegated the authority to 

100 or More Designees per County

6 to 99 Designees per County

1 to 5 Designees per County

Source: GAO analysis of FAA data.

5

Production conformity is an inspection necessary to determine that aviation products and 

related parts conform to an approved design and can be operated safely. 
Page 15 GAO-05-40 Designee Programs

perform physical examinations to determine if applicants are qualified to 

receive airman medical certificates6

 and student pilot certificates.

FAA’s Lack of 

Consistent Oversight of 

Designee Programs Is 

Affected by Incomplete 

Data, Workload 

Demands, and Lack of 

Training

Our work shows that inconsistent oversight is a key weakness of the 

designee programs. Oversight occurs at two levels: at FAA headquarters, 

which is responsible for monitoring the practices of its field offices, and at 

FAA field offices that are directly overseeing designees. First, while FAA 

has evaluated 6 of its 18 designee programs since 1997 and plans to 

evaluate 2 more programs, it has no plans to evaluate the remaining 

programs because of limited resources. Moreover, the agency has not 

implemented some key recommendations from these evaluations. Second, 

FAA field offices do not always oversee designee activities according to 

FAA policy, nor do the field offices apply consistent criteria for selecting 

and terminating designees. The primary goal of FAA’s standards and 

policies, and its oversight of designees, is the safety of U.S. aviation. While 

we did not find systematic safety problems associated with FAA’s oversight 

of designees, the agency’s inconsistent oversight limits its assurance that 

the designees’ work is performed uniformly in accordance with those 

standards and policies. FAA’s ability to systematically evaluate the designee 

programs and consistently apply its designee oversight policies may be 

impeded by three conditions: (1) incomplete data on FAA’s oversight of 

designee activities, (2) workload demands placed on FAA staff who 

oversee designees, and (3) the lack of adequate training for FAA staff who 

perform oversight duties.

FAA Provides Inconsistent 

Monitoring of Its Field 

Offices

To monitor the effectiveness of its designee programs and determine 

whether field offices are following FAA policy in their oversight of 

designees, FAA has evaluated only 6 of its 18 designee programs over the 

last 7 years. These evaluations encompass about 35 percent of FAA’s 

designees. Moreover, these evaluations vary in quality and 

comprehensiveness. While FAA has plans to evaluate two additional 

designee programs over the next several years, it does not plan to evaluate 

the other 10 designee programs because of limited resources, according to 

6

A pilot must have both a pilot certificate and a medical certificate in order to fly an aircraft, 

with the exception of glider and balloon pilots, who are not required to have a medical 

certificate. The pilot certificate never expires. The medical certificate must be updated 

every 6 months to 3 years, depending on the type of pilot certificate (e.g., airline transport 

pilots must have their medical certificate updated more frequently than private pilots).
Page 16 GAO-05-40 Designee Programs

a program official. FAA conducts evaluations of its designee programs on 

an ad hoc basis, usually at the request of FAA headquarters directors or 

regional office managers and uses these evaluations to determine whether 

the programs are being implemented in accordance with agency policies. 

The agency does not have requirements or criteria for periodically 

evaluating these programs and identifying the root causes for field offices 

and staff not consistently following FAA policies. According to FAA 

officials, the agency is developing quality management standards that will 

be used to evaluate field offices, including their oversight of designee 

programs. Both Flight Standards and Aircraft Certification Services plan to 

obtain approval of their quality management standards in 2006, but have no 

timeframe for conducting additional evaluations. While Aerospace 

Medicine has not evaluated its designee program, it uses regular 

management meetings with all the regional flight surgeons to monitor field 

oversight activities.

For the 11 designee programs within Flight Standards Service, the office 

has evaluated the designated pilot examiner program in some field offices 

and has plans to evaluate oversight practices for aircrew program 

designees in 2005 and designated mechanic examiners by 2006. However, 

the office has no current plans to review the oversight practices for the 

additional eight types of designees because of limited resources, according 

to a program official. In 2000, FAA’s Flight Standards Service created a 

Quality Assurance Team to undertake standardized evaluations of its field 

offices to determine how they are conducting business, identify deficient 

areas, and make improvements as needed.7

 As of July 2004, the Quality 

Assurance Team had evaluated the oversight of designated pilot examiners 

at 60 out of 104 Flight Standards field offices to determine whether each 

office is following FAA policies and standards. The team plans to assess the 

designated pilot examiner oversight practices of the remaining field offices 

in 2005. Among the completed evaluations, Flight Standards has identified 

program weaknesses, such as computerized data records that lack 

information on required surveillance of designees. The evaluation process 

calls for reporting any identified deficiencies to the appropriate offices and 

regions for corrective action. However, the evaluations by the Quality 

Assurance Team do not identify the root causes or reasons for field offices 

and staff not consistently following FAA policies and standards. According 

7

The Quality Assurance Team was established as a result of a 1999 recommendation by the 

International Civil Aviation Organization that Flight Standards Service conduct standardized 

evaluations of its field offices.
Page 17 GAO-05-40 Designee Programs

to program officials, root causes of the problems are not identified because 

that is not the purpose of the audits.

In addition, in 2000, Flight Standards’ Southwest Region reviewed the 

designated pilot examiner program in its nine field offices. While the 

review did not find any pilots who had been inappropriately certificated, it 

did find that inspectors were not reviewing pilot examiners’ work on an 

annual basis and conducting oversight as required by FAA policy.8

 The 

review by the Southwest Region was more comprehensive than the reviews 

undertaken by the Quality Assurance Team. Both the region and the Quality 

Assurance Team audited data on designees that were maintained in office 

files and in a computerized database for compliance with agency policy. 

However, unlike the Quality Assurance Team, the Southwest Region also 

gathered and analyzed information on designee activity and surveyed 

newly certificated pilots and conducted a 2-day conference with designated 

pilot examiners from the region. This more rigorous evaluation allowed the 

region to assess the outcomes of this designee program, identify root 

causes of the lack of compliance with agency policy, and develop 

corrective action plans, including increased training for inspectors, to 

address the root causes. Flight Standards has not applied this more 

comprehensive evaluation to its other eight regions or other designee 

programs to see if similar problems exist and to take any needed corrective 

action.

By comparison, from 1997 through 2000, FAA’s Aircraft Certification 

Service assessed five9

 of its six designee programs and took action to 

identify and correct the root causes of some identified weaknesses.10 For 

example, in 2000,11 the office assessed one designee program—designated 

alteration stations—in the aftermath of the fatal crash of Swissair Flight 

111 in 1998, which killed 229 passengers and crewmembers. The 

8

Federal Aviation Administration, Southwest Region General Aviation Pilot Examiner 

Review Final Report (Fort Worth, TX: Sept. 1, 2000). 

9

See Federal Aviation Administration, Designated Alteration Station System Assessment 

Final Report (Sept. 21, 2000); Aircraft Certification Service Evaluation of the 

Airworthiness Designee Management Program (Dec. 1998); and Aircraft Certification 

Service DER Oversight Evaluation (Sept. 11, 1997).

10The office has not assessed its smallest designee program—the delegation option 

authorization program, which has six designated organizations.

11Federal Aviation Administration, Designated Alteration Station System Assessment Final 

Report (Sept. 21, 2000).
Page 18 GAO-05-40 Designee Programs

Transportation Safety Board of Canada, which investigated the crash, 

suspected that an entertainment system, the installation of which had been 

approved by an FAA designee, may have been one factor contributing to a 

deadly electrical fire on board the aircraft.12 The Board concluded that 

FAA’s designee program did not ensure that the designated alteration 

station employed personnel with sufficient aircraft-specific knowledge to 

appropriately assess the integration of the entertainment system’s power 

supply with aircraft power. In response to the Canadian report, in 1999, 

FAA investigated its oversight of the designated alteration station involved 

in the crash and concluded that FAA’s oversight of the designee that 

installed the entertainment systems was in accordance with FAA policy.

13

However, the report went on to note that aspects of FAA’s policy for 

overseeing designated alteration stations lacked clarity and needed 

revision. To address this problem, the report recommended a nationwide 

study of FAA’s oversight of designated alteration stations. This subsequent 

study, conducted in 2000, found general oversight weaknesses, including 

the lack of a national standard policy on management and oversight of 

designated alteration stations and a general lack of FAA supervision of 

these designees. To address the root cause of the problems identified, the 

2000 study recommended revisions to FAA’s order concerning oversight of 

designated alteration stations, which were made and issued in August 2002. 

The 2000 review further recommended that the office establish a process to 

periodically assess the effectiveness and applicability of existing policies 

concerning designated alteration stations and consider feedback from FAA 

field offices and designees. The Aircraft Certification Service has not 

implemented this recommendation to directly assess the policies in place, 

but continues to rely on informal feedback from FAA field offices and 

industry.

In addition, FAA has not fully implemented its 2002 policy to conduct 

technical evaluations of 49 organizational designees, located primarily in 

12Transportation Safety Board of Canada, Aviation Investigation Report, In-Flight Fire 

Leading to Collision with Water, Swissair Transport Limited McDonnell Douglas MD-11 

GH-IWF, Peggy’s Cove, Nova Scotia 5 nm SW, 2 September 1998, report number A98H0003 

(no date).

13Federal Aviation Administration, Special Certification Review Team Report on: Santa 

Barbara Aerospace STC ST00236LA-D Swissair Model MD-11 Airplane In-flight 

Entertainment System (June 14, 1999).
Page 19 GAO-05-40 Designee Programs

the Aircraft Certification Service.14 Technical evaluations allow the agency 

to determine whether the products and data produced by the organizations 

are technically acceptable and comply with FAA policies. According to FAA 

officials, the agency had conducted 10 technical evaluations as of June 

2004. FAA is allowing organizational designees time to perform approvals 

under their new procedures before performing the technical evaluations, 

according to the agency. In the meantime, according to FAA officials, these 

organizational designees are being evaluated under the current Aircraft 

Certification Systems Evaluation Program, which require an evaluation 

every 2 years.

Field Offices Provide 

Inconsistent Oversight of 

Designees

Concerns about the consistency and adequacy of designee oversight that 

FAA field offices provide have been raised in previous reports,15 including 

FAA’s evaluations of various designee programs, which we discussed 

earlier in this report; by individuals we interviewed during site visits; and 

by our expert panel. Table 3 shows the top five oversight weaknesses 

identified by our experts. The top-ranked weakness—inconsistent 

oversight by FAA offices—was identified as a “great” or “very great” 

weakness by 36 of the 62 experts. No more than 6 of the 62 experts felt that 

these top five factors posed “no weakness” and between 5 and 13 other 

experts—believed these factors presented “little” weakness. (See app. IV 

for additional weaknesses identified by our expert panel.)

14These include 31 designated alteration stations, 12 Special Federal Aviation Regulations 

No. 36 (repair stations), and 6 delegation option authorizations.

15See bibliography at the end of this report.
Page 20 GAO-05-40 Designee Programs

Table 3: Experts’ Ranking of Top 5 Oversight Weaknesses

Source: GAO analysis of expert panel information.

Note: Rankings based on responses from 62 experts and the frequency of responses indicating a 

“great” or “very great” weakness.

Designees and industry officials that we spoke with indicated that FAA’s 

level of oversight and interpretation of rules are inconsistent among 

regions and among offices within a region. For example, several designees 

whom we spoke to provided the example of one Aircraft Certification field 

office that was stricter in its application of FAA standards than other 

offices—i.e., the stricter office would not approve submittals for 

supplemental type certificates that would be approved by other FAA 

offices. As a result, applicants tend to “shop around” to find those offices 

that will provide expedited approvals, according to these designees. 

Another designee and an aviation parts manufacturer told us that FAA field 

offices required different paperwork and interpreted FAA rules differently 

for the same work. For example, a manufacturer of fortified cockpit doors 

found that field offices in Los Angeles and Seattle interpreted regulations 

differently and required different paperwork to process the same type of 

approval. Designated mechanic examiners that we spoke with provided 

similar examples of inconsistencies among field offices. They cited 

instances in which one field office would reject applications that another 

field office would approve. Further, an industry representative that we 

spoke with provided examples of inconsistencies among FAA offices 

concerning whether approval in the form of a supplemental type certificate 

is needed—with some offices requiring a supplemental type certificate and 

other offices considering the same type of manufacturing or maintenance 

work minor and requiring no approval. A designated engineering 

representative noted that different FAA staff required different levels of 

detail in the standard FAA form that engineering designees submit to show 

their completed work. Another industry representative noted the lack of 

standardized requirements for data submittals from certain types of 

designees, such as designated engineering representatives. A standardized 

Ranking Weakness

1 FAA offices level of oversight and interpretation of rules are inconsistent.

2 Inactive, unqualified, or poor performing designees are not identified and 

removed expeditiously.

3 It is difficult to terminate poor performing designees.

4 Inadequate surveillance and oversight of designees.

5 FAA has not made oversight of designees a high enough priority.
Page 21 GAO-05-40 Designee Programs

checklist would help various FAA field offices to consistently interpret 

regulations, according to the industry representative. According to FAA 

officials, in certain cases, there are reasons for inconsistent application of 

rules. For example, in the case of cockpit doors, the projects typically 

varied across offices depending on data submitted by previous applicants 

and the capability of the applicant. In order to reduce unnecessary 

administrative burdens on applicants, FAA’s policy specifies that once an 

applicant had demonstrated that a design change met FAA requirements, 

subsequent applicants for a similar alteration may not be required to 

conduct all the same tests required of the previous applicant, according to 

FAA officials. Agency officials further stated that checklists are created for 

each project and that standardized checklists cannot be used because each 

project is unique. This was disputed by FAA staff that we spoke with, some 

of whom had created standardized checklists to use for all the designees 

that they oversaw.

We also found that, in some cases, the ability of FAA field offices to oversee 

designees is affected by designees working outside of their normal locality 

and the amount of written details about that work that is provided to FAA. 

FAA policy allows designees to work outside of their assigned geographic 

area but, in certain circumstances, requires designees to notify the local 

FAA office.16 This situation can occur, for example, when specialized 

engineering expertise is needed by an aviation parts manufacturer and the 

closest designee with that expertise is located in a remote FAA region; in 

which case, the company may request the services of a designee from 

outside the region. We spoke with one designated engineering 

representative based in Atlanta who regularly worked outside his 

geographic area. In 2001, 7 of 12 projects that he approved as a designee 

were outside the Atlanta area; in 2002, 20 of 33 projects were outside the 

area, and in 2003, 4 of 28 projects were outside the area. When he works 

out of his geographic area, he normally contacts the field office where he is 

conducting his work only after the work is completed and submits the 

required paperwork to his FAA office in Atlanta upon completion of a 

project. He and other designated engineering representatives told us that 

they are likely to include minimal details in the forms submitted to FAA 

because that information can be requested under the Freedom of 

16When designated engineering representatives conduct work related to field approvals 

outside of their assigned geographic areas, they are not required to contact the field office 

where they are conducting that work. On the other hand, when their work is related to 

issuing type certificates or supplemental type certificates outside their assigned geographic 

area, they are required to contact the FAA field office where they are conducting that work.
Page 22 GAO-05-40 Designee Programs

Information Act. An FAA engineer also told us that designated engineering 

representatives may be reluctant to include details on how they certify 

aviation products. Since FAA inspectors have little opportunity to witness 

the work being performed by designees that work outside their area, 

inspectors rely heavily on paperwork reviews. When the paperwork 

provides insufficient details about the designees’ activities, FAA staff spend 

additional time requesting the needed information from designees, 

according to an FAA engineer.

In addition, Flight Standards Service staff told us that more direction and 

clarity was needed concerning the amount of surveillance that inspectors 

should be conducting over designees. Policy guidance describes how 

inspectors are to conduct surveillance of designees, and the service 

develops a national workplan each year that determines the number of 

inspections of designees that inspectors and engineers will perform. 

Several FAA field office managers that we spoke with believed that the 

oversight called for in the national workplan does not allow them to target 

oversight to those designees that need more or less surveillance. In 

addition, according to several FAA inspectors that we spoke with, it is 

difficult during their site visits of designees to identify those who are 

improperly certifying applicants or conducting inappropriate activities, 

such as approving parts beyond their authorization. The inspectors told us 

that they usually find out about improper designee activities by noticing 

mistakes on the forms submitted by designees and receiving complaints 

from designees’ clients. A designee that we spoke with further explained 

that, because FAA visits are arranged in advance, designees have time to 

make sure things are done correctly during the visit. Flight surgeons, by 

comparison, are not required to conduct site visits of designees. Due to 

limited number of staff and resources available to conduct site visits, flight 

surgeons primarily conduct those visits only after problems have been 

identified by others, such as complaints by clients.

We also found that field offices did not consistently follow established 

policy for selecting designees. While we did not find evidence that 

unqualified designees were selected, this situation may result in not 

selecting the best qualified candidates. Nineteen of the 62 experts on our 

panel believed that FAA does not consistently follow its own designee 
Page 23 GAO-05-40 Designee Programs

selection criteria17—which are based on designee candidates experience 

and qualifications, FAA field offices’ ability to oversee designees, and the 

need for particular types of designees18—but rather appoints designees 

based on personal associations. Moreover, 9 of the 17 FAA inspectors and 

engineers on our panel rated the practice of awarding delegation status 

based on personal associations with FAA management as a “great” or “very 

great” weakness of the designee programs. FAA policy requires multiple 

parties to review applicant’s qualifications and reach consensus on 

appointment decisions, but we found that field offices sometimes add their 

own criteria. For example, Flight Standards Service has established a 

National Examiners Board to review all designee applications and prepare 

a list of qualified candidates from which field office managers must select 

designees. The board was established to provide an objective, standardized 

process and to move away from the previous ad hoc practices of appointing 

designees that were often based on selecting personal acquaintances. 

However, we found that this process does not always work as intended. For 

example, in a Flight Standards field office that we visited, an applicant for 

designed airworthiness representative is required to have a letter of 

recommendation from the manager of the field office. According to an 

inspector at that field office, this practice has resulted in screening out 

otherwise qualified individuals. According to FAA officials, personal 

associations is an important factor in selecting and appointing designees. 

They consider personal knowledge and experience with the applicant an 

important consideration in the selection process, without which it is 

difficult to know whether applicants have the necessary qualifications and 

abilities.

In addition, FAA’s internal evaluations confirm our work that FAA offices 

provide inconsistent oversight and interpretation of rules concerning 

designees, which limits the assurance that the agency has that the 

designees are performing certification work properly. For example, as 

mentioned previously in this report, in 2000, an FAA evaluation of designee 

pilot examiner oversight in one region found that inspectors were not 

17Nineteen experts indicated this factor was a “great” or “very great” weakness of the 

designee programs; 4 experts felt this factor was not a weakness; 17 experts felt that this 

posed “little” weakness.

18Each type of designee has unique qualification requirements, which are defined in FAA 

Order 8100.8 Chapter 4.
Page 24 GAO-05-40 Designee Programs

conducting oversight as required by agency policy.19 That review further 

found that up to 30 percent of the designated pilot examiners in the region 

were not conducting complete practical tests of pilot certificate applicants 

and not consistently holding pilot applicants to the standards of the 

practical test.20 In addition, an FAA-industry study found that project 

approvals by certain designated engineering representatives, which do not 

require FAA review, combined with the lack of designee and FAA technical 

expertise in certain specialized areas, have resulted in designs that were 

deficient or not in compliance with FAA regulations.21

We also found that FAA offices do not always identify and remove inactive 

or poor performing designees expeditiously, which may be due to 

reluctance on the part of managers, engineers, and inspectors to take 

disciplinary action. FAA policy calls for providing counseling, remedial 

training, or limiting or terminating designees’ authority for insufficient 

work activity and poor performance. For example, since 1998, Aircraft 

Certification Service has terminated approximately 770 designees for such 

reasons as insufficient activity, lapse in qualifications, or lack of care.22

However, a 2002 study conducted jointly by FAA and industry found that it 

was the perception of some FAA field staff who oversee designees that 

terminating designees is difficult because of fear of litigation. According to 

the report, this perception had resulted in little, if any, disciplinary action 

being taken against designees when it may be warranted.23

Our interviews with FAA field office managers and staff confirmed that 

they are reluctant to take disciplinary action against designees. For 

19Federal Aviation Administration, Southwest Region General Aviation Pilot Examiner 

Review Final Report (Fort Worth, TX: Sept. 1, 2000).

20Practical test standards are areas of operating aircraft, such as flight procedures or flight 

maneuvers, in which pilot applicants must demonstrate their knowledge and skills before 

receiving pilot certificates. FAA developed these standards for FAA inspectors and 

designated pilot examiners to use when conducting practical tests to pilot applicants.

21Federal Aviation Administration, Commercial Airplane Certification Process Study: An 

Evaluation of Selected Aircraft Certification, Operations, and Maintenance Processes

(Washington, D.C.: March 2002).

22During that time period, 2,850 additional designees were terminated for reasons not 

associated with disciplinary action, such as change of employment, retirement, or the 

request of the designee. 

23See footnote 21.
Page 25 GAO-05-40 Designee Programs

example, managers in the Seattle and Oklahoma City field offices and 

inspectors and engineers in the Atlanta and Los Angeles field offices told us 

that rather than take disciplinary action against poor performing designees, 

they wait and terminate the designee during the renewal process, as long as 

designees have not committed any criminal acts. According to these 

officials, FAA field offices prefer to not renew poor performing designees 

rather than terminate them because FAA management wants to avoid legal 

appeals that designees can make if the agency decides to terminate them 

for poor performances. According to FAA field inspectors that we spoke 

with, it is difficult for them to terminate poor performing designees—such 

as those who continue to omit information in their documented work 

despite training and counseling—because the process is lengthy and timeconsuming. According to one FAA engineer, when she tried to remove a 

designated engineering representative for making incorrect approvals, she 

was required by FAA policy to first notify the designee of FAA’s intent to 

terminate the designation, and then to document the specific reasons for 

the recommended removal. The process took 2 to 3 years, according to the 

inspector. After designees are removed, they are allowed up to two appeals, 

which can further lengthen the removal process. FAA officials 

acknowledged that misunderstandings of the removal process among 

inspector staff will continue without the development of specific guidance 

and training on the designee termination process. Our analysis of data from 

the Aircraft Certification Service found that the office terminated 15 

designees because of “lack of care or judgment” and terminated 121 by not 

renewing their designations over the last 5 years.

In addition, FAA field and program office managers have some discretion 

over terminating poor performing and inactive designees, but because 

FAA’s criteria for terminating designees is not specifically defined, each 

field and program office determines when poor performance or lack of 

activity constitutes grounds for termination. According to a manager in 

FAA’s Civil Aerospace Medical Institute, one region may terminate an 

aviation medical examiner who is consistently more than 30 days late in 

transmitting medical certification data, while another region may terminate 

an aviation medical examiner who is consistently more than 60 days late. 

An FAA engineer told us that designees in the Aircraft Certification Service 

are seldom terminated because of low activity level. Of the approximately 

770 designees for Aircraft Certification Service that were terminated since 

1998, according to information we analyzed in FAA’s Designee Information 

Network database, about 230 (30 percent) were terminated for inactivity. In 

addition, a manager for a Flight Standards field office told us that the 

criteria the office uses for terminating poor performing designees include 
Page 26 GAO-05-40 Designee Programs

whether the termination will result in a loss of income for individual 

designees. This criterion is not included in FAA policy nor considered by 

other field or program officials with whom we spoke.

Consistent application of oversight policies is important to ensure that 

designees follow FAA policies and that they remain free from pressures 

from employers or clients that may lead them to bypass those policies. For 

example, in 1999, FAA found that designated mechanics’ examiners in the 

Orlando, Florida, area had not adhered to FAA’s standards and had 

fraudulently indicated that hundreds of mechanic applicants had passed 

the certification examination. This resulted in FAA retesting many of the 

mechanics. In addition, some designated engineering representatives are 

salaried employees of the manufacturers whose products they are 

approving on behalf of FAA. In one case, a designee told us that another 

designated engineering representative was an executive officer of the 

company whose products he was approving, creating an apparent conflict 

of interest. The designee also told us that designees are under pressure by 

their employers to certify products. He stated that designated 

manufacturing inspection representatives are sometimes pressured by 

their employers to approve aviation products for export, under the threat 

of being fired. According to FAA officials, agency policy discourages the 

appointment of designated engineering representatives who are executives 

within a company where the primary job duties are schedule-driven and 

devoted to the output of the company’s whole saleable products. Other 

designees, such as designated pilot examiners, are employed by flight 

schools and test pilot applicants for those schools. Since those designees 

depend upon the flight school for employment and referral of applicants, 

there could be an incentive for the designated pilot examiner to 

compromise the integrity of pilot tests. Such situations present the 

potential risk that designees may be pressured by employers to bypass FAA 

requirements in order to meet schedules or attract additional students. FAA 

officials acknowledge that an inherent conflict of interest exists in the 

designee programs, but did not view it as a weakness because designees 

can be held liable for deficiencies in their work. However, concerns were 

expressed to us by several FAA field managers and inspectors, that smaller 

organizations, such as repair shops, may be willing to risk liability and 

bypass agency requirements. 
Page 27 GAO-05-40 Designee Programs

Poor Data, FAA Staff 

Workload, and Insufficient 

Training for FAA Staff May 

Contribute to Oversight 

Weaknesses

FAA’s oversight of its field offices and designees is hampered by the lack of 

comprehensive information in some of the agency’s databases that are used

to capture information on designees,24 the workload demands facing FAA 

staff who oversee designees, and insufficient training for FAA staff on 

designee oversight. 

Designee Databases The databases for the offices of Flight Standards Service and Aircraft 

Certification Service were not designed to capture information concerning 

oversight performed by the managing offices and do not provide a 

comprehensive picture of FAA engineers’ and inspectors’ oversight 

activities or the activity levels of designees. For example, FAA policies 

require FAA inspectors in the Aircraft Certification Service who oversee 

manufacturing designees to update the designee management database, 

Designee Information Network, every time they oversee or monitor a 

designee’s performance. However, no data field is provided to capture 

information on these oversight visits. A field for comments is available for 

FAA staff to indicate when a designee performance evaluation was 

conducted, but our review of the data files for 1998 through 2003, found 

that this information was not consistently noted. Moreover, FAA policy 

does not require its engineers to document their oversight of engineering 

designees in the database. Thus, FAA cannot readily ascertain how often 

staff in the Aircraft Certification Service monitored and evaluated 

designees, other than the minimum levels required to renew the designees’ 

authority.25 According to officials in that office, information on how often 

staff review designee performance is recorded in designees’ paper case 

files, which are maintained at the field or program offices. In addition, the 

Designee Information Network does not contain information on the 

number and type of approvals that the individual designees are conducting. 

As a result, FAA lacks a single, comprehensive data source that could be 

24The four databases are the National Vital Information Subsystem and Program Tracking 

and Reporting Subsystem used by Flight Standards Service, the Designee Information 

Network used by Aircraft Certification Service, and the Airmen Medical Certification 

Information Subsystem used by Aerospace Medicine.

25Most designees’ appointments are effective for 1 year, with the exception of individual and 

organizational designated airworthiness representatives, who are appointed for up to 5 

years, and all other types of organizational designees, which are appointed indefinitely. 

According to FAA policy, the minimum level of oversight requires FAA engineers and 

inspectors to review designees’ files for project activity in order to renew the designees’ 

authority.
Page 28 GAO-05-40 Designee Programs

used to facilitate designee oversight by providing FAA a means to prioritize 

oversight activities and engineer workload. According to FAA officials, the 

fact that all oversight information is not captured in a single database does 

not directly affect the agency’s ability to effectively oversee designees.

Two other databases—the Program Tracking and Reporting Subsystem 

(PTRS) and National Vital Information Subsystem (NVIS)—used by Flight 

Standards Service inspectors to monitor designees also do not completely 

track designees’ activity level. According to FAA officials, PTRS was 

designed to track activities by FAA inspectors, such as noting when FAA 

inspectors conducted surveillances of designees, while NVIS was 

developed to track basic profile information on designees, such as their 

names, addresses, types of certification, designated authorizations, and 

status. PTRS can be used to track the activity levels of designees; however, 

it requires the FAA inspector to input the data each time they receive a 

certification package from a designee, but past reviews have found 

problems with incomplete information in the database. For example, in 

2003, the Quality Assurance Team mentioned earlier found that required 

information on designee oversight was missing from the two databases or 

incorrect. The team noted records that would indicate the type of 

surveillance conducted (such as an observation of a complete or partial 

test) were missing from PTRS and records in NVIS that lacked renewal 

dates and contained inaccurate information on designee training and 

authorizations. By comparison, Aerospace Medicine has one database—

Airmen Medical Certification Information Subsystem—to track 

information on aviation medical examiners, including information on the 

number of medical certificates issued by each medical examiner and 

demographic, training, and oversight information for each designee. Our 

review of that database found reasonably complete information; we did not 

check the accuracy of the information.

FAA Staff Workload FAA’s oversight of the designee programs may also be weak, in part, 

because of the workload demands facing agency staff who oversee 

designees. In addition, the amount of time that FAA staff spend on other 

aviation safety activities, such as monitoring air carrier operations, affects 

the amount of time spent on designee oversight. FAA policy recognizes that 

each designee oversight scenario is unique and allows variations in 

determining the extent of oversight needed to meet minimum annual 

requirements. FAA policy also states that the ability to provide adequate 

oversight depends on balancing the level of FAA staffing to the agency’s 

workload and the number of designees. FAA policy, however, does not 

specify an acceptable workload for meeting this criterion. For example, 
Page 29 GAO-05-40 Designee Programs

each managing office must periodically verify adequate FAA staffing 

numbers based on the type and amount of the work performed by staff who 

oversee designees. FAA policy provides no further guidance for 

determining adequate numbers for proper oversight. FAA officials stated 

that the level of specificity in the guidance is adequate for determining staff 

workload with designees and that it would be difficult to determine an 

exact staffing ratio because of factors such as the size of facilities, the 

experience of designees, and the complexity of projects. However, the lack 

of clear policy guidance and staffing standards results in wide variation in 

the ratio of designees to FAA staff among offices and programs and makes 

it difficult for the agency to measure and account for its staff resources. 

For example, our review of FAA data showed that, on average, the ratio of 

designees to FAA staff is about 6 to 1 in the Aircraft Certification Service, 

about 5 to 1 in Flight Standards, and about 440 to 1 in Aerospace Medicine. 

The ratios for individual FAA staff ranged from 1 designee to 1 FAA staff in 

several Aircraft Certification offices to about 870 designees to 1 FAA staff 

in Aerospace Medicine. Information we gathered from site visits at three of 

FAA’s nine regions also showed a wide range of workload ratios. For 

example, information we gathered at Flight Standard’s Northwest 

Mountain Region showed ratios among field offices ranging from 1 

designee to 1 inspector to 100 designees to 1 inspector. Variations in the 

ratios of designees to FAA staff are due to the type of designee and the 

complexity of their work, according to FAA officials. However, several 

engineers in the Aircraft Certification Service with whom we spoke 

expressed concerns that a designee to staff ratio higher than 10 to 1 limits 

the time they have to adequately monitor the work performed by designees. 

One Aircraft Certification engineer told us that while he was currently 

responsible for overseeing 10 designated engineering representatives, in 

the past, he had been responsible for between 30 and 60 designees, which 

was too many to adequately oversee. Flight Standards Service officials 

acknowledged that staffing standards need to be established. The National 

Academy of Sciences is currently evaluating the staffing standards for the 

office of Regulation and Certification, which encompasses Flight 

Standards, Aircraft Certification, and Aerospace Medicine, and expects to 

complete the study in 2005.

Past reports by us and others pointed out that escalating workloads and/or 

high turnover rates for FAA staff continue to diminish FAA’s ability to 

oversee designees. For example, over 10 years ago, we reported that, in 

response to a dramatically escalating workload, FAA had delegated aircraft 
Page 30 GAO-05-40 Designee Programs

certification duties to designees without defining a clear role for its staff to 

ensure that they were effectively involved in the certification process.26

Since then, FAA has issued comprehensive policies governing the selection, 

appointment, and oversight of individual and organizational designees. We 

also pointed out high turnover rates (107 percent over the previous 10 

years) for FAA engineers who oversee designees. In addition, internal FAA 

documents from 2000 cited the disparity between the agency’s Aircraft 

Certification Service’ workload and its staffing levels, noting that staff 

resources have not kept pace with increasing workload. To update the 

information in our 1993 report, a 2002 study prepared for FAA confirmed 

that the two FAA field offices—Seattle and Los Angeles—responsible for 

the majority of commercial transport airplane oversight still had high 

turnover rates (115 percent over an 8-year period) and that over 50 percent 

of the engineers in those offices had less than 5 years of FAA experience.27

The report further noted that the consistently high turnover rate and 

associated low experience levels were indicators of the limited time 

available for FAA engineers to acquire the necessary experience and to 

understand the increasingly complex systems and human factors 

associated with modern aircraft, which are among the skills needed to 

oversee the work of designees. FAA noted that the annual turnover rate of 

engineers at the Seattle and Los Angeles field offices had declined in recent 

years, indicating that from fiscal years 1999 through 2004, the average 

annual rates were 3 percent and 4 percent, respectively for the two 

offices.28

In addition, designees told us that FAA staff who oversee designated 

engineering representatives change frequently. A designee monitored by a 

Seattle field office told us that he estimated that every 3 years he reported 

to a different FAA staff person. Another designee told us that in the last 5 

years, he had reported to six different FAA staff. As a result of frequent 

changes in FAA staff, the designees felt frustrated in the amount of time 

that it took to establish a good working relationship with each new FAA 

staff person. We found a similar situation in an Atlanta field office, where 

26GAO, Aircraft Certification: New FAA Approach Needed to Meet Challenges of Advanced 

Technologies, GAO/RCED-93-155 (Washington, D.C.: Sept. 16, 1993).

27See footnote 21.

28The turnover rates reported in the two studies were cumulative over the time period, while 

FAA provided information on an annual basis. The turnover rates from FAA, therefore, are 

not comparable to the rates from the two studies.
Page 31 GAO-05-40 Designee Programs

an FAA engineer explained that high turnover of engineers in the office 

made it difficult to oversee the activities of designated engineering 

representatives. The difficulty arises, according to the FAA engineer, 

because designees typically submit forms at the end of each quarter to 

document their activities, which FAA engineers then review. When a 

designee’s FAA advisor changes during a quarter, the only information that 

the new advisor has concerning the designee’s work is the information 

contained in the form, because the new advisor does not have information 

concerning discussions between the prior FAA staff person and the 

designee. Furthermore, as we mentioned earlier in this report, both an FAA 

engineer and designated engineering representatives told us that 

designated engineering representatives are reluctant to include details on 

how they certified a product, fearing that the information could be 

requested and made public under the Freedom of Information Act.

FAA provided us with information on how the size of its workforce has 

changed over time in comparison with the number of designees they 

oversee for some designee programs. For example, based on FAA’s staffing 

information, the number of designees overseen by engineers and 

inspectors in the Aircraft Certification Service decreased slightly from 6.7 

to 1 in fiscal year 1999 to 6.5 to 1 in fiscal year 2003. However, FAA could 

not provide similar information for Flight Standards Service or Aerospace 

Medicine to determine how the agency’s workforce has changed over time 

in comparison to designees. Some members of our expert panel 

commented that the number of FAA staff who oversee designees has not 

increased at the same rate the aviation industry has grown. Experts also 

stated that FAA staff do not have time to provide adequate oversight of 

designees for whom they are responsible for overseeing. Additionally, FAA 

inspectors and engineers that we spoke with commented that as FAA’s 

dependence on designees continues to increase, their ability to conduct 

oversight—consisting of designee supervision, monitoring, and tracking, as 

required by FAA policy—will continue to decrease. According to some FAA 

engineers that we spoke with, dramatic increases in their workload has 

resulted in their ability to review only a minimal percentage of work 

conducted by designees.

The situation in Aerospace Medicine provides another example of 

workload issues potentially hampering oversight. Between July 2002 and 

June 2003, the nine regional flight surgeons in Aerospace Medicine each 

headed a team of about three or four FAA staff and monitored over 4,900 

designated medical examiners, who conducted more than 420,000 medical 

examinations. Given high workload demands on the flight surgeons and 
Page 32 GAO-05-40 Designee Programs

their staff, in many cases, they are not able to perform site inspections to 

ensure that designee offices and facilities meet FAA standards, according 

to Aerospace Medicine officials. These officials also noted that site visits 

would help FAA ensure that designees are in compliance with FAA’s facility 

and equipment requirements, such as verifying that the designees have 

access to acceptable facilities to perform physical examinations, meet 

minimum vision and hearing test equipment standards, and have access to 

approved diagnostic instruments. According to regional flight surgeons, 

due to the limited number of staff and resources available to conduct site 

visits, they primarily conduct those visits only after problems arise due to 

unprofessional behavior or unethical practices on the part of the 

designated examiners. Such questionable designee practices are brought to 

the attention of regional flight surgeons by the Civil Aerospace Medical 

Institute, FAA field staff, and through complaints by the designees’ clients. 

According to FAA officials, limited resources also hinder the flight 

surgeons’ ability to identify unprofessional or unethical designated medical 

examiners.

Inspectors in Flight Standards also told us of workload demands affecting 

designee oversight. For instance, one FAA inspector provided an example 

of a designated pilot examiner who conducted approximately 400 practical 

tests in 1 year. FAA policy calls for inspectors to conduct one annual 

inspection of each designated pilot examiner and to carry out additional 

surveillance of pilot examiners who perform more than 50 practical tests 

per quarter. Because of high workload, the inspector was only able to 

conduct one annual inspection of the designee with high activity and was 

not able to conduct the required additional surveillance.

The ability of FAA staff to oversee designees is also affected by the amount 

of time that they spend on a wide variety of other aviation safety activities 

and the priorities that are given to the various activities. For example, FAA 

officials from Flight Standards Service commented that inspectors are also 

responsible for other activities such as taking enforcement actions, 

evaluating air carrier operations, monitoring general aviation activities, and 

conducting accident investigations. Several FAA engineers that we spoke 

with said that their first work priority was to conduct accident 

investigations and draft airworthiness directives; their second priority was 

to draft policy and regulations; and their third priority was designee 

oversight. FAA staff that we interviewed estimated that they spend about 5 

to 15 percent of their time overseeing designees, depending largely on the 

number of designees for whom they are responsible. According to one 

estimate by an FAA engineer who is responsible for overseeing 25 
Page 33 GAO-05-40 Designee Programs

designees in the Aircraft Certification Service, approximately 10 percent of 

his time—or about 4 hours per week—is devoted to designee oversight. 

Inspectors and engineers also pointed out that poor-performing designees 

can significantly increase their workload as they require greater 

surveillance and more frequent interactions.

Training for FAA Staff FAA’s oversight of the designee programs may also be weak, in part, 

because of insufficient training for staff who oversee designees. Twentyone of the 62 experts on our panel cited a lack of training in designee 

oversight for FAA inspectors and engineers as a “great” or “very great” 

weakness of the designee programs. Six out of 15 FAA inspectors or 

engineers on our expert panel considered this situation to be a “great” or 

“very great” weakness. (Six experts felt the lack of training was not a 

weakness, and 6 other experts felt it posed little weakness.) Flight 

Standards Service officials acknowledged that additional oversight training 

would be helpful to address training weaknesses. 

FAA’s Aircraft Certification Service and Aerospace Medicine have 

established initial training requirements for newly hired staff, which 

include courses on designee oversight. For example, the Aircraft 

Certification Service requires staff to take the Delegation Management Job 

Functions Course, which focuses on overseeing designees and is designed 

to teach the skills necessary to select, supervise, and terminate designees. 

FAA’s Aerospace Medicine requires regional flight surgeons to take initial 

training on policies and regulations pertaining to designees. Aerospace 

Medicine staff who assist flight surgeons do not receive initial training 

concerning designees, but periodically attend training at the Civil 

Aerospace Medical Institute in Oklahoma City or are informed of relevant 

policy changes through teleconferences, according to officials in the office. 

By comparison, Flight Standards Service does not provide initial training to 

its inspectors on designee oversight. Instead, this office requires new 

inspectors to attend initial training in their areas of specialization. Flight 

Standards is currently evaluating the Delegation Management Course used 

by Aircraft Certification to determine if the course meets inspectors’ needs 

for overseeing designees, according to several officials in Flight Standards.

Once inspectors and engineers in Flight Standards and Aircraft 

Certification services have fulfilled their initial training requirements, they 

are encouraged, but not required, to participate in refresher training. In 

contrast, FAA requires designees to receive formal refresher training every 

2 or 3 years. By not requiring its oversight staff to take refresher training, 

FAA cannot maintain reasonable assurance that its inspectors and 
Page 34 GAO-05-40 Designee Programs

engineers stay current on changes to policies and procedures. In fact, one 

FAA manager told us that, in his office, FAA engineers who oversee 

designees needed additional training, especially in the area of managing 

designees. In addition, several experts on our panel stated that, given the 

disparity in training requirements, it would be possible that designees 

could gain a better knowledge of FAA’s policies and procedures than the 

FAA staff who oversee them. FAA officials stated that inspectors and 

engineers receive training through workshops, video training sessions, and 

FAA academy training. However, they do not receive refresher training, 

which is required for designees. This is in contrast to regional flight 

surgeons, who are required to attend refresher training every 3 years, 

which is the same training required for designees.

Additionally, previous recommendations for improving inspector training 

have not been implemented. For example, as mentioned previously in this 

report, in 2000, FAA found that inspectors in field offices in the Southwest 

Region were not reviewing designated pilot examiners’ work on an annual 

basis and conducting oversight as required. The report recommended that 

the Southwest Region conduct standardized initial and refresher training 

for FAA inspectors, supervisors, and managers on the agency’s oversight 

policies and procedures pertaining to designated pilot examiners. In 

response to the recommendation, the region implemented a training course 

that included briefings at each field office to raise the awareness of FAA 

inspectors concerning the importance of designee oversight, to explain 

current policy, and to offer techniques for effective oversight. The region 

also used the briefings as the basis of curriculum for new training courses 

for FAA inspectors and has recommended that such courses be made 

available for all Flight Standards Service inspectors nationwide. According 

to agency officials, FAA plans to implement a national policy based on this 

recommendation in October 2004 and expects the policy to be 

implemented by 2005.

FAA Has Potential 

Opportunities to 

Improve Designee 

Programs

Experts on our panel, best practices within FAA, and practices adopted by 

other countries in administering their respective designee programs, 

including experiences in implementing organizational delegation systems, 

suggest that there are potential opportunities for FAA to improve (1) 

program oversight to ensure consistent compliance with existing policies 

by FAA inspectors, engineers, and flight surgeons and (2) the accuracy and 

comprehensiveness of computerized information on designees so that the 

databases can be more useful tools for designee oversight. Given the 

central importance that the designee programs hold for FAA and future 
Page 35 GAO-05-40 Designee Programs

agency plans to expand the use of organizational designees with the 

creation of the ODA program, FAA has incentives to carefully consider 

such opportunities.

Several Opportunities 

Identified to Improve 

Oversight of Designee 

Programs

Our work indicated that additional opportunities exist to improve FAA’s 

oversight of its designee programs to ensure consistent compliance with 

existing policies by FAA inspectors, engineers, and flight surgeons. For 

example, our expert panel offered a number of suggestions to improve the 

designee programs that address some of the weaknesses we identified, 

including improvements in selecting and terminating designees and 

ensuring that FAA staff who oversee designees are knowledgeable about 

FAA policy. In addition, many experts agreed that it was important for FAA 

to hold designees accountable for their findings.29 For example, one expert 

pointed out that the designated engineering representative and 

organizational designee programs should be overhauled so that the 

designees are responsible and accountable for certifications and that FAA 

needed to put in place a process to monitor that additional responsibility. 

An FAA official told us that accountability is a central part of their designee 

programs, since failure to perform delegated functions in accordance with 

agency standards and expectations will result in removal of the delegation. 

In addition, all of the experts on our panel indicated that it was important 

for FAA to conduct audits of existing designee programs to determine if 

field offices are providing adequate oversight.30 As we mentioned 

previously in this report, FAA has audited only 6 of its 18 designee 

programs. Table 4 lists the top ranked actions in terms of importance and 

feasibility identified by the experts; these actions were identified as “high” 

or “highest” in importance and feasibility for implementation by most of 

our experts. Appendix IV provides a complete list of suggestions made by 

our expert panel. 

29Only one expert indicated that greater accountability of designees was not necessary. 

30In response to this question, two experts had no opinion and three experts declined to 

answer.
Page 36 GAO-05-40 Designee Programs

Table 4: Experts’ Ranking of Top Ways to Improve FAA’s Designee Programs

Source: GAO analysis of expert panel information.

Note: Rankings based on responses from 62 experts and the frequency of responses indicating a 

“high” or “highest” importance to implement. 

Consistent evaluation and monitoring of designee activities is crucial to 

hold designees accountable for their findings, and some FAA offices have 

best practices that may be broadly applicable across the designee 

programs. For example, as we discussed earlier in this report, FAA’s 

internal review of pilot examiners in the Southwest Region was 

implemented to determine whether the designees in the region were 

conducting valid practical tests of general aviation pilot applicants and to 

determine the quality of FAA oversight provided by field offices in the 

region. Findings from the internal review were based on a comprehensive 

statistical analysis of pilot examiners’ activities in the region, a survey of 

newly certified private pilots in the region, audits of pilot examiner files, 

surveillance reports from FAA inspectors, and interviews with field office 

managers and staff. The review provided a reasonable method to assess 

program outcomes, identify the root causes of the lack of compliance with 

agency policy, and develop corrective action plans to address the root 

causes. FAA’s Organization Effectiveness Branch Manager commented that 

the methodology for the internal review was reliable, and suggested that 

the review was informative for developing regional policy. The Branch 

Manager also commented that in order to address FAA national policy, a 

national survey would be necessary. Flight Standards Service has not 

expanded its use of this methodology to other regions or to other designee 

programs.

Canada’s practice of systematically evaluating and/or monitoring its 

designee programs provides additional examples of opportunities for 

Ranking Suggested improvement

1 Hold designees accountable for their findings. 

2 Ensure that FAA employees who oversee designees are knowledgeable about 

the regulations, policies, and processes applicable to the designees’ particular 

specialization.

3 Select designees according to their qualifications and experience rather than 

on personal associations with FAA managers.

4 Clearly define and consistently follow the criteria for selecting designees.

5 Increase penalties (including the ability to terminate their status as designees) 

for individual and organizational designees found to violate standards or who 

do not exercise proper judgment.
Page 37 GAO-05-40 Designee Programs

improving FAA’s oversight of its organizational designee programs and its 

plans to implement ODA. Transport Canada oversees both individual and 

organizational designees (which are called “delegates”), and focuses on 

aircraft design and design modifications.31 Transport Canada oversees 

delegates using regional offices and headquarters staff, similar to FAA. 

FAA, however, oversees a much larger number of designees. For example, 

Canada has approximately 760 aviation medical examiners and 80,000 

pilots, while the United States has about 5,000 aviation medical examiners 

and about 630,000 pilots. Transport Canada has implemented a policy to 

provide a consistent and standard approach for conducting safety oversight 

of its organizational delegates, which includes conducting audits of 

delegated organizations on a cycle ranging from 6 to 36 months—an initial 

audit within 6 months of certification and comprehensive follow-up audits 

on a recurring basis. They have also established a centralized 

standardization office to ensure that field offices are consistently 

interpreting rules and procedures. The centralized office evaluates and 

approves technical submissions from applicants and delegated 

organizations to determine compliance with regulations. The office is also 

responsible for the development, coordination, and implementation of a 

national audit plan in auditing delegated organizations. By comparison, 

FAA policy calls for conducting annual inspections, and procedural audits 

and technical evaluations every 2 years. Annual inspections focus on a 

review of the system that the delegated organization has in place to 

perform the delegated functions and a review of the activities conducted by 

individuals. As mentioned previously, FAA conducted 10 technical 

evaluations (out of 49) as of June 2004. According to FAA, it has established 

centralized offices responsible for standardization of policies. However, 

our work has shown that FAA field offices do not implement policies in a 

standard manner, as discussed earlier in this report.

Transport Canada’s experiences in developing an organizational delegation 

system in the late-1980s also provide relevant lessons for FAA as it begins 

developing the ODA program. According to the Chief of Delegation and 

Quality Divisions in Transport Canada, an inconsistent level of oversight 

was a major challenge that Transport Canada faced as it implemented its 

organizational delegation system. To address this challenge, the agency 

established a centralized standardization office to ensure that field offices 

31Established in the 1980s, Canada’s two types of organizational delegates, Design Approval 

Organizations and Airworthiness Engineering Organizations, are authorized to evaluate and 

approve technical data to determine compliance with safety requirements.
Page 38 GAO-05-40 Designee Programs

are consistently interpreting rules and procedures. Based on this 

experience, the Transport Canada official told us that FAA needs to plan for 

the inconsistencies that will arise during the implementation of the ODA 

program. The larger size of the U.S. designee programs increases the 

likelihood that the level of oversight will be inconsistent, according to the 

Transport Canada official. Moreover, the official also commented that, in 

hindsight, they should have developed and conducted an audit of 

organizational delegates early in the implementation process. The 

Canadian official told us that Transport Canada did not conduct audits 

early on because staff were preoccupied with reviewing and approving 

organizations’ procedures manuals. Transport Canada’s quality assurance 

review later determined that they were not doing audits of organizational 

delegates on time, nor conducting audit follow-ups, which contributed to 

inconsistent oversight.

Database Monitoring 

Performance of Aviation 

Medical Examiners Could 

Be Model for Other 

Designee Databases

Accurate, comprehensive information on designee activities is an 

important prerequisite for designee oversight and is integral to monitoring 

and evaluating the programs. The Airmen Medical Certification 

Information Subsystem—a database used by FAA’s Office of Aerospace 

Medicine to monitor the performance of aviation medical examiners—

provides a model for the other designee programs. Although this database 

was designed to simplify the processing of airmen medical certification 

information, Aerospace Medicine also uses it as a tool to oversee aviation 

medical examiner designees and monitor their activity levels. For instance, 

regional FAA flight surgeons use information from the database to 

determine if they need to more closely monitor aviation medical examiners 

with high activity levels or to determine how long it takes to transmit 

medical information to FAA. Each flight surgeon is periodically provided 

performance data for their designees that include the number of medical 

certificates issued by each designee, the number of errors found in those 

certificates, and the number of accidents and incidents involving pilots that 

received medical certificates from designated medical examiners, 

according to an Aerospace Medicine official. Additionally, according to 

FAA officials, regional flight surgeons also use data from the database and 

link it with the Airmen Registry to determine the region where FAA needs 

additional examiners. Applying this model to Flight Standards Service and 

Aircraft Certification Service would provide those offices and inspectors 

and engineers with more detailed performance information on designees 

and provide a foundation for more consistent oversight of the numerous 

designee programs.
Page 39 GAO-05-40 Designee Programs

FAA officials agreed that improvements were needed to these databases, 

but expressed a concern that it would cost $50 million to make upgrades, 

which may have implications for other safety programs that would then 

receive less funding. Such concerns might be addressed by looking for 

ways to share the costs of the designee programs with the aviation industry, 

similar to other federal agencies that charge user fees to process 

applications for approvals or licenses. For instance, the Federal Drug 

Administration charges pharmaceutical companies application fees to 

recover the cost of the agency’s review of new drugs.32 As another example, 

U.S. Customs and Border Protection charges fees to brokers—private 

individuals and companies that are licensed and regulated by the agency to 

aid importers and exporters in moving merchandise through Customs. 

Brokers pay Customs a $100 permit application fee and a $125 annual user 

fee. FAA does not charge designees an initial application fee or a renewal 

fee, which could help recover the cost of processing these applications, 

because it has been prohibited in law from promulgating new user fees 

since 1997.33 Moreover, designees charge companies and the general public 

fees to have a product certified or to perform a pilot practical test. Some 

designees earn up to $60,000 or more a year and have made designated 

activities their sole source of income. FAA inspectors, engineers, and flight 

surgeons, on the other hand, provide the same service free as a function of 

their government employment. In prior reports, we have stated our belief 

that, to the extent possible, commercial users of the aviation system should 

pay their share of the costs that they impose on the system.34 Charging fees 

to designees to offset the cost to FAA to administer the designee programs 

is an analogous situation.

Conclusions Designees perform a valuable function for FAA and the aviation industry, 

enabling FAA to leverage its staff resources and industry to obtain FAAissued certificates in a timely manner. By using designees, however, FAA 

places great trust in the integrity and honesty of designees to adhere to the 

same requirements, instructions, and procedures as FAA staff do; 

32The user fee program was established by the Prescription Drug User Fee Act of 1992.

33P.L. 105-66 (October 27, 1997).

34GAO, Transportation Financing: Challenges in Meeting Long-Term Funding Needs for 

FAA, Amtrak, and the Nation’s Highways, GAO/T-RCED-97-151 (Washington, D.C.: May 7, 

1997); GAO, Airport and Airway Trust Fund: Issues Raised by Proposal to Replace the 

Airline Ticket Tax, GAO/RCED-97-23 (Washington, D.C.: Dec. 9, 1996).
Page 40 GAO-05-40 Designee Programs

therefore, periodic validation and consistent oversight by FAA staff is 

necessary to ensure that such trust is well placed. To date, FAA has not 

ensured that the oversight process for its many designee programs is 

implemented consistently by different field offices. While we did not find 

systematic safety problems associated with FAA’s oversight of designees, 

the agency’s inconsistent oversight limits its assurance that the designees’ 

work is performed in accordance with the agency’s standards and policies. 

We found examples of weaknesses in FAA’s designee programs—such as 

inspectors with too great a workload to conduct required surveillance of 

designees—that underscore the need for FAA to ensure that its staff are 

consistently following agency policy concerning designee oversight and to 

validate those policies and their application by periodic evaluations. 

However, FAA has evaluated only 6 of its 18 designee programs to date. Our 

study indicated that reasons for FAA’s inconsistent oversight may include 

limitations on designee data that FAA maintains, along with heavy 

workload, and potentially inadequate training for FAA staff overseeing 

designees. FAA lacks a comprehensive information system to effectively 

monitor and oversee the thousands of activities performed by designees. 

Without such information, FAA management cannot readily determine 

whether its field staff is overseeing designees according to policy nor 

whether designees are performing according to FAA’s standards. Heavy 

workload for FAA staff responsible for overseeing designees might 

preclude thorough assessment—or any assessment—of some designees’ 

performance. Finally, by not requiring refresher training for FAA staff, the 

agency increases the risk that staff do not retain the information, skills, and 

competencies required to perform their oversight responsibilities. Potential 

opportunities exist for FAA to address these weaknesses and provide more 

consistent oversight of the designee programs by expanding the use of 

existing agency practices, such as the Office of Aerospace Medicine’s 

practice of maintaining information on aviation medical examiners 

performance and activity levels and using that information in conjunction 

with designee oversight. Charging application and renewal fees to 

designees to help offset the cost of administering these programs would be 

in line with practices by other agencies and prior GAO reports on costsharing with the aviation industry. However, FAA is prohibited, by law, 

from imposing new user fees unless they are specifically authorized by law. 

It is especially important for FAA to consider ways to improve the oversight 

of its designee programs as the agency moves forward with the 

organization designation authorization program, which would expand the 

number and types of organizational designees and further transform FAA’s 

role to that of monitoring the performance of others. Moreover, concerns 
Page 41 GAO-05-40 Designee Programs

have been raised that under the proposed program FAA would provide less 

specific and less technical oversight of the new organizational designees 

than under the current program. Expanding the use of good oversight 

practices already used within FAA for some designee programs and 

examining lessons that may be learned from Canada’s oversight of 

organizational designees and efforts suggested by our expert panel, would 

increase FAA’s assurance that its designees are meeting FAA safety 

standards and that any future changes to the designee programs maintain 

those standards.

Recommendations for 

Executive Action

To improve management control of the designee programs, and thus 

increase assurance that designees meet FAA’s performance standards, GAO 

recommends that the Secretary of Transportation direct the FAA 

Administrator to take the following three actions:

1. Establish a program to evaluate all designee programs, placing a 

priority on those 12 programs that have not been evaluated. At a 

minimum, the evaluations should examine field office compliance with 

existing policies, identify root causes of noncompliance with those 

policies, and establish and monitor corrective action plans.

2. Develop mechanisms to improve the compliance of FAA program and 

field offices with existing policies concerning designee oversight. The 

mechanisms should include additional training for staff who directly 

oversee designees. As part of this effort, FAA should identify best 

oversight practices that can be shared by all FAA program and field 

offices and lessons learned from the program evaluations and 

incorporate, as appropriate, suggestions from our expert panel.

3. Enhance the effectiveness of FAA designee oversight tools, such as 

databases, by improving the consistency and completeness of 

information on designees’ activities and performance and FAA 

oversight. To the extent necessary, FAA should examine charging fees 

to designees to help pay for the costs of such efforts. If FAA identifies a 

need for such fees, the agency should request the Congress to authorize 

them.

Agency Comments We provided a draft of this report to DOT for review and comment. FAA’s 

Deputy Associate Administrator for Regulation and Certification and other 
Page 42 GAO-05-40 Designee Programs

DOT officials provided oral comments. DOT generally agreed with our 

recommendations and acknowledged that automating the data concerning 

oversight of designees and enhancing training for FAA employees who 

oversee designees are useful steps to enhance the programs. The 

department also provided clarifying comments and technical corrections, 

which we incorporated as appropriate. In addition, the department noted 

that designee programs have been a cornerstone of aviation safety for 50 

years. The constantly improving level of safety in the U.S. aviation system 

is due, in no small measure, to the professional performance of the 

thousands of designees who evaluate aircraft designs, assess pilot 

capability, or conduct the myriad of other reviews designees perform, 

according to DOT. DOT also pointed out that statistics and data show that 

every day of the year, the pilots and aircraft that pass through these 

designee systems fly safely from departure to destination.

However, DOT officials expressed concern about the use of the Delphi 

method in our review of 18 different programs with nearly 14,000 

designees. First, they emphasized that, at best, the Delphi method provides 

a means to consolidate and prioritize expert opinion, but even under the 

best of circumstances, the results are opinion, not necessarily factual data. 

The use of Delphi was further complicated in this particular case, 

according to DOT, by the span of knowledge that would be necessary to be 

considered an “expert” on designees when the scope of expertise runs from 

aviation medicine, to aircraft engineering and production methods, to 

parachute rigging. They stated that no individual could be considered an 

expert in all the programs, and the solicitation of opinions from the panel 

of experts would reflect the specific experience of each individual—but 

could not be considered a general statement of the strengths or 

weaknesses of all the programs. By consolidating the responses from 

individuals with expertise from these diverse fields, the officials questioned 

whether the results could be useful for guiding decisions to improve any of 

the individual designee programs. Further, the DOT officials cautioned that 

the Delphi results should be carefully qualified in the final report, along 

with explicit statements about the limitations on the use of the information. 

We disagree with DOT’s characterization of our use of the Delphi method; 

furthermore, we believe we used this methodology (which is described in 

detail in app. I) appropriately. In particular, we used a “modified” version of 

the Delphi method in order to compensate for some the limitations 

inherent in the Delphi method as well as to adapt the method to the specific 

needs of this engagement. For example, we created a Web-based panel that 

allowed us to include many more experts than had we convened a live 
Page 43 GAO-05-40 Designee Programs

panel. In addition, the Web-based panel allowed us to keep the experts’ 

identities anonymous, minimizing the biasing effects often associated with 

live group discussions. We also carefully selected the experts starting with 

a list provided by FAA, and took into consideration that not all of the 

panelists would possess expertise in many of the designee programs. To 

help adjust for that fact, during the first round of questions, we asked 

experts to indicate if their responses referred only to specific designee 

programs and, in a few cases, experts indicated such. During the second 

round, the experts were given the choice of responding to each question 

that they did not know or had no opinion. In short, while DOT criticizes the 

responses from the experts as “opinions,” we believe the responses are 

more appropriately characterized as carefully considered judgments of 

systematically selected experts. Lastly, as described below, the report only 

focuses on issues that were identified by the panel and other sources.

Second, in reviewing a draft of this report, DOT officials expressed concern 

about the way the Delphi results had been presented. They emphasized, for 

example, that while the draft mentioned the number of respondents who 

considered a factor a “great” or “very great” weakness, the draft should also 

state the number who considered a factor “no” weakness or of “little” 

weakness. Presenting what DOT considers both ends of the response 

spectrum in the body of the report would allow a full understanding of the 

results, according to the department. We agreed that the number of experts 

responding “no” and “little” should also be presented whenever the 

responses to individual questions were mentioned in the report, and we 

revised the report accordingly.

Finally, DOT officials emphasized the need to consider, what they called, 

the “totality” of the questions and responses in order to evaluate any 

inconsistencies among responses. For example, they said that while our 

report uses the responses from a single question to indicate concern 

regarding the selection process for designees, the responses from other 

questions could be interpreted to conclude that there was little concern 

about the competency of the designees that were selected or the quality of 

their work. Taken together, these officials felt that these responses in total 

present a different perspective on the outcome of the designee selection 

process than the first question alone. DOT officials stated that our 

highlighting the responses to one question and not balancing it with the 

results of others, presents an incomplete picture of the panel’s overall 

findings and could mislead those who read the report but do not look at the 

details in appendix IV. We disagree with DOT’s characterization of our 

analysis. First, we considered all responses from the expert panel and 
Page 44 GAO-05-40 Designee Programs

provided them in their entirety in the appendix. Furthermore, for the body 

of the report, we only focus on issues that were identified by multiple 

sources. For example, the report highlights the issue of selecting designees 

based on personal association because it was identified by other sources 

during our field work and our review of prior evaluations of the designee 

programs. Other issues raised by some of the panel experts concerning the 

selection process were not identified by other work we conducted and, 

therefore, not highlighted in the report.

As agreed with your office, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 21 days from the 

report date. At that time, we will send copies of this report to interested 

congressional committees, the Secretary of Transportation, and the 

Administrator, FAA. We will also make copies available to others upon 

request. In addition, the report will be available at no charge on the GAO 

Web site at http://www.gao.gov.

Please call me at (202) 512-2834 if you or your staff have any questions 

concerning this report. Major contributors to this report are listed in 

appendix V.

Sincerely yours,

JayEtta Z. Hecker

Director, Physical Infrastructure Issues
Page 45 GAO-05-40 Designee Programs

Appendix I

Objectives, Scope, and Methodology ApApenednxidexiIs

This report addresses the following research questions: (1) What are the 

strengths of FAA’s designee programs? (2) What are the weaknesses of the 

programs and the factors that contribute to those weaknesses? and (3) 

What can be done to address the identified weaknesses or otherwise 

improve the programs?

To address these questions, we used a variety of methods and sources of 

information. We obtained and analyzed data for fiscal years 1998 through 

2003 from four Federal Aviation Administration (FAA) databases1

 that 

maintain records on designees. We assessed the reliability of the databases 

by (1) performing electronic testing of required data elements; (2) 

reviewing existing information about the data and the system that 

produced them; and (3) interviewing agency officials knowledgeable about 

the data to learn how the information system was structured, controlled, 

and used. We determined that the data were sufficiently reliable for our 

purposes of describing the number of designees by program, identifying the 

geographical location of designees, and calculating the number of 

designees per FAA staff responsible for designee oversight. However, we 

found that specific data needed for oversight were not found in some 

databases, as we discuss in this report.

In addition, we reviewed FAA program guidance concerning designee 

management to obtain an understanding of designee roles and 

responsibilities. We did not verify how FAA delegates authorized functions 

and what certification activities were delegated. We also reviewed FAA’s 

Notice of Proposed Rulemaking on the organization designation 

authorization program and public comments on the proposed rule, 

conducted computer literature searches to obtain information on other 

countries’ designee programs, and interviewed officials from the Canadian 

civil aviation authority. In addition, we reviewed past studies, by us and 

others, of FAA’s designee programs. (See the bibliography at the end of this 

report.) We identified recommendations that had been made to improve the 

programs and determined whether those recommendations had been acted 

upon by the agency. Information obtained from the reports and the 

databases was not equally comprehensive and available for all types of 

designees. 

1

The four databases are the (1) National Vital Information Subsystem, (2) Program Tracking 

and Reporting Subsystem, (3) Designee Information Network, and (4) Airmen Medical 

Certification Information Subsystem.
Appendix I

Objectives, Scope, and Methodology

Page 46 GAO-05-40 Designee Programs

We obtained information and data on FAA’s designee programs on visits to 

four locations--Los Angeles, Seattle, Atlanta, and Oklahoma City. We 

selected the locations based on (1) number of designees in the region; (2) 

activity-level of designees; (3) ratio of inspectors, engineers, or flight 

surgeons to designees; and (4) location of both Aircraft Certification 

directorate offices and Flight Standards Service regional offices. 

Additionally, these offices were selected because of the following: (1) the 

Seattle office has the largest number of aircraft certification designees, (2) 

the Atlanta office has the largest number of flight standards designees 

along with the most certification activity, and (3) the Oklahoma City office 

manages some designee data and is the location of FAA’s training institute. 

We interviewed individual FAA inspectors and engineers who oversee 

designees at the offices we visited as well as officials from the National Air 

Traffic Controllers Association and Professional Airway System 

Specialists—unions that represent FAA inspectors and engineers. We also 

interviewed designees in Los Angeles, Seattle, and Atlanta. The cities and 

organizations where we conducted our work are shown in table 5.

Table 5: Organizations Interviewed by GAO During Site Visits

Location Type of entity Organization

Seattle, WA, area Federal government FAA’s Office of Aircraft Certification

• Transport Airplane Directorate 

• Manufacturing Inspection Office

• Manufacturing Inspection District Office

• Manufacturing Inspection Satellite Office

• Boeing Certificate Management Office

FAA’s Office of Aerospace Medicine 

FAA’s Office of Flight Standards Service, Northwest Mountain Region

• Seattle Flight Standards District Office

Organizational designated 

airworthiness representative

The Boeing Company

Designated airworthiness 

representative

Pacific Propellers

Designated alteration station Goodrich Aviation Technical Services, Inc.

Special Federal Aviation Regulations 

No. 36, repair station

Alaska Airlines
Appendix I

Objectives, Scope, and Methodology

Page 47 GAO-05-40 Designee Programs

Source: GAO.

In addition, we convened a Web-based panel of experts selected for their 

knowledge and expertise in the area of FAA’s designee programs. An initial 

list of experts was identified through referrals by FAA officials, the 

National Air Traffic Controllers Association, the Professional Airway 

System Specialists, and the Aerospace Repair Station Association and 

through citations in the literature on aviation. We then asked these initially 

identified experts for additional experts. We continued this process until 

we had about 10 to 20 experts in each of four categories: (1) designees, (2) 

FAA inspectors and engineers, (3) independent experts and university 

academics, and (4) private sector and aviation industry associations. (See 

app. II for the list of participating experts.)

Atlanta, GA, area Federal government FAA’s Office of Aircraft Certification

• Small Airplane Directorate

FAA’s Office of Aerospace Medicine

FAA’s Office of Flight Standards Service, Southern Region

• Flight Standards Regional Office

Designated engineering representative • Garrett Aviation

• Propulsion Consultants Inc.

• Delta Airlines

Los Angeles, CA, 

area

Federal government FAA’s Office of Aircraft Certification

• Manufacturing Inspection District Office

FAA’s Office of Aerospace Medicine

FAA’s Office of Flight Standards Service, Western Pacific Region

• Los Angeles Flight Standards District Office

• Riverside Flight Standards District Office

Designated pilot examiner Aviation Services

Designated airworthiness 

representative/Designated 

engineering representative

CDO Associates

Oklahoma City, OK, 

area

Federal government FAA’s Aviation Data Systems

FAA’s Designee Standardization Branch

FAA’s Delegation and Continued Airworthiness Programs Branch

FAA’s Medical Systems Branch

FAA’s Aerospace Medical Education Division

FAA’s Civil Aerospace Medical Institute

FAA’s Aerospace Human Factors Research Division

FAA’s Office of Flight Standards Service, Southwest Region

• Oklahoma City Flight Standards District Office

(Continued From Previous Page)

Location Type of entity Organization
Appendix I

Objectives, Scope, and Methodology

Page 48 GAO-05-40 Designee Programs

To structure and gather expert opinion from the panel, we employed a 

modified version of the Delphi method.2

 To obtain opinions from the large, 

diverse group of experts, we incorporated an iterative and controlled 

feedback process—an important feature of the Delphi method. We did not 

encourage experts to arrive at a consensus nor make forecasts. During this 

process, we obtained opinions from the experts using questionnaires 

administered over the Internet. The experts’ identities were kept 

anonymous during this step of the process. The anonymity of this approach 

helped minimize potential biasing effects often associated with live group 

discussions. Biasing effects of live expert discussion sessions may include 

the dominance of individuals and group pressure for conformity.3

 The 

dominance bias would tend to limit the input of less dominant individuals, 

and the group pressure bias would tend to suppress true opinion, 

particularly on more controversial issues. These concerns were 

particularly important given the need for a broad range of expertise from 

individuals with varying backgrounds and perspectives. Also, by creating a 

Web-based panel we were able to include many more experts than we 

could have if we had convened a live panel.

In the first phase of the expert panel, which ran from October 2 to 31, 2003, 

we asked the panelists to respond to three open-ended questions: (1) What, 

if any, are the three most significant strengths of the FAA designee 

programs? (2) What, if any, are the three most significant weaknesses of the 

FAA designee programs? And (3) What, if any, are your suggestions for 

addressing the weaknesses of or otherwise improving the FAA designee 

programs? We further asked them to indicate those responses that referred 

only to specific types of designees. The three questions, based on our study 

objectives, were pre-tested to ensure that the questionnaire was clear and 

unambiguous, did not place undue burden on individuals completing it, and 

was independent and unbiased. We made relevant changes before we 

deployed the first questionnaire to all participants on the Internet.

2

For examples of recent use of this methodology see, GAO, Drinking Water: Experts’ Views 

on How Future Federal Funding Can Best Be Spent to Improve Security, GAO-04-

29 (Washington, D.C.: Oct. 31, 2003); International Trade: Experts’ Advice for Small 

Businesses Seeking Foreign Patents, GAO-03-910 (Washington, D.C.: June 26, 2003); 

Economic Models of Cattle Prices: How USDA Can Act to Improve Models to Explain 

Cattle Prices, GAO-02-246 (Washington, D.C.: Mar. 15, 2002); Environmental Protection: 

Federal Incentives Could Help Promote Land Use That Protects Air and Water Quality, 

GAO-02-12 (Washington, D.C.: Oct. 31, 2001).

3

James P. Wright, “Delphi-Systematic Opinion Gathering,” The GAO Review (Spring 1972): 

20-27.
Appendix I

Objectives, Scope, and Methodology

Page 49 GAO-05-40 Designee Programs

We performed a content analysis of the responses to the open-ended 

questions in order to compile a list of all the strengths, weaknesses, and 

improvements mentioned by the experts. We contacted the experts, when 

necessary, if responses were unclear. About 25 percent of the coded 

responses were reviewed by an independent coder to ensure that the initial 

coding decisions were consistent and valid. To maintain standards of 

methodological integrity, any disagreements in coding between the coder 

and reviewer were discussed until consensus was reached.

The content coded results from the phase I questionnaire consisted of a list 

of distinct and specific strengths, weaknesses, and suggested 

improvements, which were used to construct the phase II questionnaire. 

The phase II questionnaire also served as a feedback mechanism to the 

panelists about what other experts thought were important strengths and 

weaknesses. The phase II questionnaire was also pre-tested, revised, and 

then administered on the Internet from January 5 to March 30, 2004. 

In phase II, the panelists rated the strengths, weaknesses, and suggested 

improvements on various relevant dimensions using a five-category scale 

(e.g., “no weakness” to “very great weakness,” or “definitely infeasible” to 

“definitely feasible”). In analyzing the responses to the phase II 

questionnaire, we calculated the frequency of responses to identify the 

strongest levels of opinions on each item regarding the strength, weakness, 

or attractiveness (based on importance and feasibility) of suggested 

improvements. We ranked the results based on the number of responses at 

the top two categories (e.g., the number of “great weakness” and “very 

great weakness” responses) that were rated as the more frequently 

identified responses.

Initially, 78 experts agreed to participate in the panel. Fifty-eight panelists 

actually completed the phase I questionnaire, resulting in a response rate of 

74 percent. There was some attrition during the subsequent phase. Of the 

76 experts who agreed to participate in phase II, 62 actually completed the 

questionnaire (including some who did not participate in phase I). This 

resulted in a 82 percent response rate for phase II (see table 6).
Appendix I

Objectives, Scope, and Methodology

Page 50 GAO-05-40 Designee Programs

Table 6: The Number of Panelists Participating in Each Phase and Response Rate

Source: GAO.

We conducted our work between April 2003 and October 2004 in 

accordance with the generally accepted government auditing standards.

Phase

Experts who agreed to 

participate

Experts responding to 

questionnaire

Response rate in 

percentile

I 78 58 74%

II 76 62 82%
Page 51 GAO-05-40 Designee Programs

Appendix II

Experts Participating on GAO’s Panel ApendxiI

Independent expert or 

university affiliation

Roger Bacchieri, Chair, Air Traffic Management Division, Daniel Webster College

Patricia Backer, Chair, Department of Aviation and Technology, San Jose State University 

William Caldwell, Chair, Department of Aviation, Central Missouri State University 

Thomas J. Connolly, Associate Dean, College of Aviation, Embry-Riddle Aeronautical University

Bart J. Crotty, Aviation Safety/Security Consultant, former FAA Airworthiness Inspector, former FAA 

Designated Airworthiness Representative

Alfred Dickinson, Director, Aviation Safety Program, University of Southern California 

Carey L. Freeman, Chair, Aviation Department, Hampton University

Jim Frisbee, Aviation Consultant, former Director of Quality Assurance, Northwest Airlines

Larry Gross, Associate Professor of Aviation Technology, Purdue University

Gary Kitely, Executive Director, Council on Aviation Accreditation

Nick Lacey, Aviation Consultant, Mortem Beyer and Agnew, former Director of FAA’s Flight Standards 

Service

Doug Latia, Associate Professor, Aviation Technology Department, Purdue University

Fred Leonelli, former manager of FAA’s Aircraft Maintenance Division

Kent Lovelace, Chair, Department of Aerospace, University of North Dakota

Jacqueline B. Sanders, Assistant to the Provost, Mercer County Community College

Glynn Dale Sistrunk, Chair, Department of Professional Aviation, Louisiana Tech University
Appendix II

Experts Participating on GAO’s Panel

Page 52 GAO-05-40 Designee Programs

Source: GAO.

Note: In addition, to the experts listed above, 7 inspectors from FAA’s Flight Standards Service, 10 

engineers from FAA’s Aircraft Certification Service, and 1 other designee participated on the panel. 

Aviation industry Mark Arcelle, Senior Manager of Fleet Engineering, FedEx Express

Melissa Bailey, Vice President of Air Traffic Regulation and Certification, Aircraft Owners and Pilots 

Association 

Tony Broderick, Aviation Safety Consultant, former FAA Associate Administrator

Eric Byer, Manager of Government Industry Affairs, National Air Transportation Association

Aubrey Carter, General Manager of Enabling Technology, Delta Airlines

Elias Cotti, Director of Technical Operations, National Business Aviation Association 

Brian Finnegan, President, Professional Aviation Maintenance Association

John Frisbee, Manager of Quality Assurance, Champion Airline

Rick Hoy, Manager, Regulatory Compliance, Delta Airline

Sarah Macleod, Executive Director, Aeronautical Repair Station Association

Doug MacNair, Vice President, Government Relations, Experimental Aircraft Association

Nick Mateo, Senior Director, Technical Services, Continental Airlines

Thomas McSweeny, Director of International Safety and Regulatory Affairs, Boeing, former FAA 

Associate Administrator of Regulation and Certification, former FAA Director of Aircraft Certification 

Service 

Rick Oehme, Vice President, Quality and Engineering, America West Airlines

Richard Peri, Vice President, Government and Industry Affairs, Aircraft Electronic Association

Robert Robeson, Jr., Vice President of Civil Aviation, Aerospace Industries Association

Stan Sorscher, Labor Representative, Society of Professional Engineering Employees in Aerospace

Ronald Swanda, Vice President of Operations, General Aviation Manufacturers Association

Mark Szkirpan, Senior Specialist of Regulatory Affairs, American Airlines

Designees David Bryman, D.O., Senior Aviation Medical Examiner

Thomas W. Carroll, Designated Airworthiness Representative, former FAA Supervisory Aviation Safety 

Inspector

Harold Coralnick, M.D., Senior Aviation Medical Examiner

Dominick P. DaCosta, Designated Airworthiness Representative, Designated Engineering 

Representative, Chief Executive Officer of DERS Group Inc.

Joseph Kilpatrick, Designated Engineering Representative 

Osvaldo Lopez, Designated Engineering Representative

Joe Norris, Designated Airworthiness Representative

David Orfant, CDO Associates, Designated Airworthiness Representative (Manufacturing and 

Maintenance), Designated Engineering Representative

Thomas C. Willis, Designated Airworthiness Representative (Maintenance) 

(Continued From Previous Page)
Page 53 GAO-05-40 Designee Programs

Appendix III

Roles and Responsibilities of Designees ApendxiI

Designee type Responsibilities

Individual designees

Aviation Medical Examiners Authorized to accept applications and perform physical examinations necessary to determine 

qualification for the issuance of airman medical certificates and combined medical/student pilot 

certificates. Designees can issue, defer, or deny the certificates, as appropriate.

Designated Engineering 

Representatives 

Authorized to examine and approve certain engineering technical data for their employer. 

Designees can either be employed by a company or act as free agents.

Designated Manufacturing Inspection 

Representatives 

Authorized to perform conformity inspectionsa and issue airworthiness certificates and approvals 

for products and parts produced by FAA-approved production approval holders.b

 Production 

approval holders or its authorized suppliers employ this type of designee. 

Training Center Evaluators Authorized to accept applications and conduct practical tests leading to the issuance of pilot and 

flight instructor certificates. 

Designated Pilot Examiners Authorized to accept applications for flight tests, conduct those tests, and issue temporary pilot 

certificates to qualified applicants.

Aircrew Program Designees Authorized to perform airman certification in one type of aircraft for an operator’s pilots who have 

been trained under the operator’s FAA-approved training program. 

Designated Airworthiness 

Representatives (maintenance)

Authorized to perform certain inspections, including issuing recurrent airworthiness certificates 

and approvals for maintenance conducted by repair stations and air carriers. 

Designated Airworthiness 

Representatives (manufacturing)

Authorized to perform conformity inspections, issue airworthiness certificates and approval for 

products and parts produced by FAA-approved production approval holders. Designees are 

independent individuals, but may be employed by the production approval holder. 

Designated Mechanic Examiners Authorized to accept applications for and conduct oral and practical tests for issuing mechanic 

certificates. 

Designated Parachute Rigger 

Examiners

Authorized to accept applications for, and conduct, oral and practical tests for issuing parachute 

rigger certificates. 

Designated Aircraft Dispatcher 

Examiners

Authorized to accept applications for, and conduct, written and practical tests necessary for 

issuing aircraft dispatcher certificates and, at the discretion of a local Flight Standards inspector, 

issue temporary aircraft dispatcher certificates to qualified applicants.

Designated Flight Engineer 

Examiners 

Authorized to perform airman certification for an operator’s flight engineer candidates who have 

been trained under the operator’s FAA-approved training program. 

Computer Testing Designee Authorized to administer computerized airman knowledge tests through computer test sites 

located throughout the United States and authorized foreign locations. 

Organizational designees

Organizational Designated 

Airworthiness Representatives 

(maintenance)

Organizations that (1) hold repair station certificates with appropriate ratings or air carrier 

operating certificates with FAA-approved Continuous Airworthiness Maintenance programs and 

(2) are authorized to issue recurrent airworthiness certificates and export airworthiness 

approvals for certain products. 

Organizational Designated 

Airworthiness Representatives 

(manufacturing)

Organizations that hold FAA production approvals and are authorized to issue airworthiness 

certificates and approvals and make conformity determinations.
Appendix III

Roles and Responsibilities of Designees

Page 54 GAO-05-40 Designee Programs

Source: GAO analysis of FAA documents.

a

Conformity inspection is an assessment necessary to determine that aviation products and related 

parts conform to an approved design and can be operated safely.

b

Production approval holders are aircraft manufacturers that hold a type or production certificate and 

can produce modification or replacement parts.

c

Prototype conformity inspection is an examination to verify an applicant’s compliance with federal 

regulations and determine that prototype products and related parts conform to proposed design 

drawings and specifications.

Designated Alteration Stations Companies that hold a current domestic repair station certificate and are manufacturers of a 

product for which they have alteration authority. The designees are authorized to issue 

supplemental type certificates, perform prototype conformity inspections,c

 and issue 

experimental airworthiness certificates for the purpose of flight-testing and the standard 

airworthiness certificate after the supplemental type certificate has been issued. 

Special Federal Aviation Regulations 

No. 36, Repair Stations

Companies that are authorized to generate engineering technical data that are acceptable to the 

FAA. These data can be used only by the specific designee for major repairs.

Delegation Option Authorizations Companies that are authorized to obtain type certificates, approve type design changes, conduct

conformity inspections, and issue airworthiness certificates and approvals.

(Continued From Previous Page)

Designee type Responsibilities
Page 55 GAO-05-40 Designee Programs

Appendix IV

Survey Instrument and Results ApendxiIV

This appendix presents the results from the expert panel on the identified 

strengths, weaknesses, and what can be done to address the program 

weaknesses or otherwise improve the designee programs. Included here 

are the questions and the ranking of responses developed based on the 

frequency of responses to questions that were completed by members of 

the panel selected for this study (referred to as “phase I” and “phase II”). 

We administered the questionnaires for phases I and II over the Internet.

As discussed in appendix I, in phase I of the expert panel, we asked the 

panelists to respond to open-ended questions about the identified 

strengths, weaknesses, and the potential of other alternatives to improve 

FAA’s designee programs. We performed a content analysis on the 

responses to the open-ended questions in order to develop close-ended 

questions for phase II of the expert panel. The purpose of the second phase 

was to provide the panelists with the opportunity to consider the other 

panelists’ responses to the first phase and to respond in a structured, 

quantifiable way. Phase II consisted of 64 closed-ended questions on the 

categorized responses to phase I. Sixty-two of the 76 experts completed 

the phase II survey (about 82 percent response rate). Table 7 summarizes 

the results from phase II, ranked based on the number of responses at the 

top two points on the categories (e.g., the number of “great” and “very 

great” responses) that were rated as the more frequently identified 

responses. 

Table 7: Experts’ Responses to GAO’s Survey

Strengths of FAA’s designee programs

1. How important, if at all, is each of the following strengths of FAA’s designee programs toward accomplishing FAA’s 

safety responsibilities?

Strengths No Some Moderate Great

Very 

great

Don’t 

know / 

No 

opinion

No 

response

a. Use of designees expands available FAA 

resources. 0 3 9 16 33 1 0

b. Use of designees allows for more timely 

approvals than by not using designees. 0 3 10 15 33 1 0

c. Use of designees expands available 

technical expertise. 2 2 11 19 27 1 0

d. Use of designees enables FAA staff to 

concentrate on other areas of aviation safety. 2 5 13 19 20 2 1
Appendix IV

Survey Instrument and Results

Page 56 GAO-05-40 Designee Programs

Strengths of FAA’s designee programs

e. Designees provide greater scheduling 

flexibility and access to the public. 1 7 12 12 27 2 1

f. Use of designees allows for greater 

geographic coverage. 3 7 12 15 23 1 1

g. Designees also perform liaison role 

improving relations between FAA and 

aviation community. 5 12 16 19 7 3 0

h. Designees help educate FAA engineers and 

inspectors. 10 7 15 17 8 4 1

i. Designees provide consistent certification 

because they receive recurrent training. 7 14 16 13 7 4 1

j. Designees provide a pool of resources from 

which to draw when filling positions at FAA. 11 15 16 10 4 5 1

Weaknesses of FAA’s designee programs

2. How much of a weakness is each of the following factors related to the workload of FAA inspectors and aircraft 

certification engineers who oversee designees?

Factors No Little Moderate Great

Very 

great

Don’t 

know/ 

No 

opinion

No 

response

a. Numbers of FAA inspectors and engineers 

not increasing commensurate with industry 

growth. 1 5 17 12 20 7 0

b. Backlog of work submitted by designees 

awaiting approval/concurrence by FAA. 2 6 18 16 11 8 1

c. FAA inspectors and engineers do not have 

enough time to provide adequate oversight of 

designees for whom they are responsible. 5 4 16 17 10 8 2

d. Insufficient number of FAA 

inspectors/engineers compared with 

designees to provide adequate oversight. 3 8 23 13 8 7 0

e. Applies only to Designated Pilot Examiners 

(DPE): High turnover rate of FAA inspectors 

responsible for overseeing DPEs. 2 2 7 5 2 25 19

3. How much of a weakness is each of the following factors related to the designee selection process?

Factors No Little Moderate Great

Very 

great

Don’t 

know / 

No 

opinion

No 

response

a. Local FAA offices appoint designees based 

on personal associations rather than 

qualifications and experiences. 7 15 12 10 11 7 0

b. Shortage of designees in some geographic 

areas and in certain specializations. 4 6 23 15 5 9 0

c. FAA limits the number of designees. 8 7 18 13 7 8 1

(Continued From Previous Page)
Appendix IV

Survey Instrument and Results

Page 57 GAO-05-40 Designee Programs

Weaknesses of FAA’s designee programs

d. FAA does not follow its own selection criteria. 4 17 13 11 8 8 1

e. The selection process lacks sufficient rigor to 

ensure that designees are competent and 

will perform high quality work. 3 22 14 9 9 4 1

f. Variation in the qualifications of designees. 3 19 19 13 4 3 1

g. The application process for becoming a 

designee takes a long time. 8 18 15 10 3 8 0

h. The selection process is not well defined. 8 24 13 8 4 4 1

4. How much of a weakness is each of the following factors related to designee activities?

Factors No Little Moderate Great

Very 

great

Don’t 

know / 

No 

opinion

No 

response

a. Applicants for certification shop for “easy” 

designees. 0 11 14 11 18 6 2

b. Employer pressure of financial incentives 

may lead to conflicts of interest. 10 13 15 8 12 4 0

c. Some applicants for certification are 

unfamiliar with FAA requirements and 

designee’s authority limits. 7 12 21 12 6 1 3

d. Designees’ fees are inconsistent and 

unregulated. 8 15 12 9 8 7 3

e. Designees perform beyond their delegated 

authority. 7 21 10 10 6 6 2

f. Designees provide inconsistent service. 6 14 25 9 6 2 0

g. Designees perform more activities in less 

time than standards would seem to require. 8 19 11 10 4 9 1

h. Designees are not current on regulations and 

orders 11 19 18 9 4 1 0

i. Designees are constrained geographically. 9 20 15 10 3 3 2

j. Companies with organizational designations 

appoint inexperienced engineers to make 

approvals and do not train them in the 

certification process. 8 12 8 5 7 19 3

k. Erroneous certification by designees 7 18 15 5 7 7 3

l. Designees do not understand their full 

authority. 8 19 18 5 6 4 2

m. The current scope of organizational 

delegation is narrow. 9 18 10 8 3 12 2

n. Designees perform outside of their 

jurisdiction without the knowledge and 

authorization of local FAA offices. 9 17 12 5 4 15 0

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Page 58 GAO-05-40 Designee Programs

Weaknesses of FAA’s designee programs

o. Limitations on the approval authority of 

designees. 10 23 16 5 2 4 2

p. Applies only to Designated Mechanic 

Examiners: Inflexible procedures for testing 

candidates for A&P certificates. 4 3 6 2 2 25 20

5. How much of a weakness is each of the following factors related to FAA oversight?

Factors No Little Moderate Great

Very 

great

Don’t 

know / 

No 

opinion

No 

response

a. FAA offices’ level of oversight and 

interpretation of rules are inconsistent. 2 5 17 16 20 0 2

b. Inactive, unqualified, or poor performing 

designees are not identified or removed 

expeditiously. 1 8 22 15 12 3 1

c. It is difficult to terminate poor performing 

designees. 2 9 16 6 17 12 0

d. Inadequate surveillance and oversight of 

designees. 6 13 15 8 14 4 2

e. FAA has not made oversight of designees a 

high enough priority. 4 9 18 12 8 8 3

f. Multitude of bulletins, advisory circulars, and 

other documents from FAA have resulted in 

conflicting information and procedures. 1 11 23 10 10 2 5

g. FAA management does not agree with 

engineers’ or inspectors’ judgment about 

disciplining or removing poor performing 

designees. 4 11 7 9 10 18 3

h. Oversight process is burdensome for FAA 

staff. 6 11 17 8 10 9 1

i. Designees are not held accountable for their 

findings. 10 19 8 7 11 5 2

j. FAA does not terminate poorly performing 

organizational designees because that would 

put an entire company out of business. 4 13 10 9 8 17 1

k. FAA does not have adequate authority to 

impose penalties on certain types of 

designees. 9 14 11 8 8 10 2

l. Lack of FAA process to evaluate the 

designee programs. 5 11 19 10 5 7 5

m. Lack of independent review of data. 

Designees perform the analysis of the data 

that they then approve. The data are not 

reviewed by a different person. 6 15 10 9 5 12 5

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Weaknesses of FAA’s designee programs

n. FAA engineers duplicate efforts of 

designees.

4 20 8 4 6 17 3

o. FAA engineers are reluctant to delegate 

routine activities to designees. 6 11 10 6 4 21 4

p. FAA management pressures FAA engineers 

to give designees’ findings less scrutiny than 

standards require. 4 14 3 1 9 25 6

q. FAA inspectors and engineers lack the level 

of professional experience necessary to 

oversee designees. 9 19 12 7 2 9 4

r. The designee programs lack formal methods 

of appeal when designees’ privileges are 

revoked. 14 13 12 5 2 12 4

s. Designees as well as the FAA 

inspectors/engineers who oversee them have 

little or no familiarity with the products upon 

which findings are being made. 6 23 12 2 4 10 5

t. FAA field office staffs do not have complete 

knowledge of designees within their 

jurisdictions. 5 13 23 3 3 10 5

u. Applies only to Aviation Medical Examiners 

(AME): Error letters are inaccurate indicators 

of an AME’s performance. 1 0 3 1 1 31 25

6. How much of a weakness is each of the following factors related to training for designees, FAA inspectors, and FAA 

engineers?

Factors No Little Moderate Great

Very 

great

Don’t 

know / 

No 

opinion

No 

response

a. FAA engineers and inspectors do not receive 

adequate training in designee oversight. 6 6 12 14 7 12 5

b. Lack of adequate and accessible designee 

training. 5 15 19 10 4 5 4

c. Designees are technically well versed in the 

area in which they are authorized but poorly 

educated in the relevant regulations. 8 22 13 7 5 3 4

d. Seminar instructors for designee training are 

not current or knowledgeable in the subject 

matter. 14 12 14 6 4 8 4

e. Training disparity between FAA engineers 

and designees results in designees being 

more current on new orders, advisories, and 

policies. 12 13 10 4 5

13

5

Overall Weaknesses of FAA’s Designee Programs

7. How much weakness, overall, is there in each of the following main areas of FAA’s designee programs?

(Continued From Previous Page)
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Page 60 GAO-05-40 Designee Programs

Weaknesses of FAA’s designee programs

Weakness No Little Moderate Great

Very 

great

Don’t 

know / 

No 

opinion

No 

response

a. FAA oversight 2 10 18 14 12 5 1

b. Workload of FAA inspectors and aircraft 

certification engineers who oversee 

designees. 4 5 16 15 11 10 1

c. Training for FAA inspectors and FAA 

engineers who oversee designees. 3 5 18 12 10 11 3

d. Designee selection process. 4 18 15 10 7 6 2

e. Training for designees 7 13 17 11 6 4 4

f. Designee activities. 6 20 12 12 4 6 2

Addressing Weaknesses with or Otherwise Improving FAA Inspector/engineer Workload

8. Increase the number of engineers/inspectors so that FAA staff have more time available for oversight of designees.

Questions No Low Some High

Highest

Don’t 

know / 

No 

opinion

No 

response

a. How important is it to implement this 

improvement? 4 10 14 17 12 4 1

b. How feasible is it to implement this 

improvement? 2 8 21 12 11 7 1

9. Increase the priority given to the oversight of designees within FAA.

a. How important is it to implement this 

improvement? 2 8 17 24 4

5

2

b. How feasible is it to implement this 

improvement? 0 6 13 21 14 6 2

10. Establish specific ratio for FAA engineers/inspectors to designees.

a. How important is it to implement this 

improvement? 5 15 11 15 6 8 2

b. How feasible is it to implement this 

improvement? 0 6 16 13 16 8 3

Addressing Weaknesses with or Otherwise Improving the Designee Selection Process

11. Select designees according to their qualifications and experience rather than on personal associations with FAA 

managers.

a. How important is it to implement this 

improvement? 0 6 7 19 28 1 1

b. How feasible is it to implement this 

improvement? 1 2 6 10 40 2 1

12. Clearly define and consistently follow the criteria for selecting designees.

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Improving FAA’s designee programs

a. How important is it to implement this 

improvement? 0 5 7 23 24 1 2

b. How feasible is it to implement this 

improvement? 1 1 7 24 24 3 2

13. Establish a review process for determining demand for designees by type, specialty, activity level, and geographic 

location.

a. How important is it to implement this 

improvement? 5 9 20 16 8 2 2

b. How feasible is it to implement this 

improvement? 3 1 11 28 11 4 4

14. Streamline procedures for the appointment of designees.

a. How important is it to implement this 

improvement? 4 15 18 14 7 3 1

b. How feasible is it to implement this 

improvement? 1 1 15 25 16 3 1

15. Centralize the designee selection process.

a. How important is it to implement this 

improvement? 16 6 14 14 9 2 1

b. How feasible is it to implement this 

improvement? 7 9 13 14 13 5 1

Addressing Weaknesses with or Otherwise Improving Designee Activities

16. Improve FAA communication with designees, including communications on regulations and orders and complicated 

certification situations.

a. How important is it to implement this 

improvement? 0 8 8 24 18 3 1

b. How feasible is it to implement this 

improvement? 0 0 5 28 23 4 2

17. Clarify designations, including authority and limits.

a. How important is it to implement this 

improvement? 1 8 8 25 14 4 2

b. How feasible is it to implement this 

improvement? 0 1 5 24 25 5 2

18. Make company or organizational designees part of a different group within the company than the group seeking the 

certification.

a. How important is it to implement this 

improvement? 6 6 13 14 14 8 1

b. How feasible is it to implement this 

improvement? 3 8 11 17 13 9 1

19. Determine if there are additional safety-critical areas that should be beyond the scope of designees’ authority.

a. How important is it to implement this 

improvement? 5 8 12 16 12

8

1

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Improving FAA’s designee programs

b. How feasible is it to implement this 

improvement? 2 4 11 21 15 8 1

20. Provide individual designees with identification cards listing their delegated authorizations that could be requested by 

and displayed to customers.

a. How important is it to implement this 

improvement? 6 7 17 11 16 3 2

b. How feasible is it to implement this 

improvement? 1 0 9 16 30 5 1

21. Increase FAA participation in complex approvals conducted by a Designated Alteration Station (DAS).

a. How important is it to implement this 

improvement? 1 5 9 14 13 17 3

b. How feasible is it to implement this 

improvement? 0 0 5 22 14 18 3

22. Implement FAA’s Organization Designation Authorization proposal and provide training for FAA employees on how to 

oversee a delegated organization.

a. How important is it to implement this 

improvement? 8 5 9 14 12 11 3

b. How feasible is it to implement this 

improvement? 1 3 8 21 13 13 3

23. Require designees performing work outside of their geographic boundaries to notify their home FAA office and the FAA 

office where the work is being performed.

a. How important is it to implement this 

improvement? 8 11 13 16 8 4 2

b. How feasible is it to implement this 

improvement? 2 2 4 18 27 5 4

24. Implement legislative proposal to establish “certified design organizations” (also called “design organization 

certificates”).

a. How important is it to implement this 

improvement? 14 5 9 8 7 16 3

b. How feasible is it to implement this 

improvement? 2 6 15 10 9 17 3

25. Develop a fee structure of what designees may charge.

a. How important is it to implement this 

improvement? 23 16 5 8 7 1 2

b. How feasible is it to implement this 

improvement? 9 12 10 9 13 5 4

26. Provide designees with broader authority.

a. How important is it to implement this 

improvement? 13 16 13 11 3 4 2

b. How feasible is it to implement this 

improvement? 3 2 17 24 9 4 3

27. Make public the fees charged by designees.

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Improving FAA’s designee programs

a. How important is it to implement this 

improvement? 20 12 14 5 7 2 2

b. How feasible is it to implement this 

improvement? 9 4 17 11 15 4 2

28. Establish a standard for limiting the number of certifications that a designee can perform in a given period of time.

a. How important is it to implement this 

improvement? 23 14 10 9 2 3 1

b. How feasible is it to implement this 

improvement? 8 11 15 13 8 6 1

29. Assign designees to applicants instead of allowing applicants to choose designees.

a. How important is it to implement this 

improvement? 24 13 11 4 4 4 2

b. How feasible is it to implement this 

improvement? 12 10 12 9 9 8 2

Addressing Weaknesses with or Otherwise Improving FAA Oversight

30. Hold designees accountable for their findings.

a. How important is it to implement this 

improvement? 1 0 4 22 31 0 4

b. How feasible is it to implement this 

improvement? 0 3 6 16 30 2 5

31. Ensure that FAA employees who oversee designees are knowledgeable about the regulations, policies, and processes 

applicable to the designee’s particular specialization.

a. How important is it to implement this 

improvement? 0 0 6 17 32 1 6

b. How feasible is it to implement this 

improvement? 0 0 6 19 30 2 5

32. Increase penalties (including the ability to terminate their status as designees) for individual and organizational 

designees found to violate standards or who do not exercise proper judgment.

a. How important is it to implement this 

improvement? 4 3 8 15 28 2 2

b. How feasible is it to implement this 

improvement? 0 2 4 27 24 3 2

33. Establish strict criteria and process for identifying and removing designees that are underperforming, unqualified, or 

inactive.

a. How important is it to implement this 

improvement? 0 7 11 20 22 2 0

b. How feasible is it to implement this 

improvement? 0 1 11 22 25 2 1

34. Improve coordination among the regional offices and headquarters to standardize designee oversight.

a. How important is it to implement this 

improvement? 1 3 15 20 18 2 3

b. How feasible is it to implement this 

improvement? 1 4 9 24 18 3 3

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Improving FAA’s designee programs

35. Obtain feedback from users, designees, and other stakeholders regarding the certification process and quality of 

oversight.

a. How important is it to implement this 

improvement? 2 5 14 18 19 1 3

b. How feasible is it to implement this 

improvement? 0 4 6 28 17 3 4

36. Conduct audits to determine if designees have been given adequate oversight.

a. How important is it to implement this 

improvement? 0 7 15 26 9 2 3

b. How feasible is it to implement this 

improvement? 0 3 9 27 16 4 3

37. Improve FAA’s public relations with those in the aviation community who use designees by providing timely, 

knowledgeable responses to public inquiries.

a. How important is it to implement this 

improvement? 3 2 16 22 12 3 4

b. How feasible is it to implement this 

improvement? 0 1 8 29 15 5 4

38. Establish a “whistleblower” program that would grant protection to FAA employees who identify problems with the 

designee programs.

a. How important is it to implement this 

improvement? 10 4 9 17 15 3 4

b. How feasible is it to implement this 

improvement? 4 9 8 16 18 3 4

39. Develop competency testing and performance standards for designees.

a. How important is it to implement this 

improvement? 3 9 14 18 13 1 4

b. How feasible is it to implement this 

improvement? 3 6 11 21 13 3 5

40. Increase the support by FAA management of engineers’ and inspectors’ judgment about disciplining poor performing 

designees.

a. How important is it to implement this 

improvement? 2 8 9 18 12 7 6

b. How feasible is it to implement this 

improvement? 2 4 15 17 11 6 7

41. Develop a formal process of appeal for designees facing discipline or termination.

a. How important is it to implement this 

improvement? 1 8 14 19 9 4 7

b. How feasible is it to implement this 

improvement? 1 1 10 20 18 6 6

42. Increase requirements for oversight and surveillance to be conducted by FAA inspectors and engineers.

a. How important is it to implement this 

improvement? 8 6 11 17 11 4 5

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Improving FAA’s designee programs

b. How feasible is it to implement this 

improvement? 4 4 18 14 12 6 4

43. Choose FAA aircraft certification offices with oversight responsibility based on their knowledge of the product involved 

rather than the geographic location of the designee.

a. How important is it to implement this 

improvement? 5 6 11 18 8 7 7

b. How feasible is it to implement this 

improvement? 2 4 15 13 11 10 7

44. Renew designees based on performance standards, rather than allowing renewal to be automatic.

a. How important is it to implement this 

improvement? 4 11 13 12 14 3 5

b. How feasible is it to implement this 

improvement? 2 3 11 20 18 4 4

45. Make FAA engineers responsible for understanding and approving the results of designee actions rather than checking 

only the paperwork associated with those actions.

a. How important is it to implement this 

improvement? 8 9 9 12 12 6 6

b. How feasible is it to implement this 

improvement? 6 9 10 15 9 7 6

46. Reduce the administrative (paperwork) burden of designee oversight.

a. How important is it to implement this 

improvement? 3 8 18 19 5 4 5

b. How feasible is it to implement this 

improvement? 3 5 18 18 8 6 4

47. Establish a panel of senior FAA inspectors/engineers to review allegations of impropriety by designees. Provide the 

panel with the authority to improve penalties.

How important is it to implement this 

improvement? 6 12 14 11 12 5 2

How feasible is it to implement this 

improvement? 5 7 16 14 12 6 2

48. Develop an automated system to allow designees to complete and submit documents electronically only when they are 

done correctly.

How important is it to implement this 

improvement? 5 11 14 16 7 4 5

How feasible is it to implement this 

improvement? 1 5 14 19 12 6 5

49. Develop specific statements or checklists that identify the steps in the certification process and the extent of the 

designee’s authority.

How important is it to implement this 

improvement? 4 5 24 16 4 4 5

How feasible is it to implement this 

improvement? 1 1 17 21 11 7 4

50. Eliminate geographic boundaries imposed on aircraft certification designees.

(Continued From Previous Page)
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Page 66 GAO-05-40 Designee Programs

Improving FAA’s designee programs

How important is it to implement this 

improvement? 10 7 9 9 10 12 5

How feasible is it to implement this 

improvement? 2 3 10 14 12 15 6

51. Have FAA inspectors and engineers who oversee designees report to a central FAA focal point who is independent of 

their supervisors.

How important is it to implement this 

improvement? 11 5 17 13 3 8 5

How feasible is it to implement this 

improvement? 5 8 19 11 6 7 6

52. Prohibit designees from approving any documents that they have produced.

How important is it to implement this 

improvement? 12 13 9 6 9 8 5

How feasible is it to implement this 

improvement? 8 7 11 10 13 8 5

53. Applies only to Designated Engineering Representatives (DER): Make the selection and oversight process for company 

DERs the same as for consultant DERs.

How important is it to implement this 

improvement? 5 4 12 8 7 16 10

How feasible is it to implement this 

improvement? 0 2 8 14 11 17 10

54. Limit the ability of designees to contest their removal.

How important is it to implement this 

improvement? 20 15 9 7 4 6 1

How feasible is it to implement this 

improvement? 7 7 18 12 9 7 2

Addressing Weaknesses with or Otherwise Improving Training

55. Improve availability of training for FAA inspectors and engineers to advance technical competence related to oversight 

of designees.

How important is it to implement this 

improvement? 2 4 8 20 22 3 3

How feasible is it to implement this 

improvement? 1 1 7 30 16 3 4

56. Ensure standard training of designees within specific specialties to improve consistency of their work.

How important is it to implement this 

improvement? 1 3 14 20 20 0 4

How feasible is it to implement this 

improvement? 1 3 9 24 20 1 4

57. Require consistent training for all designees with the same skill designation to improve the consistency among 

designees.

How important is it to implement this 

improvement? 1 6 13 27 13 0 2

(Continued From Previous Page)
Appendix IV

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Page 67 GAO-05-40 Designee Programs

Source: GAO analysis of expert panel information.

Improving FAA’s designee programs

How feasible is it to implement this 

improvement? 0 5 6 31 16 1 3

58. Increase number of subject matter workshops for designees, with instruction provided by industry experts, FAA 

specialists, engineers, and designees.

How important is it to implement this 

improvement? 1 5 11 23 17 1 4

How feasible is it to implement this 

improvement? 0 1 13 22 20 2 4

59. Require FAA inspectors and engineers to receive recurrent training related to the oversight of designees.

How important is it to implement this 

improvement? 2 3 14 22 14 3

4

How feasible is it to implement this 

improvement? 1 2 10 27 14 4 4

60. Require additional training for designees in regulations that apply to their work.

How important is it to implement this 

improvement? 1 10 14 22 9 2 4

How feasible is it to implement this 

improvement? 0 0 10 32 15 2 3

61. Improve and expand designee training, including routine skills testing.

How important is it to implement this 

improvement? 2 11 11 16 15 2 5

How feasible is it to implement this 

improvement? 2 4 13 24 12 3 4

62. Have experienced designees mentor designee candidates.

How important is it to implement this 

improvement? 3 6 19 23 6 1 4

How feasible is it to implement this 

improvement? 2 3 18 18 15 1 5

63. Make the training and standardization seminar for designees an annual requirement.

How important is it to implement this 

improvement? 9 5 15 13 15 1 4

How feasible is it to implement this 

improvement? 4 3 11 23 16 1 4

64. Applies only to Designated Alteration Station (DAS): Require additional training for FAA inspectors and engineers in 

areas such as designee selection and oversight, regulations that pertain to the activities of designees, and the 

recognition of a management structure that provides appropriate direction and support for DAS operations. 

How important is it to implement this 

improvement? 1 2 6 10 13 18 12

How feasible is it to implement this 

improvement? 0 2 6 11 14 18 11

(Continued From Previous Page)
Page 68 GAO-05-40 Designee Programs

Appendix V

GAO Contacts and Staff Acknowledgments ApendxiV

GAO Contacts JayEtta Z. Hecker (202) 512-2834

Gerald Dillingham (202) 512-2834

Teresa Spisak (202) 512-3952

Staff 

Acknowledgments

In addition to the above individuals, Howard Cott, Colin Fallon, Isidro 

Gomez, Curtis Groves, Brandon Haller, David Hooper, Jennifer Kim, Rosa 

Leung, Elizabeth A. Marchak, and Larry Thomas made key contributions to 

this report.
Page 69 GAO-05-40 Designee Programs

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