Letters to the Editor

Subject: "Bias" QUESTIONED
From: T. D. Ponder tdponder@worldnet.att.net (Airline Transport Pilot)

This new site's statement of "Bias" unfortunately begs a simple view of a complex operational entity -- The safety of flying. A modicum of elaboration, ergo, is required.

Given: Most pilots flying airliners will agree with a general statement that the less government regulation is involved, the better a given piloting situation will be. That is because they have dealt with government at an individual level and witnessed what often is a recalcitrant, bureaucratic approach that seems, and usually is, ludicrous.

Given: Most airlines and aircraft manufactures also will agree with the same general statement because the government costs them plenty of money --- i.e., profit.

Given: The general flying public could not care less. About a third of passengers are scared out of their minds just boarding and the other two thirds just want to get it over and "be there" (destination) without thinking about the mechanics of it happening safely.

The implication of the "Bias" statement is that zero government involvement would be the desirable goal. This just can not be. The reason that there is government involvement is that, historically, the fox does not make a reliable guard for the Hen House.

Does anyone believe that Boeing would spend $128 million, to redesign and retrofit rudder parts of older 737 aircraft, if the FAA had not issued an AD (Airworthiness Directive) requiring it? Would airlines carry the added weight and expense of flotation devices if they were not required to do so?

The other side of the coin is a hypothetical question: Since the FAA is charged with protecting the safety of the flying public, should it therefore require all passengers to wear parachutes and crash gear? Obviously, there must be compromise, since no flight can ever be guaranteed 100 percent safe. Risk is involved, no matter how statistically small.

What is really desirable is an effort to reduce the need for such a bias. If the FAA, NTSB, airlines and aircraft manufactures could work together to improve safety, without an adversarial attitude, there would be no need for bias. Do not look for that to happen. There are too many interests involved, each with their own political or financial ox to gore. Just hope for an acceptable level of compromise. Sadly, it seems while safety can achieve gains, it never will be the top winner.

T. D. Ponder

EDITOR’S REPLY:

Bias is not something we "need," but rather something we all have as a by-product of the learning/thinking process.

The bias statement, on the home page of AirlineSafety.Com, serves the purpose of fair dealing and honesty. The reader, having been notified of the Editor’s bias, can better judge both the advocacy and conclusions of the writer. Do they flow from reasoned dispassionate analysis of the facts, or does that bias cause the writer to twist, distort or ignore the facts?

While Mr. Ponder may infer from the bias statement that I advocate zero government, I did not imply that. Like James Madison, I recognize that, because men are not angels, limited government is a necessary evil. I also recognize that where monopoly is imposed, by force of law, innovation, individual initiative and personal responsibility are greatly diminished and sometimes destroyed. That is why the FAA is still using 25-year-old tube computers while most of us have more computing power on our own desks than the Apollo moon missions.

It is also why it has taken over 20 years for the B-737 rudder problem to be corrected: Because the FAA is the fox guarding the hen house. It was the FAA that approved the unprecedented 737 rudder design (without the redundancy of dual control units and/or limiters, such as those incorporated in 727 and DC-9 designs). The FAA certified that dangerous 737 rudder design, not on the basis of adequate backup modes, but because Boeing persuaded the FAA that the odds of failure of that design were so small as to be "statistically insignificant." I refer to that as the "It can’t happen syndrome" (CHS).

CHS was causal in the following accidents:

UAL 727, on Jan 18, 1969 (all flight instruments wired to the main electric power buses, with no pneumatic or battery backup).

Turkish Airlines, DC-10, on March 3, 1974; JAL 747, on August 12, 1985; UAL DC-10, on July 19, 1989 (all flight controls hydraulically powered, with no electric or cable backup).

American DC-10, on June 12, 1972; Turkish DC-10, on March 3, 1974; UAL 747 on February, 24, 1989; Evergreen DC-9, on March 18, 1989 (outward opening, non-plug doors, with "fail-safe" designs that were supposed to prevent opening in flight).

The FAA certified all such CHS designs. Yet, despite the accidents noted above, the FAA continues to rely on CHS as a design criterion for new aircraft!

Once the FAA has certified a deficient design, that becomes causal in accidents, it refuses to acknowledge the error. Instead, it acts like the prosecutor who put a rapist in prison and then fights tooth-and-nail to keep him there, even though the sole witness admits she lied at the trial.

The FAA does not deserve credit for the recent AD on the 737 rudders. It was brought kicking and screaming to that decision by the Free Market publicity that followed the terrible accidents. The same thing happened in the DC-10 cargo door design case. Despite the overwhelming evidence that it was a bad design, which should never have been approved by the FAA, no AD was issued until 346 fatalities generated the necessary publicity.

While hoping for "…an acceptable level of compromise," may be a way of getting a budget thru Congress, it is a very poor and detrimental way to try and improve airline safety. It is the granting of monopoly power that creates the "need" for political action to solve problems that flow from the misuse of that power.

The Free Market is the antithesis of political action. It fosters rapid innovation and creativity that not only solves past problems, but also creates new and better designs for the future.

CLR/CRM, one of the best safety innovations in aviation, was designed and created by United Airlines and then adopted by others. The FAA was a Johnny-come-lately and only later decided to make it mandatory training for all U.S. pilots. The enhanced warning ground proximity warning system (EGPWS), another terrific safety tool, is already being installed by some airlines. Federal Bureaucracy delayed its development because the U.S. Military didn’t want to release its worldwide terrain database, that is essential to that new technology. It was Free Market forces that finally broke loose that bureaucratic logjam, when the information could be freely purchased from databases created by Soviet satellites.

I do not claim we will achieve utopia with Free Market solutions; no aspect of human affairs can ever rise that high. But, I do hold that the Free Market responds much more rapidly, with more and better solutions than bureaucratic monopolies. I find it hard to imagine how the Free Market could have done worse than the FAA in the above mentioned cases.

February, 1998

Robert J. Boser    
Editor-in-Chief 
AirlineSafety.Com

Return to the Letters to the Editor page.