Future of Aviation Advisory Committee

Aviation Safety Subcommittee

Record of Meeting

November 17, 2010

General Aviation Manufacturers Association

Washington, DC

1

Public Announcement

The U.S. Department of Transportation (DOT), Office of the Secretary of Transportation, told the 

public of this Future of Aviation Advisory Committee (FAAC) Aviation Safety Subcommittee meeting 

in a Federal Register notice published November 3, 2010 (75 FR 67805).

Subcommittee Members in Attendance

Name Affiliation(s)

Nicole W. Piasecki 

(Subcommittee 

Chair)

Vice President, 

Business Development

Boeing Commercial Airplanes (Boeing)

Juan J. Alonso1 Associate Professor, 

Department of Aeronautics and 

Astronautics

Stanford University

Susan M. Baer1 Director, Aviation Department Port Authority of New York & New Jersey

(PANY/NJ)

John M. Conley International Administrative 

Vice President and 

Air Transport Division Director

Transport Workers Union of America 

(TWU), American Federation of Labor and 

Congress of Industrial Organizations 

(AFL-CIO)

Daniel Grace Safety Manager, 

Flight Operations

Cessna Aircraft Company (Cessna)

Robert L. Lekites President United Parcel Service Airlines (UPS)

William J. McGee Travel and Aviation Consultant Consumers Union

Steve Predmore 

(attending for Mr. 

Barger)

Vice President of Safety JetBlue Airways Corporation (JetBlue)

Other Officials Present

Name Affiliation(s)

Tony Fazio Designated Federal Official Federal Aviation Administration (FAA)

Arnold Konheim Alternate Designated Official DOT

Susan Kurland Assistant Secretary for Aviation 

and International Affairs

(FAAC Chair)

DOT

 

1 By phone.
Future of Aviation Advisory Committee

Aviation Safety Subcommittee

Record of Meeting

November 17, 2010

General Aviation Manufacturers Association

Washington, DC

2

Other Persons Present

Name Affiliation(s)

Bob Bergman UPS

Patty Clark PANY/NJ

Andy Compart Aviation World/Aviation Daily

Mike Derrick PAI Consulting

Steve Douglas FAA

Paul Feldman General Aviation Manufacturers Association (GAMA)

Kate Fraser GAMA

Keith Hagy Air Line Pilots Association (ALPA)

Krister Holladay1 Goodrich

Dean Hubbard TWU

Aloha Ley DOT

Brian McCullagh FAA

Bill Mosely DOT

Tim Neale Boeing

Salli Rowe FAA

Mont Smith Air Transport Association (ATA)

David Traynham Boeing

Daniel Zuspan Boeing

BACKGROUND AND WELCOMING REMARKS

This is the record of the fifth meeting of the Aviation Safety Subcommittee of the FAAC, a 

Federal advisory committee formed pursuant to and subject to the requirements of the Federal Advisory 

Committee Act (FACA).

Ms. Nicole Piasecki, Subcommittee Chair, Boeing, called the meeting to order at 8:41 a.m. 

She welcomed the subcommittee members and members of the public in attendance and opened the 

meeting by asking the members to introduce themselves to the subcommittee. The members 

made introductions.

Mr. Tony Fazio, FAA, read the formal statement required under FACA. He noted the meeting is 

recorded and asked the subcommittee to give supporting documents to Mr. Mike Derrick, 

PAI Consulting, for posting to the docket. Ms. Piasecki stated that the subcommittee needed to ratify 

the minutes from the previous meeting, and asked if any of the members had suggested revisions. No 

revisions were offered, and the minutes were ratified.

 

1 By phone.
Future of Aviation Advisory Committee

Aviation Safety Subcommittee

Record of Meeting

November 17, 2010

General Aviation Manufacturers Association

Washington, DC

3

OPENING DISCUSSION

Ms. Piasecki stated the objective of the meeting was to finalize the subcommittee’s recommendations 

for submission to the DOT on November 22, 2010 to allow adequate time for their review and 

inclusion in briefing packages for the final FAAC meeting on December 15, 2010. She thanked the 

subcommittee for their substantive inputs to the recommendations document since last month’s 

meeting. Ms. Piasecki added that Mr. William McGee, Consumers Union, would cover the issue of 

how best to include the issue on use of child restraint systems on aircraft in the recommendations 

document, and that portions of the presentation by Mr. Brad Brugger, TWU, from the subcommittee’s 

August 24, 2010 meeting would be considered for inclusion in the recommendations document.

RECOMMENDATIONS PAPER DISCUSSION

Ms. Piasecki asked Mr. David Traynham, Boeing, to cover changes made to the subcommittee’s draft 

recommendations, an internal working document for use by the subcommittee, since the last meeting

on October 19, 2010. Mr. Traynham noted the version distributed to the subcommittee members was 

largely the same as they had seen at the last meeting.

Background Section

Mr. Traynham explained the wording on a “just” safety culture that had been added on page 2 of the 

recommendations paper was largely based on the presentation given by Mr. Brugger at the 

subcommittee’s August 24, 2010 meeting. Ms. Piasecki suggested an edit to Mr. Traynham to clarify

the need to capture data from ground maintenance employees, which seemed to be excluded by use of 

the phrase, “data collected on flights.” Mr. Keith Hagy, ALPA, suggested that air carrier maintenance 

and flight attendant employee groups have recently established Aviation Safety Action Programs, and 

those may be worthy of mention when clarifying which air carrier employees are submitting voluntary 

safety data. Mr. Traynham noted the changes.

Discussion continued to page 3 of the document, and Ms. Piasecki asked if the subcommittee was 

comfortable with the language on Safety Management Systems (SMS). Mr. Fazio explained that the 

FAA had recently published a notice of proposed rulemaking on SMS that mandates its implementation 

at air carriers. Mr. Steve Predmore, JetBlue, added that SMS lays out authorities and responsibilities in

a safety culture, and provided a suggested edit to the SMS language.

Mr. Hagy pointed out that use of the phrase, “large airline accidents,” in the background section could 

be misleading, and suggested a broader term be used to reflect that the subcommittee was discussing all 

air carrier accidents, not just those that have occurred at the largest airlines. The subcommittee agreed 

with Mr. Hagy’s input, citing the need to be inclusive of the aviation industry as a whole.

Legal Protection of Voluntary Safety Data

Mr. Traynham then discussed the issue of increased legal protections of voluntary safety data. He 

explained the expandsion of the problem/challenge statement to capture the distinctions of the industry 

operating under a purely voluntary nature versus the future under mandated SMS programs. Mr. Fazio 
Future of Aviation Advisory Committee

Aviation Safety Subcommittee

Record of Meeting

November 17, 2010

General Aviation Manufacturers Association

Washington, DC

4

asked for clarification of the term “study,” and whether it simply was a request for a study or formation 

of a committee to explore the topic. Ms. Susan Baer, PANY/NJ, added her belief that the 

subcommittee should recommend that the Secretary of Transportation should propose legislation to 

better protect voluntary safety data. Ms. Baer further stated her belief that the subcommittee was 

asking for more than just a study, and the subcommittee agreed. Changes in the wording of the 

recommendation were discussed, and Mr. Fazio suggested that addition of the phrase, “with industry 

stakeholder input,” could be helpful in crafting the recommendation.

Mr. Daniel Zuspan, Boeing, asked for clarification of the use of the terms, “safety data” and “safety 

information,” and whether they were one and the same. Mr. Predmore and Mr. Hagy offered 

clarification and added information about the request for safety data from plaintiffs’ attorneys in the 

case of an aircraft accident involving a Comair Airlines flight at Lexington, Kentucky to further explain 

the subcommittee’s intent with this recommendation. Mr. Predmore suggested the problem/challenge 

statement for this recommendation needed some clarification. Mr. Traynham asked Mr. Predmore to 

submit his suggested revisions to better state the problem.

Analytic Capabilities for Safety Data and Information

Mr. Traynham continued to the second recommendation in the paper suggesting a shift from traditional 

forensic safety studies to more predictive searches for future vulnerabilities by increasing analytic 

capability for parties that analyze safety data and information. Ms. Piasecki suggested the word 

“predictive” be used in the title and the recommendation to better clarify the subcommittee’s intent on 

this topic. Mr. Juan Alonso, Stanford University, noted that in being predictive the subcommittee also 

has to anticipate the introduction of risk as new technologies, including the Next Generation 

Air Transportation System (NextGen), are implemented. He agreed to provide suggested edits to 

Mr. Traynham. Mr. Zuspan added that he believed an additional sentence was needed detailing the 

culture change within the federal government required to accomplish this recommendation. The 

subcommittee agreed.

Expanding Sources of Voluntary Safety Data

Mr. Traynham continued to the third issue area, expanded sources of voluntary safety data. Mr. McGee 

suggested the addition of aircraft dispatchers to the potential sources for expansion. Mr. Fazio 

proposed broadening the language to capture other communities, including general aviation. 

Mr. Zuspan noted that Aviation Rulemaking Committees (ARC) and other advisory committees could 

be sources of data, as well. Mr. Fazio suggested use of the term “advisory bodies” as a broad term to 

capture ARCs and other committees. Ms. Susan Kurland, DOT, suggested “other constituencies” as a 

term to more broadly capture the intent of the subcommittee. The subcommittee further discussed 

language for this recommendation, and Ms. Piasecki asked that suggestions be sent to Mr. Traynham.
Future of Aviation Advisory Committee

Aviation Safety Subcommittee

Record of Meeting

November 17, 2010

General Aviation Manufacturers Association

Washington, DC

5

NextGen and Enhanced Safety Performance

Mr. Traynham stated the fourth recommendation was to incorporate safety enhancements into 

implementation of NextGen. Mr. Zuspan cautioned the subcommittee that this was an area where 

duplication with existing work being done by other parties was a concern, and suggested language to 

note that the subcommittee was not attempting to replicate existing efforts. The subcommittee agreed. 

Mr. Hagy added that there are a vast number of entities involved with NextGen. Ms. Kurland asked 

whether the recommendation needed more specific language, or if the work of an existing body needed 

expanding. Ms. Baer expressed her concern that the suggested steps may cause the recommendation to 

become overly prescriptive. Mr. Alonso agreed.

Ms. Kurland asked for the subcommittee’s input on improving the recommendation. Mr. Predmore 

suggested language to capture the subcommittee’s intent to embed enhanced safety performance into 

NextGen without being overly prescriptive. The subcommittee agreed with the suggested language and 

acknowledged the need to give the Secretary of Transportation leeway to determine how best to 

implement safety enhancements in NextGen, and Mr. Predmore agreed to provide his revisions 

to Mr. Traynham.

Ms. Piasecki sought to clarify the subcommittee’s intent on how to acknowledge the vast amount of 

NextGen work underway through multiple parties. Ms. Kurland suggested that placing language in the 

problem/challenge statement of the recommendation may be helpful.

Mr. McGee brought up a theory previously discussed by the subcommittee at prior meetings, stating 

that risk is inherent with new technologies, and the need to capture that theory within the rationale of 

this recommendation. Ms. Piasecki agreed, and asked Mr. McGee to provide suggested language 

to Mr. Traynham.

Identification of Safety Priorities

Mr. Traynham stated the focus of recommendation number 5 pertains to prioritizing aviation safety

issues, as there are a multitude of safety initiatives championed by interest groups and 

recommendations from government agencies and committees. He stated the need to focus on the large 

areas of concern, while not expending limited resources on issues with little potential for enhancing 

aviation safety. Mr. Traynham explained the subcommittee’s recommendation would propose the 

Secretary of Transportation determine a methodology to effectively prioritize aviation safety initiatives 

to ensure that those having the most benefit are the top priority for implementation. Mr. Predmore 

asked if the problem was actually too many regulations, or a lack of methodology to determine 

priorities. Mr. Fazio stated that both of these were problematic for the FAA. He noted that the 

subcommittee’s recommendation should take both into account and state the need to determine how to 

effectively implement the most needed safety initiatives.
Future of Aviation Advisory Committee

Aviation Safety Subcommittee

Record of Meeting

November 17, 2010

General Aviation Manufacturers Association

Washington, DC

6

Mr. Feldman asked for clarification on whether all proposed regulations affecting aviation safety would 

go through this envisioned process. Mr. Fazio stated he did not envision all regulations doing so, and 

likely it would be around 40 percent of the FAA’s rulemaking activities that would be rational for such 

a process. Ms. Kurland asked whether the description of this recommendation needed clarification on 

this matter and whether a team of experts was needed to develop a prioritization methodology. 

Mr. Fazio agreed and noted the need to collaborate on the topic because of the number of parties and 

agencies involved. Ms. Baer cited the need to strengthen the recommendation without being overly 

prescriptive. The subcommittee further discussed how to word the recommendation.

Mr. Robert Lekites, UPS, raised the issue that in an SMS-based safety culture, data originates from the 

air carriers on a multitude of parameters, and he sees a challenge for regulators to determine how to use 

the data to the benefit of aviation safety, rather than for enforcement. Ms. Piasecki clarified with the 

subcommittee where Mr. Lekites’ comments were most pertinent in the recommendations document. 

Mr. Lekites added that there is a tremendous amount of safety data available to the aviation industry, 

including unstabilized approaches, encounters with terrain, and others. He noted the large volume of 

data was beneficial but questioned how it is best used. Mr. Predmore cited the work of the Commercial 

Aviation Safety Team as an example of using data to improve aviation safety.

Ms. Piasecki offered her opinion that Mr. Lekites’ comments were best suited for recommendation 

number 5. The subcommittee further discussed placement of the comments and suggested language. 

Mr. Fazio stated there was also a need to eliminate “personalization” of safety initiatives, such as an 

action championed by a single air carrier or industry association, through an industry-accepted 

methodology for prioritization of safety initiatives. Mr. Predmore noted this was essentially SMS for 

the regulator, and several subcommittee members expressed agreement. Mr. Fazio expressed 

reservation, as it seemed to him two critical issues were being combined into one. Mr. Predmore stated 

that the need for a prioritization methodology should capture this issue. Ms. Piasecki asked 

Mr. Predmore and Mr. Fazio to work with Mr. Zuspan to finalize the language.

Mr. McGee asked if language to solicit input from foreign carriers would be useful. He also added that 

smaller carriers may not have the resources to do the level of work that the larger carriers are doing. 

Mr. Zuspan asked Mr. Lekites to clarify his thoughts on the link between data collection and 

decisionmaking on regulations. A short discussion followed and potential language was captured.

Mr. John Conley, TWU, asked if the phrase, “truly important,” which referred to safety initiatives, was 

necessary. After a short discussion, the subcommittee deleted the entire sentence containing this 

statement from the recommendations document. Mr. Hagy discussed the need to incorporate SMS 

principles into field enforcement of regulations. He stated the headquarters level of federal agencies

may embrace programs, but sometimes the principles of these programs don’t make it to the field level. 

Mr. Daniel Grace, Cessna added that change management is a critical portion of SMS, and that it is 

important to include this philosophy in execution of an SMS program. Ms. Piasecki clarified the 

subcommittee’s intent on the topic and asked for any further input. There were no further comments.
Future of Aviation Advisory Committee

Aviation Safety Subcommittee

Record of Meeting

November 17, 2010

General Aviation Manufacturers Association

Washington, DC

7

Child Safety on Airliners

Recommendation number 6 covered safety issues of small children flying in passengers’ laps on 

air carrier aircraft. Mr. McGee noted that consumer stakeholders have reviewed the language, and that 

he felt it was unnecessary to further discuss the topic due to previous discussions at the subcommittee’s 

meetings. Mr. Fazio expressed his concern with the phrase “potentially flawed” used to describe FAA’s 

methodology associated with diversion for child safety seat use on air carrier aircraft. Mr. McGee 

explained that the more accurate meaning was that the methodolody was outdated, and many changes 

had occurred in the aviation industry since it was completed. Mr. Fazio expressed satisfaction with 

Mr. McGee’s clarification, and they agreed to work together on refining the language in the 

recommendation.

Mr. Alonso noted the need to cite sources when discussing studies in the recommendations to give 

added credibility, rather than using a generic phrase, such as “scientific research.” The subcommittee 

agreed. Mr. Feldman asked if the approach given in this recommendation was too specific, as all of the 

subcommittee’s other recommendations dealt with broad actions the Secretary of Transportation could 

take. The subcommittee discussed how to ensure the recommendation was suggestive, as opposed to 

prescriptive, and how best to word the subject of public awareness of the dangers of small children 

flying in adults’ laps. Several examples of lack of awareness were raised based on the subcommittee 

members’ own experiences and observations, and input given to them by air carrier employees.

Mr. Predmore asked if it would be appropriate to mention in the rationale for this recommendation why 

it was more specific than the others. The subcommittee briefly discussed the need for modification of 

the rationale but ultimately decided to leave the wording as it was.

Mr. Hagy asked a general question on the lack of security topics in the subcommittee’s 

recommendations, noting this was his first attendance at one of the meetings. Ms. Piasecki clarified 

that the subcommittee charter focused solely on safety topics. She suggested this may be beneficial to 

state in the introduction to the recommendations, and the subcommittee agreed. Ms. Kurland asked 

whether it would be beneficial to mention the cooperative relations with the Department of 

Homeland Security and Transportation Security Administration (TSA) in the introduction, as well. The 

subcommittee agreed it may be beneficial.

Ms. Piasecki called for a break at 10:02 a.m., and the meeting resumed at 10:18 a.m.
Future of Aviation Advisory Committee

Aviation Safety Subcommittee

Record of Meeting

November 17, 2010

General Aviation Manufacturers Association

Washington, DC

8

Single Safety Standard for Aircraft Maintenance

Ms. Piasecki cited the extensive discussions on contract aircraft maintenance that have occurred at 

previous subcommittee meetings and briefly summarized the topic based on previous discussions with 

Mr. Conley and Mr. McGee. She added that several subcommittee members have discussed positive 

experiences with contract maintenance providers. Ms. Piasecki stated that based on the previous 

discussions, it was not evidently clear that this was a safety issue, there was a general lack of data to 

support it as a concern, and that there was not consensus among the subcommittee members on the 

topic. She stated that a paper titled “Is There a Single Safety Standard for Maintenance of all 

U.S. Aircraft? Should There Be?” from Mr. Dean Hubbard, TWU, had been circulated to the 

subcommittee members for their consideration.

Ms. Piasecki turned the discussion over to Mr. Conley for his views on the topic. He reviewed his 

thoughts on the need for a single standard for conduct of criminal history records checks, background 

checks, and drug and alcohol testing for personnel performing aircraft maintenance, regardless of 

where the work occurs, including outside the United States.

Ms. Piasecki noted Mr. Hubbard’s paper referenced a report by the DOT Office of Inspector 

General (OIG), and asked Mr. Fazio for his input. Mr. Fazio stated he had concerns with some areas of 

Mr. Hubbard’s paper, and that they could work together to correct them. He asked Mr. Steve Douglas, 

FAAAircraft Maintenance Division, for his input on the topic. Mr. Douglas began by explaining 

standard terms used by the FAA to describe what is commonly referred to as “outsourced 

maintenance,” stating that it is better described as “contract maintenance” completed by “maintenance 

providers.” He then highlighted the FAA’s progress on complying with the OIG’s recommendations in 

the report and stated they continue to work with the OIG to update them on the FAA’s progress. 

Mr. Douglas noted the FAA has validated documents and processes put into place after the OIG 

investigation, and has revised processes put in place from 2001 right up to the investigation because 

they were already in need of updating.

Mr. Douglas continued the discussion, and covered the differences between FAA certificated repair 

stations in the United States and foreign countries. Mr. Fazio added that a notice of proposed 

rulemaking issued by the TSA addressed many of Mr. Conley’s concerns over the security of foreign 

repair stations. Mr. Douglas agreed, provided a brief summation of some of the changes that the 

proposed regulation would implement, and stated that the TSA expected to finalize the rule in 

early 2011.
Future of Aviation Advisory Committee

Aviation Safety Subcommittee

Record of Meeting

November 17, 2010

General Aviation Manufacturers Association

Washington, DC

9

Mr. McGee asked for clarification of the terms “contract maintenance” and “maintenance provider.” 

Mr. Douglas provided further explanation. Mr. McGee asked how these terms differed from 

“outsourced maintenance.” Mr. Douglas explained that the terms are based on regulatory language and 

are more standard. Mr. Hagy raised the issue of coordination between safety and security agencies on 

oversight of repair stations. Mr. Fazio explained that the FAA inspects repair stations certificated under 

Title 14, Code of Federal Regulations part 145, both in the United States and abroad but that TSA has 

the mandate to develop security requirements for foreign repair stations. It was noted that the FAA and 

TSA had coordinated on inspections of foreign repair stations. Mr. Fazio stated that FAA and TSA had 

coordinated on the TSA NPRM proposal and even noted that the TSA lead for the rule is a former FAA 

employee.

A brief discussion of the bilateral agreement process and general discussion of the safety and security 

of repair stations in foreign countries followed. Ms. Piasecki expressed that it seemed to her the 

subcommittee was suggesting global harmonization and cooperation between government agencies to 

obtain consistent standards among repair stations, regardless of where they are located.

Mr. Hubbard began to discuss his paper, covering three topics he believed were gaps in safety: 

non-certificated repair stations, whether the FAA has adequate resources to oversee all maintenance 

providers, and a lack of security standards and alcohol/drug testing programs at foreign repair stations. 

He stated he would like to take one more opportunity for the subcommittee to achieve consensus on 

this topic. Mr. Douglas explained air carrier oversight of maintenance providers, and the use of 

certificated and non-certificated providers. He noted the FAA approves the air carriers’ standards, and 

the maintenance providers have to the meet the air carriers’ standards.

Mr. Douglas then covered the process of air carriers sending on-site representatives to accompany their 

aircraft during heavy maintenance events performed by maintenance providers. He noted there are 

multiple layers of people overseeing the process, regardless of whether the facility was certificated or 

not. Mr. Hubbard agreed that the oversight of contract maintenance is complex and still evolving, and 

suggested that continuing dialogue on the topic among aviation industry stakeholders is prudent.

Ms. Piasecki stated that in an SMS environment, the air carrier is ultimately accountable for the work 

conducted on its aircraft. Mr. Hubbard agreed but noted as the transition away from maintenance 

performed by the air carriers themselves to contracted maintenance continues, in the view of 

maintenance workers, consumers, and flight attendants, there continue to be gaps in oversight of 

contracted maintenance. Mr. McGee added that two of the biggest changes in the air carrier industry 

have been the outsourcing of flying to regional air carriers and outsourcing of maintenance to contract 

providers. He noted the shift is still evolving and that large changes in regional flying and contracted 

maintenance had occurred in the last decade, and from a predictive safety standpoint it would seem that 

risk would be present with such a large change in how the air carrier industry conducts business.
Future of Aviation Advisory Committee

Aviation Safety Subcommittee

Record of Meeting

November 17, 2010

General Aviation Manufacturers Association

Washington, DC

10

Mr. McGee continued by stating that while forensic safety studies may not show these changes to be a 

safety risk, noting that he could not specifically cite hard data on the topic, common sense would show 

that shifting from the traditional model of an FAA office near an air carrier maintenance facility in the 

United States to a newer model of work performed by contract maintenance providers outside of the 

United States would be more difficult to oversee. Mr. Hubbard stated that a study of air carrier 

accidents from 1976-2004 showed that human factors were decreasing as a cause of accidents, while 

organizational factors increased. He noted market factors, including outsourcing of air carrier work 

functions, could potentially be to blame and called for more study on the topic.

Ms. Piasecki asked Mr. Predmore to provide input from an air carrier perspective on contract 

maintenance. Mr. Predmore stated that there was not broad consensus on this topic among the 

subcommittee members, while noting the members had raised good questions and more discussion of 

the topic could be helpful. Mr. Lekites noted there was a general absence of data to support the issue, 

though suggestions that it is a problem could warrant further exploration. He discussed air carrier 

oversight of maintenance providers and noted air carriers’ records are readily available for inspection 

by the FAA.

Mr. Lekites added that he has not heard concerns from FAA inspectors on the inability to oversee 

maintenance providers and noted that FAA inspectors have visited most of UPS’ maintenance providers 

worldwide and the inspectors were impressed with UPS’ oversight of the maintenance providers. 

Mr. Lekites also noted that his air carrier’s growth has been strongest internationally and represents a 

global shift in the aviation industry, and added the international growth has created jobs in the 

United States.

Mr. Conley asked Mr. Hubbard and Mr. Hagy to work with Mr. Douglas to further refine the topic of 

contract maintenance. He then asked the subcommittee members to take a vote on whether the third 

issue area in Mr. Hubbard’s paper regarding maintenance providers in foreign countries was a concern 

to them. Ms. Piasecki and Ms. Kurland informed Mr. Conley this was not an appropriate action, and a 

vote did not take place. Ms. Kurland then described the consensus process for subcommittee 

recommendations.

Ms. Piasecki asked Ms. Salli Rowe, FAA, for further input on contract maintenance. Ms. Rowe

explained that while the OIG report is publicly available, the FAA’s responses to the recommendations 

are not, and this may create the impression that the FAA is not taking action. She stated data validation 

work on maintenance providers was underway as well as an inventory of non-certificated maintenance 

providers. She noted there was a shift in the contract maintenance industry even since the release of 

the OIG report and that dynamics have changed even for non-certificated maintenance providers. 

Ms. Rowe added that the OIG is expected to do another audit on oversight of maintenance providers, 

likely in 2011.
Future of Aviation Advisory Committee

Aviation Safety Subcommittee

Record of Meeting

November 17, 2010

General Aviation Manufacturers Association

Washington, DC

11

Mr. Fazio expressed his agreement that aviation is a dynamic industry, and there are many areas that 

the FAA must oversee. He noted the OIG oversees the FAA’s oversight activities, as well. Mr. Douglas 

and Ms. Rowe added that the FAA conducts surveillance on non-certificated maintenance facilities 

to better understand their roles and noted this segment of the aviation maintenance industry is 

still evolving.

Mr. McGee reminded the subcommittee that in previous meetings, discussion had taken place on the 

introduction of risk with changes in systems. He reiterated his belief that the fundamental shift from a 

traditional air carrier maintenance scenario of work being done by the carriers and overseen by a local 

FAA office to work being performed by contractors, often in foreign countries, would certainly 

introduce risk into the aviation industry. Mr. McGee expressed his desire to ensure the recording of 

this topic as part of the Aviation Safety Subcommittee’s discussions in the FAAC’s final report.

Mr. Fazio stated the OIG works directly for the Secretary of Transportation, and this issue is visible to 

him. Ms. Piasecki shared what she had captured as the subcommittee’s thoughts on the topic of 

contract maintenance from the subcommittee, including: acknowledgement that aircraft maintenance is 

increasingly being performed by contractors and air carriers must retain oversight of and accountability 

for the work; that it is important the FAA remain responsive to the OIG report; the FAA is to be 

commended for continuing to respond to changes in the aviation industry; and there is a perceived 

safety risk with contract maintenance providers, but a lack of data to show that there is indeed a risk.

Ms. Piasecki expressed her belief the subcommittee could agree there are changes evolving in the 

aviation industry, and that SMS is a critical component of aviation safety. She stated her proposal 

would be for the subcommittee to focus on areas of common ground and document the discussion on 

the topic of contract maintenance and include it in the background of the Aviation Safety 

Subcommittee’s submission for the FAAC final report. However, Ms. Piasecki noted there did not 

appear to be consensus among the subcommittee members that contract maintenance was a risk to 

aviation safety. Ms. Baer reaffirmed Ms. Piasecki’s statement. Ms. Piasecki asked subcommittee 

members with input on this topic to provide their suggestions to Mr. Traynham.

CLOSING REMARKS

Ms. Piasecki thanked the subcommittee for its work, and recognized the Boeing team and 

Mr. Traynham in particular, for their assistance with transitioning the subcommittee’s thoughts into 

recommendations for the FAAC. She asked Ms. Kurland for her input on the final FAAC meeting on 

December 15, 2010. Ms. Kurland first thanked Ms. Piasecki for her leadership in chairing the 

Aviation Safety Subcommittee, and the meaningful discussions of the subcommittee. She stated the 

subcommittee’s recommendations were due to the DOT on November 22, 2010, so that they may be 

packaged in time for review by the final FAAC meeting. Ms. Kurland noted at the FAAC meeting, the 

subcommittee chairs would first report out in the morning then work on consensus on overall 

recommendations from the FAAC to the Secretary of Transportation. Ms. Kurland added that the 

committee would work to resolve cross cutting issue areas, and officially present its recommendations 

to the Secretary in the afternoon.
Future of Aviation Advisory Committee

Aviation Safety Subcommittee

Record of Meeting

November 17, 2010

General Aviation Manufacturers Association

Washington, DC

12

Mr. Traynham reminded the subcommittee members that those providing suggested and revised 

language for the recommendations document needed to have their submissions to him by close of 

business on Thursday, November 18, 2010. He stated a revised document would be circulated to the 

subcommittee for review the morning of November 22, 2010 and then the document would be 

submitted to the DOT by close of business that day.

ADJOURNMENT

Ms. Piasecki adjourned the meeting at 11:20 a.m.

I hereby certify that, to the best of my knowledge, the foregoing minutes are accurate and complete.

Approved by: ____________________________________________

Tony Fazio, Designated Federal Official

Dated: ___December 14, 2010________________________________