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The Boeing 737 MAX
Who governs a consequential decision once it has been approved, and what brings it back for review when the assumption it rests on changes?
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On 30 August 2011 Boeing launched the 737 MAX as a derivative of the existing 737. Certification as a change to the existing type, and pilot transition by differences training without simulator time, both rested on that founding decision. In March 2016 a redesign increased the authority of the flight-control software MCAS at low speed. Lion Air Flight 610 crashed on 29 October 2018 and Ethiopian Airlines Flight 302 on 10 March 2019. Together the 2 crashes killed 346 people.
What the investigations documented. The Joint Authorities Technical Review found that the changed-product certification process was followed and worked for discrete changes, but did not adequately address cumulative effects or how changes interacted across the whole aircraft. The US House Committee on Transportation and Infrastructure found that the FAA officials who approved removing references to MCAS from the flight crew manual did not learn of the redesign until after the first crash. The investigations set out many findings across design, certification, training, maintenance and oversight. This page does not reduce the findings to a single cause.
The Kettei reading. Separately from those findings, the article reads the reports with the decision as the unit of analysis, rather than the outcome. Rules and review mechanisms existed. What the record does not show is a person accountable for the founding derivative assumption, with a written trigger on it and a declared link to the MCAS design and the training commitment. That is an interpretation, offered as a question for any organisation, and it is not a finding of the inquiries. It does not claim that Kettei would have prevented the accidents. A trigger creates an obligation to review; whether a review is honest and acted on depends on the people in the room.
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Since 8 October 2026, Kettei uses one Watchcard per steering decision and one Watchlist per endeavour; the essay is kept as published.
Read on Substack
The Decision That Could Not Expire: the Boeing 737 MAX
Reads the 737 MAX inquiry reports with the decision as the unit of analysis, beside a single franchise studio in Christchurch, and ends with 5 questions to ask of any year-old decision.
Official sources the article relies on
- Joint Authorities Technical Review (2019)Boeing 737 MAX Flight Control System: Observations, Findings, and Recommendations, submitted to the FAA, 11 October 2019. Establishes the finding on cumulative effects in changed-product certification, and that design assumptions went without adequate review as MCAS evolved.
- US House Committee on Transportation and Infrastructure (2020)Final Committee Report: The Design, Development and Certification of the Boeing 737 MAX, September 2020. Establishes the Southwest simulator-training clause, the 2016 MCAS redesign approval, the manual change, and the accountability structure around the chief project engineer.
- Komite Nasional Keselamatan Transportasi (2019)Aircraft Accident Investigation Report, PT. Lion Mentari Airlines, Boeing 737-8 (MAX), PK-LQP, final report. The Indonesian investigating authority's report on Lion Air Flight 610.
- Federal Aviation Administration (2016)Advisory Circular 21.101-1B, Establishing the Certification Basis of Changed Aeronautical Products, 11 March 2016. Establishes that evolutionary changes during a certification programme may require the certification basis to be re-evaluated.
- US Department of Justice (2021)Press release, 7 January 2021: Boeing charged with 737 MAX fraud conspiracy and agrees to pay over $2.5 billion. Establishes the deferred prosecution agreement.
The CTO briefing (PDF) The Kettei Card and the Watchcard Kettei