Rules vs. Cases: FAA Undue Burdens
Often, we think about rules and regulations as concrete: even if the language is fuzzy (and needs interpretation), in theory there is a single "right" interpretation of the rule, and we can know if we're following the rule. One regulation where this is not the case is the Federal Aviation Administration's (FAA) rule that moving work between factories can cause "no undue burden" to the FAA to monitor the work. I encountered this issue when cleaning up a regulatory violation at my former company: the violation was inadvertent, we disclosed it to the FAA, and we needed to 1) catch up on undue-burden assessment requests, and 2) put better processes in-place to avoid the issue coming up again. Like other "special" projects , I was pulled in to help on this one because I could quickly absorb the data and turn it into actions and close the issues. This post will have a brief discussion on how I solved the issues, and a longer musing on the difficul...