The FAA, Quality Culture, and the Danger of “The Customer Will Never Notice”

Charles Nadeau
Dec 6, 2025
3 min read

When someone says “the customer will never notice,” they’re not just violating internal expectations. They’re potentially violating federal law, because in aerospace:

The FAA is the customer.

And the FAA always notices.

1️⃣ FAA Requirements Make This Mindset Legally Dangerous

Under FAA regulations (14 CFR Part 21, Part 43, Part 145, etc.), manufacturers and repair stations must:

Ensure airworthiness
Maintain configuration control
Ensure conformity to approved design data
Ensure traceability, material pedigree, and process compliance
Ensure objective evidence of inspection
Report significant defects, escapes, and safety issues

When someone knowingly ships a nonconforming product because “no one will notice,” they are potentially violating:

🔹 14 CFR Part 21.3 - Reporting of Failures, Malfunctions, and Defects

If you know something is outside design intent, you cannot just ignore it. You may be required to report it.

🔹 14 CFR §21.137 - Quality System Requirements

Manufacturers must have a system ensuring product conforms to type design and is safe.
Shortcut thinking directly undermines this.

🔹 14 CFR §43.13(a) - Performance Rules

Maintenance and manufacturing work must follow methods, techniques, and practices in approved data.
Skipping steps or altering configuration without documentation violates this rule.

🔹 14 CFR Part 145 — Repair Stations

Repair stations must perform work to the level of airworthiness, not convenience.
Any “good enough” mentality violates not just company standards, but regulatory obligations.

2️⃣ Why the FAA Always Notices - Even If the Customer Doesn’t Today

When shortcuts become normalized, the FAA detects it through:

audit findings
process surveillance
sampling of released hardware
conformity inspections
production certificate reviews
designee oversight (DAR, DMIR, DER)
systemic trend analysis
suspected unapproved parts (SUP) investigations
recurring quality escapes

Some organizations convince themselves the FAA “won’t see” a deviation.

But the FAA sees it in:

incomplete objective evidence
deviations not documented
rework not logged
process flow gaps
missing lot traceability
undocumented concessions
serial/lot-level patterns

They ALWAYS see the cultural pattern long before they see the individual defect.

3️⃣ How Organizational Hierarchy Amplifies the Problem

Here’s the hardest truth:

When Quality reports to Operations, this mindset becomes culturally inevitable.

Not because people are bad, but because the hierarchy creates built-in pressure:

Operations metrics:

Ship
Deliver
Hit schedule
Reduce labor hours
Reduce scrap/rework

Quality metrics:

Conformity
Compliance
Airworthiness
Configuration control
Safety
Risk reduction

When Quality is subordinate to Ops:

🔸 Quality becomes a “production support function”

🔸 Quality inspectors learn not to slow down the line

🔸 Engineers learn to “just approve it”

🔸 Supervisors pressure for “practical” decisions

🔸 Concessions become the path of least resistance

🔸 Quality loses independence

And the cultural math becomes:

**Production pressure > Compliance

Schedule > Standard

Speed > Integrity**

The FAA has repeatedly warned against this structure because:

Quality cannot be fully independent if the people whose output it must police control its budget, promotions, or job security.

4️⃣ The FAA Looks at Quality Independence as Part of Safety Culture

While not expressed in a single line item, FAA audits consistently evaluate:

independence of the quality system
conflict of interest between Ops and Quality
how nonconformities are dispositioned
whether inspectors feel pressure to conform to schedule
whether the organization has a speak-up culture
whether escapes are buried or surfaced

When Quality reports to Operations, FAA auditors see:

rushed buy-offs
undocumented rework
incomplete calibration adherence
out-of-tolerance conditions justified as “acceptable”
NCRs overridden
concessions approved without engineering rigor
systemic underreporting

These are red flags that trigger deeper FAA surveillance.

5️⃣ Cultural Impact: When Employees See Leaders Override Quality

When employees watch Ops leadership overrule Quality, the cultural consequences are profound:

A. They learn compliance is optional

Rules become suggestions.

B. They assume audits are something to “get through,” not learn from

People hide issues instead of correcting them.

C. Inspectors stop raising concerns

Silence becomes a survival strategy.

D. Engineers learn to rubber-stamp deviations

Design intent erodes.

E. The FAA becomes a feared adversary instead of a safety partner

This creates a defensive, secretive atmosphere.

F. The organization slowly accumulates technical debt

This debt eventually shows up in:

high scrap
high MRB volume
high COPQ
recurring defects
customer dissatisfaction
FAA findings
loss of PC (Production Certificate) privileges in worst cases

6️⃣ What the Best Aerospace Companies Do Instead

The highest-performing organizations; Airbus, Boeing (post-MAX reforms), Collins, GE Aviation, move toward one consistent structure:

➡️ Quality reports to a VP of Quality or Chief of Compliance, NOT Operations.

Benefits:

independence
courage to stop the line
unbiased oversight
better FAA trust
stronger safety culture
reduced escapes
faster systemic corrections

And culturally:

**Employees trust leaders who uphold standards over schedule.

Not the other way around.**

7️⃣ Closing Message

“When someone says ‘the customer will never notice,’ they are forgetting that the FAA is always watching, and your employees are too.”

It becomes not just a quality conversation, but a safety and leadership conversation.