Review of Technical Center Policies Issued

REPORT OF

REVIEW OF TECHNICAL CENTER POLICIES ISSUED

AS DIRECTIVES

ACT-2003-02

Prepared by:

Office of Enterprise Performance

July 31, 2003

Distribution: ACT-1/2/3, ACB-1, ACF-1, ACH-1, ACK-1, ACX-1

REPORT OF

REVIEW OF TECHNICAL CENTER POLICIES ISSUED

AS DIRECTIVES

TABLE OF CONTENTS

Page

Background ...... 1

Purpose...... 2

Scope and Methodology...... 2

Observations...... 3

Findings and Recommendations...... 3

Conclusion...... 5

Appendix...... 6

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REPORT OF

REVIEW OF TECHNICAL CENTER POLICES ISSUED

AS DIRECTIVES

Background

The Federal Aviation Administration (FAA) established and uses a Directives System, defined in FAA Order 1320.1E, to provide a single, uniform, agency-wide process to deliver policy, instructions, and guidance to staff within the FAA. The Directives System includes procedures or instructions that describe, establish, or explain agency policies, required actions, organization, or methods. The System also allows a particular office or facility (for example, a service, region, or center) to establish and implement policies applicable to the respective office or facility.

The system provides for six basic types of directives:

1. Orders are permanent and remain in effect until canceled.
2. Notices are short-term and are effective for no more than one year; they automatically cancel one year from their effective date.
3. Revisions modify an entire directive.
4. Changes add new information or modify existing information but not the entire directive.
5. Supplements are additional information or instructions added to a directive to fit the special needs of the office issuing the supplement.
6. Other policy documents, such as Personnel Reform Instructions and Bulletin System (PRIBS) are in the directives database but are not called directives.

Periodic reviews and validation are defined processes in the Directives System to ensure the continuing need for and accuracy of the published policies, instructions, and guidance. The Order identifies the Office of Cost and Performance Management at headquarters as the responsible organization to notify program offices of the need to review their directives for currency. The Head of the organization preparing a directive is responsible for ensuring all directives within their areas of responsibility remain current by appointing a Directives Management Officer (DMO). The DMO responsibilities include, “…continuously reviews directives and notifies the originating office of directives that may be out-of-date and ensures that all directives in the system remain current.” The DMO requests validation reviews and subsequent actions by the directives issuer. Directives checklist reviews and updates, along with other internal review activities, provide evidence of the directives issuer effort in this regard.

Purpose

This review was performed to implement the validation process defined for the Directives System by examining the existing policies established in Technical Center directives (orders and supplements) to ensure they are still applicable to Center operating procedures and responsibilities, reflect the current requirements, and accurately state the Center organization to which responsibility is assigned.

Scope and Methodology

A total of 77 orders and supplements issued by the Technical Center (ACT directorate) were reviewed. Of those, 73 were listed in the most recent available directives checklist, CT 0000.4F, dated September 02, 1998. Organizations were also asked to identify and report any orders or supplements they knew were issued after the checklist date. This effort identified four (4) additional orders.

The review was accomplished via an action item that requested the appropriate, current ACT organization, initially identified by assigned mission and function or historically traced to be the office of primary responsibility on record for a particular Technical Center directive, ensure that the directives be reviewed and a determination made regarding the policy. Copies of the orders and supplements, if available, were provided to the reviewing organization. In performing the review, organizations were to first determine if the policy is accurate as written. Next, they were requested to determine if the policy is still needed or should be eliminated. Finally, if the policy is still needed but not accurate as written, the organization was asked to ensure the policy is updated to accurately and concisely state the requirements and application for current operations.

Initial responses to the action item were summarized and analyzed. The ACF Program Analyst leading the review conducted follow-up with those organizations that did not respond by the assigned due date and to obtain additional clarifying information on the responses submitted. The follow-up was performed via email, telephone conversations, and personal contacts.

The ACF Program Analyst leading the effort established a “default response” to “eliminate” a directive if a copy of the document could not be located.

Observations

The knowledge level regarding the purpose, process, and need for directives varied among those responding to the action item. Many organizations, created as a result of the March 2002 Technical Center reorganization, were not aware of the existing policies that transitioned by the establishment of the organization and assignment of mission and functions. This review provided a significant awareness.

Five of the directives included in this review had previously (circa 1996-more than 6 years earlier) been identified for elimination in the report prepared by an established ACT “Directives Quality Action Team”. However, the recommended elimination action had not occurred.

Completion of and responses to the action item were dependent on the availability of a copy of the respective directives to review for determination. Copies of several documents could not be obtained because there was no “central point” or repository for directives. In many instances the

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office of primary responsibility that issued or implemented the policy did not have copies of the directive. The “elimination” response was chosen for these documents because without a copy of the document, there is no way of knowing the directive’s content.

In previous years, the Directives Management Officer; transferred from the former Communications Division, ACT-70 to the Office of Human Capital Strategies, ACH-1 in March 2002; and Technical Center Library; transferred from the former Communications Division, ACT-70, to the Office of Knowledge Management, ACK-1 in March 2002; had been two central repositories for directives. Staff and organizational reassignments, combined with space availability, have either limited or eliminated these sources of information.

Findings and Recommendations

Finding 1. Initial responses to the action item identified 31 of the 77 orders and supplements to be eliminated. The follow-up on “no responses” and initial responses identified an additional 17 resulting in 48 orders and supplements to be eliminated, equating to eliminating 62.30%. Two (2.3%) of the 77 directives were accurate as issued. The responses identified 27 (35%) for updating and retention. Appendix 1 lists the individual directives and the response or action related to each.

The most common reasons provided for elimination include:

Superceded by a subsequent version or change

No longer required because of changed policies and operations such as a Memorandum of Understanding (MOU) with the bargaining unit or an automated on-line system in use

Consolidation of policies into one document

Basic order, to which supplement applied, was cancelled or updated

Copies of the document not available

Transfer of program responsibility from ACT organization

Recommendation 1.a. The Directives Management Officer prepares and processes a notice through the Directives System to officially cancel the documents identified for elimination.

ACTION: ACH-1

Recommendation 1.b. The identified office of primary responsibility (OPR) prepares and processes updated policy documents through the Directives System.

ACTION: To be assigned to appropriate organization

Recommendation 1.c. The Directives Management Officer updates the Directives Checklist, CT Order 0000.4F.

ACTION: ACH-1

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Recommendation 1.d. Electronic copies of valid and updated Technical Center directives be archived in the Technical Center’s library database and posted on-line for accessibility via the intra-web.

ACTION: ACH-1

ACK-1

Finding 2. The significant time lapse between issuing, updating, or otherwise validating policies revealed that the Directives System process is not implemented. As an example, directives dating as early as August 1970 were listed as valid, but later confirmed for either elimination or modification as a result of this review.

Recommendation 2.a. The Directives Management Officer and OPR jointly ensure that a complete review of local policies is conducted every 3-years, perhaps at the first quarter or beginning of the fiscal year, to ensure currency of the policies.

ACTION: ACH-1

Recommendation 2.b. The fiscal year audit plan is developed so that all established policies would be audited over a 3-year period to determine the currency and level of compliance with the policy.

ACTION: ACF-1

Finding 3. Recent activities in developing and updating policies have revealed a desire for concise (one page) policy statements. The current Directives System process and guidelines do not prescribe a size or length for a policy; however, any and all policies should be appropriately identified, distributed, and archived in a records system. A practice over the past several years has been to display policy statements (primarily related to process improvement) in strategic locations throughout the building. Because these statements were not archived with identifier information, they were not included in the current inventory of policies, specifically the Directives Checklist.

Recommendation 3.1. All policy statements will be assigned an appropriate subject matter number according to the FAA records classification standards. Consider establishing and using a designator for “one page policy statements” such as the one used for supplements (SUP) to national orders.

ACTION: ACH-1

Recommendation 3.2. Ensure that all policies are appropriately distributed and archived.

ACTION: ACH-1

ACK-1

OPR

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Conclusion

Webster defines policy as: 1) prudence or wisdom in the management of affairs; 2) a definite course or method of action selected from among alternatives and in light of given conditions to guide and determine present and future decisions; and 3) a high-level overall plan embracing the general goals and acceptable procedures, especially of a governmental body. Having policies in place that are outdated, insignificant, or not enforced does not provide guidance for decision-making nor general instruction on goals and acceptable procedures. In fact, one would question if having no policies at all would represent a preferred alternative. Since it is impossible for the Technical Center to operate without having some policies defined, a position must be taken to identify, maintain, and enforce those policies necessary for effective and efficient operations and attainment of established goals.

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APPENDIX