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 accident stated that oversight of foreign carriers under Part 129 included inspections of trip records and facilities in the United States and ramp inspections of airplanes and crews when they were in the United States or its territories. However, the POI stated that the FAA did not inspect, approve, or oversee a foreign airline's training program or any of its manuals or accomplish line checks or en route inspections on board foreign airlines. (There is no requirement that a foreign carrier provide the FAA POI with flight operations or training manuals.) The POI also stated that there was no formal interaction between the KCAB and the FAA regarding their respective oversight activities relating to Korean Air.

The Safety Board notes that the purpose of the FAA's International Aviation Safety Assessment (IASA) program is to ensure that foreign air carriers operating in the United States are receiving adequate oversight by their respective civil aviation authority (CAA). The FAA developed this program in response to an identified need to oversee foreign carriers operating to the United States; however, the FAA's assessment under that program is limited to an evaluation of the foreign CAA's ability to provide oversight in accordance with ICAO Annex 6 standards. The FAA does not directly assess whether foreign carriers are receiving such oversight or are complying with Annex 6. When the FAA assessed the KCAB in 1996, the FAA concluded that the KCAB was capable of overseeing Korean air carriers in accordance with ICAO safety standards, and Korea was therefore given a Category I rating (the highest rating of the three IASA categories). The FAA indicated that it would reassess a country that has air carriers operating into the United States if there was any reason to question whether that country was meeting its international safety oversight obligations.

The substantial number of Korean Air crew-related accidents and incidents, the deficiencies in Korean Air's pilot training program, and the lack of documented cockpit procedures suggest that Korean Air had not fully complied with the intent of paragraph 9.3.1 of ICAO Annex 6, which states that operators "shall establish and maintain a ground and flight training program...which ensures that all flight crew members are adequately trained to perform their assigned duties. [The training program] shall also include training in knowledge and skills related to human performance and limitations...[and] shall ensure that all flight crew members know the functions for which they are responsible and the relation of those functions to the functions of other crew members."

The reliability of the FAA's assessment and rating of a country's CAA under the IASA program is becoming ever more important in light of increases in code-sharing and other alliances involving U.S. and foreign carriers. U.S. carriers are likely to view a positive assessment by the FAA and the resulting Category I rating as an indication that the country's airlines are receiving adequate oversight and are therefore maintaining an adequate level of safety. However, even though Korea had received and maintained a Category I rating, the evidence developed in this investigation (including that only two operations inspectors were assigned to Korean Air and that neither was type rated for the 747, as well as the deficiencies in the KCAB's oversight of Korean Air) and Korean Air's accident and incident record (both before and after the flight 801 crash) suggest that the FAA's IASA program was not adequate in its scope and depth to determine the capacity of the KCAB to fully assess Korean Air's level of safety or ensure that Korean Air was