# Did Federal Self-Certification Laws Enable Systemic Safety Blind Spots?: 39 Sourced Claims, Contested Facts & Evidence The crisis was created by statutory reforms that forced the FAA to delegate critical flight-safety approvals directly to Boeing staff. Authors: djwide HTML: https://moyomap.com/maps/did-federal-self-certification Markdown: https://moyomap.com/maps/did-federal-self-certification.md License: HTML and markdown are for reading and citation. Bulk copying and AI training need a written license. See /terms and /developers#maps-data. Cite a claim as: MoyoMap, "Did Federal Self-Certification Laws Enable Systemic Safety Blind Spots?: 39 Sourced Claims, Contested Facts & Evidence", claim {id}, https://moyomap.com/maps/did-federal-self-certification.md#{id}. “Moyo, a product of SenTeGuard Inc.” ### Boeing received its Organization Designation Authorization in 2009, creating an ODA unit of roughly 1,000–1,5… Id: claim_507c1f5dfc933e309bc595f8 Parent: topic_TNsnxWHLrkwjnfmXyiBb Depth: 1 Boeing received its Organization Designation Authorization in 2009, creating an ODA unit of roughly 1,000–1,500 Boeing employees approving design data on the FAA's behalf while reporting through Boeing management. Labels: Source-linked, Medium, known ### Internal Boeing messages revealed the company discussed framing MCAS to regulators as an extension of the exi… Id: claim_76c3eea2856abfdb29b99e48 Parent: topic_TNsnxWHLrkwjnfmXyiBb Depth: 1 Internal Boeing messages revealed the company discussed framing MCAS to regulators as an extension of the existing speed-trim system rather than as a distinct new function. Labels: Source-linked, High, known ### Boeing's ODA structure allowed an engineer who participated in designing a feature to approve that same desig… Id: claim_f7058cd4951cc15d36be4ffe Parent: topic_TNsnxWHLrkwjnfmXyiBb Depth: 1 Boeing's ODA structure allowed an engineer who participated in designing a feature to approve that same design while acting as an FAA ODA unit member. Labels: Source-linked, Medium, known ### Concealment of Simulator Data and Pilot Reaction Times Id: section_067eb2d545cb01eb155626a0 Parent: topic_TNsnxWHLrkwjnfmXyiBb Depth: 1 Concealment of Simulator Data and Pilot Reaction Times Labels: Inferred, Low ### Internal Concerns Over MCAS Design and Single-Sensor Vulnerability Id: section_2f8c56464e6a052013dccdf5 Parent: topic_TNsnxWHLrkwjnfmXyiBb Depth: 1 Internal Concerns Over MCAS Design and Single-Sensor Vulnerability Labels: Inferred, Low ### Reports of Undue Management Pressure on ODA Members Id: section_3e7b7a04ef882072cecbcecc Parent: topic_TNsnxWHLrkwjnfmXyiBb Depth: 1 Reports of Undue Management Pressure on ODA Members Labels: Inferred, Low ### Establishment and Expansion of the ODA Program Id: section_493b7b8c9db6a53badafcc04 Parent: topic_TNsnxWHLrkwjnfmXyiBb Depth: 1 Establishment and Expansion of the ODA Program Labels: Inferred, Low ### Delegation of 737 MAX Certification Plans Id: section_a8c173369a418db68048ff2a Parent: topic_TNsnxWHLrkwjnfmXyiBb Depth: 1 Delegation of 737 MAX Certification Plans Labels: Inferred, Low ### Regulatory and Legislative Reforms to ODA Authority Id: section_af5faabe68a62521e2a75ddd Parent: topic_TNsnxWHLrkwjnfmXyiBb Depth: 1 Regulatory and Legislative Reforms to ODA Authority Labels: Inferred, Low ### Investigations into FAA Awareness and MCAS Oversight Failures Id: section_c76917aa68a476fd7d5c0a6a Parent: topic_TNsnxWHLrkwjnfmXyiBb Depth: 1 Investigations into FAA Awareness and MCAS Oversight Failures Labels: Inferred, Low ### FAA Staffing and Oversight Limitations Id: section_e2ca2cb09bcd618620429211 Parent: topic_TNsnxWHLrkwjnfmXyiBb Depth: 1 FAA Staffing and Oversight Limitations Labels: Inferred, Low ### DOJ Criminal Proceedings and Prosecution of Mark Forkner Id: section_ef745f9200398ce2cc908a11 Parent: topic_TNsnxWHLrkwjnfmXyiBb Depth: 1 DOJ Criminal Proceedings and Prosecution of Mark Forkner Labels: Inferred, Low #### In 2015, a Boeing authorized representative specifically questioned whether MCAS was vulnerable to the failur… Id: claim_16e1bba6fcba670557cd8b09 Parent: section_2f8c56464e6a052013dccdf5 Depth: 2 In 2015, a Boeing authorized representative specifically questioned whether MCAS was vulnerable to the failure of a single angle-of-attack sensor prior to aircraft certification. Labels: Source-linked, High, known #### The Aircraft Certification, Safety, and Accountability Act (ACSAA), enacted December 27, 2020, required the F… Id: claim_3677a28860037131d168f94f Parent: section_af5faabe68a62521e2a75ddd Depth: 2 The Aircraft Certification, Safety, and Accountability Act (ACSAA), enacted December 27, 2020, required the FAA to approve ODA unit members directly and mandated protections against management interference. Labels: Source-linked, Low, known #### The FAA Modernization and Reform Act of 2012 prompted an implementation plan that prioritized the 'Enhanced U… Id: claim_58843f6887ffc1b3de6c4ee2 Parent: section_493b7b8c9db6a53badafcc04 Depth: 2 The FAA Modernization and Reform Act of 2012 prompted an implementation plan that prioritized the 'Enhanced Use of Delegation' to improve certification efficiency. Labels: Source-linked, Low, known #### The FAA initially delegated 28 of 87 detailed certification plans for the 737 MAX, but ultimately delegated a… Id: claim_5fb649d9548ce8b7a94a5a7e Parent: section_a8c173369a418db68048ff2a Depth: 2 The FAA initially delegated 28 of 87 detailed certification plans for the 737 MAX, but ultimately delegated all 91 plans to Boeing by March 2017. Labels: Source-linked, Medium, known #### The October 2019 Joint Authorities Technical Review (JATR) found that the FAA lacked adequate awareness of MC… Id: claim_6af9e58539b4611d8cab4926 Parent: section_c76917aa68a476fd7d5c0a6a Depth: 2 The October 2019 Joint Authorities Technical Review (JATR) found that the FAA lacked adequate awareness of MCAS functionality and that the ODA structure gave FAA engineers insufficient visibility into Boeing's delegated analyses. Labels: Source-linked, Medium, known #### On January 7, 2021, the DOJ announced a Deferred Prosecution Agreement charging Boeing with conspiracy to def… Id: claim_7b9c32998bcbc3db4cd7b06c Parent: section_ef745f9200398ce2cc908a11 Depth: 2 On January 7, 2021, the DOJ announced a Deferred Prosecution Agreement charging Boeing with conspiracy to defraud the FAA's Aircraft Evaluation Group regarding MCAS, with Boeing agreeing to pay over $2.5 billion. Labels: Source-linked, Medium, known #### A Boeing survey begun in December 2019 revealed that 40% of responding ODA unit members perceived undue press… Id: claim_7d2dd709d6fde639327d325a Parent: section_3e7b7a04ef882072cecbcecc Depth: 2 A Boeing survey begun in December 2019 revealed that 40% of responding ODA unit members perceived undue pressure within the preceding 24 months, largely driven by schedule and cost concerns. Labels: Source-linked, High, known #### Boeing simulations showed that a pilot response time longer than ten seconds to uncommanded MCAS was catastro… Id: claim_7e94388d142622a031b6e11e Parent: section_067eb2d545cb01eb155626a0 Depth: 2 Boeing simulations showed that a pilot response time longer than ten seconds to uncommanded MCAS was catastrophic, but this finding was not provided to the FAA. Labels: Source-linked, High, known #### The statutory basis for the FAA's self-certification ODA program was created by the Vision 100—Century of Avi… Id: claim_93af05b9b50bcc98ce4ae6d0 Parent: section_493b7b8c9db6a53badafcc04 Depth: 2 The statutory basis for the FAA's self-certification ODA program was created by the Vision 100—Century of Aviation Reauthorization Act of 2003 (Public Law 108-176), allowing delegation to entire company-run units rather than only individuals. Labels: Source-linked, Low, known #### A 2012 internal FAA survey revealed that a substantial portion of Boeing authorized representatives perceived… Id: claim_9cd3185faa8356d19f9ae823 Parent: section_3e7b7a04ef882072cecbcecc Depth: 2 A 2012 internal FAA survey revealed that a substantial portion of Boeing authorized representatives perceived undue pressure from company management when executing delegated safety tasks. Labels: Source-linked, Medium, known #### The FAA Reauthorization Act of 2018 (P.L. Id: claim_afb37699809efc3eac8e0b66 Parent: section_493b7b8c9db6a53badafcc04 Depth: 2 The FAA Reauthorization Act of 2018 (P.L. 115-254), enacted three weeks before the Lion Air crash, contained provisions pushing the FAA to increase delegations and restricted oversight of ODA holders. Labels: Source-linked, Medium, known #### GAO reports published between 2005 and 2015 repeatedly warned that the FAA lacked the staff, data, and risk-b… Id: claim_b6c3cab44bb348100be3eaab Parent: section_e2ca2cb09bcd618620429211 Depth: 2 GAO reports published between 2005 and 2015 repeatedly warned that the FAA lacked the staff, data, and risk-based oversight needed to monitor its expanding delegation and designee workload. Labels: Source-linked, Low, known #### Staffing shortages in the FAA's Boeing Aviation Safety Oversight Office hindered retained certification tasks… Id: claim_b9a8f5349d2f269b9e0920a9 Parent: section_e2ca2cb09bcd618620429211 Depth: 2 Staffing shortages in the FAA's Boeing Aviation Safety Oversight Office hindered retained certification tasks and ODA oversight, with some engineers lacking experience in key MAX technologies. Labels: Source-linked, Medium, known #### In November 2019, FAA Administrator Steve Dickson stripped Boeing's longstanding delegated authority by annou… Id: claim_ba38589d8f5133090e0be4cc Parent: section_af5faabe68a62521e2a75ddd Depth: 2 In November 2019, FAA Administrator Steve Dickson stripped Boeing's longstanding delegated authority by announcing the agency would individually issue airworthiness certificates for every newly built 737 MAX. Labels: Source-linked, Medium, known #### The House Transportation Committee's September 2020 final report concluded the MAX crashes resulted from faul… Id: claim_c1f788c849d53c7a8b3293a6 Parent: section_c76917aa68a476fd7d5c0a6a Depth: 2 The House Transportation Committee's September 2020 final report concluded the MAX crashes resulted from faulty technical assumptions, lack of transparency, and grossly insufficient oversight by the FAA, leaving FAA engineers without basic knowledge of MCAS. Labels: Source-linked, Medium, known #### A December 2020 Senate Commerce Committee report found FAA senior leadership may have obstructed a DOT OIG re… Id: claim_c24a0c40fa5d448f9a4a767e Parent: section_c76917aa68a476fd7d5c0a6a Depth: 2 A December 2020 Senate Commerce Committee report found FAA senior leadership may have obstructed a DOT OIG review of pilot reaction times and engaged in a coordinated effort with Boeing to manipulate MAX recertification. Labels: Source-linked, High, known #### DOT OIG found that the FAA and Boeing technically adhered to established certification processes, concluding… Id: claim_cbbdc3c6f5ff09dae767d723 Parent: section_c76917aa68a476fd7d5c0a6a Depth: 2 DOT OIG found that the FAA and Boeing technically adhered to established certification processes, concluding that the blind spots regarding MCAS stemmed from systemic process weaknesses. Labels: Source-linked, Medium, known #### In June 2016, a Boeing authorized representative raised concerns about repetitive MCAS operation after a test… Id: claim_eb655a4308c1dad063e46df0 Parent: section_2f8c56464e6a052013dccdf5 Depth: 2 In June 2016, a Boeing authorized representative raised concerns about repetitive MCAS operation after a test pilot had difficulty trimming against the system. Labels: Inferred, High, known ##### The FAA delegated approval of the final corrected Enhanced Digital Flight Control System System Safety Analys… Id: claim_0cee5746297266a70ff4db6c Parent: claim_5fb649d9548ce8b7a94a5a7e Depth: 3 The FAA delegated approval of the final corrected Enhanced Digital Flight Control System System Safety Analysis to Boeing in January 2017, only two months prior to 737 MAX certification. Labels: Source-linked, High, known ##### The FAA renewed Boeing's ODA in 2015 during early 737 MAX development, despite the FAA's own oversight office… Id: claim_0d5b0c5bee870d351eedff9c Parent: claim_9cd3185faa8356d19f9ae823 Depth: 3 The FAA renewed Boeing's ODA in 2015 during early 737 MAX development, despite the FAA's own oversight office having documented findings of undue management pressure. Labels: Source-linked, High, known ##### Whistleblower disclosures to the Senate Commerce Committee documented that a 2016 FAA evaluation found pilots… Id: claim_150dacf565cdd63de534ebdb Parent: claim_c24a0c40fa5d448f9a4a767e Depth: 3 Whistleblower disclosures to the Senate Commerce Committee documented that a 2016 FAA evaluation found pilots took up to roughly 16 seconds to respond to MCAS activation, well exceeding the 4-second baseline assumption. Labels: Source-linked, High, known ##### Mark Forkner was indicted in October 2021 as the only individual criminally charged over the MAX certificatio… Id: claim_35c6f3d4684bce05e1e0a595 Parent: claim_7b9c32998bcbc3db4cd7b06c Depth: 3 Mark Forkner was indicted in October 2021 as the only individual criminally charged over the MAX certification and was acquitted by a federal jury in March 2022. Labels: Source-linked, Medium, known ##### Boeing technical pilot Mark Forkner messaged a colleague in November 2016 that MCAS was 'running rampant in t… Id: claim_4093fde80d29f07f3fdc5453 Parent: claim_7b9c32998bcbc3db4cd7b06c Depth: 3 Boeing technical pilot Mark Forkner messaged a colleague in November 2016 that MCAS was 'running rampant in the sim,' an exchange withheld from the FAA's Aircraft Evaluation Group. Labels: Source-linked, High, known ##### The FAA's Boeing Aviation Safety Oversight Office (BASOO) had only roughly 40–45 engineers assigned to overse… Id: claim_44908010b21be7f87bdbf0ac Parent: claim_b9a8f5349d2f269b9e0920a9 Depth: 3 The FAA's Boeing Aviation Safety Oversight Office (BASOO) had only roughly 40–45 engineers assigned to oversee Boeing's internal ODA unit of over 1,000 employees. Labels: Source-linked, Medium, known ##### The FAA delegated the system safety assessment of the flight control system including MCAS to Boeing's ODA un… Id: claim_8666140fb5599f3283ac5a2f Parent: claim_5fb649d9548ce8b7a94a5a7e Depth: 3 The FAA delegated the system safety assessment of the flight control system including MCAS to Boeing's ODA unit, allowing Boeing employees to approve the safety classification permitting MCAS to rely on a single AOA sensor. Labels: Source-linked, Medium, known ##### Certain FAA certification engineers and pilot-training approval personnel lacked adequate knowledge of MCAS a… Id: claim_bdecb7dcffd7d85b465f4be4 Parent: claim_6af9e58539b4611d8cab4926 Depth: 3 Certain FAA certification engineers and pilot-training approval personnel lacked adequate knowledge of MCAS activation triggers, system interactions, and repeated operation risks. Labels: Source-linked, Medium, known ###### Boeing's original 2013 functional hazard assessment classified MCAS failure as 'major' and specified a 0.6-de… Id: claim_01f024cfd71553916203a894 Parent: claim_8666140fb5599f3283ac5a2f Depth: 4 Boeing's original 2013 functional hazard assessment classified MCAS failure as 'major' and specified a 0.6-degree stabilizer authority limit, which was later expanded to 2.5 degrees and repetitive activation without briefing FAA engineers. Labels: Source-linked, Medium, known