Boeing’s Licensure - Exemption Culture

Source of the following: The book Engineering’s Public-Protection Predicament, Chapter 3, “Disasters: Were Some Caused by Licensure-Exemption Cultures?” 2021, by Stuart G. Walesh

Purpose of following: Uses Boeing, which caused two 737 MAX 8 crashes that killed 346 passengers and crew, to illustrate aspects of the bottom-line-first cultures. These cultures often evolve in engineering organizations, like Boeing, that operate under exemptions to state engineering licensure-exemption laws. Therefore, the public-protection-is-paramount claim in engineering ethics codes is not operable increasing the likelihood of disasters.

Culture Defined

What does “culture” mean within an organization like Boeing, or other organizations, manufacturers, utilities, and government entities operating in licensure-exemption industries? Engineer Stephen E. Armstrong says, “Culture wields great power over what people consider permissible and appropriate…The embedded beliefs, values, and behavior patterns carry tremendous weight. The culture sends its energy into every corner of the organization, influencing virtually everything.” 1 That definition expresses culture’s complexity and power. I offer another and consistent definition of culture: The way things really work around here, especially when the chips are down.

Reporter Jerry Useem2 shares and elaborates on a similar view of culture as a collection of scripts gradually written within an organization by very busy individuals, especially managers and executives, seeking relief from being bombarded with information and pressed for decisions. However, these efficient tools can be morally or otherwise flawed, and because they are used in top-down fashion in an organization, they become embedded vertically and horizontally, as standard operating procedures (SOP). In addition, the script collection, once the theme is set, easily expands, like an “elastic waistband,” to include more scripts that are similar.

Taken together, the preceding three takes on culture capture and describe a powerful and pervasive force created, from the top down, in any organization. The exemptions environment exemplifies the power of culture.

Glimpses of Boeing’s Culture

In October 2019, while drafting this section of the book, I visited the Boeing website and scanned the first dozen descriptions of job openings that had “engineer” in the title. None listed licensure, or being on a licensure track, as a requirement. Many noted, under education requirements, bachelor’s or other degrees in fields outside of engineering—such as chemistry, computer science, mathematics, and physics. This is an example of how organizations operating under licensure exemptions, commonly assign titles containing “engineer” to individuals who have not earned an engineering degree (5.3.11). Some positions were labeled as “union-represented positions.” I share this job description information to illustrate how, at Boeing, “engineers” are employees, some members of unions. The title “engineer” is bestowed, by the employer, on whomever they wish.

Bestowing “engineer” on non-engineers suggests that companies value the word “engineer,” even if they don’t respect the education effort required to earn the right to be called a graduate engineer. Maybe employers misuse the word for recruitment and retention purposes.

Consider another example of this kind of distortion. In 2003, efforts by the Florida Engineering Society to require proper use of “engineer,” were thwarted by the aerospace industry, which obtained an exemption in legislation that allowed, in aerospace, “identification of their employees as engineers, regardless of their qualifications.” 3

As part my research, I encountered or learned about mostly engineers and others who once worked for Boeing and shared their experiences, which provided personal insights into how licensure exemption influences engineers and engineering and other activities within Boeing. Consider some of their views.

Alan Werner, PE an NSPE Fellow NSPE wrote: “Licensed engineers do not have a role in aircraft design because of the industrial exemption. As a matter of fact, a PE cannot display his/her credential on their badges” at Boeing.4

Ed Pierson worked at Boeing from 2008 to February 2019, with his last position being senior manager, production system support. Pierson, who is not an engineer, graduated from the U.S. Naval Academy and served in the Navy before joining Boeing. On December 11, 2019, Pierson testified as part of the House of Representatives hearing, “The Boeing 737 MAX: Examining the Federal Aviation Administration’s Oversight on the Aircraft’s Certification.” 5

Pierson’s well-documented message was that, beginning in June 2018, four months before the first of the two crashes, he made many attempts to get Boeing to change aircraft production processes, including two recommendations to shut down the production line. His concern was an unstable production environment characterized by employee fatigue, out-of-sequence tasks, and communications and scheduling breakdowns—the cumulative effect of which was likely to lead to faulty aircraft and public risk. Pierson cited aircraft sensors, which played a role in the two disasters, as one example. His whistleblowing efforts failed.6

Retired engineer Cynthia Cole, who initially enjoyed working at Boeing during the early part of her 32-year career there, stated during an October 2019 interview that the safety-first culture at Boeing began to weaken after the company purchased its rival McDonnell Douglas in 1997. According to Cole, “greater emphasis on maximizing profits over safety caused all kinds of problems as the company developed the 787 Dreamliner, which ended up three years behind schedule and billions over budget.” The Dreamliner, which just preceded the 737 MAX, was grounded 14 months after beginning service because its lithium-ion batteries ignited.

Engineers, who often have pride in the results of their work, can empathize with Cole when she said that pulling the 737 MAX 8 from service globally was demoralizing and made her sad. Aerospace engineer and aviation industry analyst, Bjorn Fehrm, noted “safety has always been a high priority a Boeing…but it hasn’t been high enough.” 7

Another engineer, who left Boeing in the early 2000s and preferred to be anonymous, confirmed the PE credential non-display policy. This individual also explained how, because of a 2000 strike involving engineers and a big drop in stock value, the human resources policies gradually downgraded requirements for engineering positions. This led to today’s omission of references to licensure tracks, as well as the dropping of the requirement that engineers hold degrees from ABET-accredited engineering programs, and allowing individuals without engineering degrees to hold engineering positions.

Another anonymous engineer, who worked at Boeing for seven years, resigned immediately after the strike. While this person initially “loved working at Boeing,” citing the work and coworkers as the best parts, the engineer became increasingly concerned about changes within Boeing following its 1997 purchase of McDonnell Douglas. Examples of such changes included “ethical lapses” and what the engineer saw as a choice to sacrifice the company’s key competency—wing design—to make Boeing more of a systems integrator and less an aircraft designer. The engineer disliked the unionization of engineers and the system whereby Boeing “self-polices itself” on behalf of the FAA and the Joint Aviation Authorities (JAA), a safety-oriented organization of some European countries.

According to this former Boeing employee, PE licenses “are not needed in aerospace and as such there is zero desire or incentive to get one.” Finally, in response to my question about the cause of the two Boeing 737 MAX 8 crashes, this former employee speculated the cause was probably lack of engineering “rigor” and “oversight.”

In 2016, during the 737 MAX certification process, Boeing conducted an internal survey that revealed aspects of its culture at the time. A whistleblower later provided results of that survey to the previously mentioned U.S. House of Representatives Committee on Transportation and Infrastructure. The results: 39 percent of employees reported “undue pressure” and 29 percent expressed concern “about consequences if they reported potential undue pressure.” 8

Three years later, and after the two crashes, Boeing engineer Curtis Ewbank filed a formal internal ethics complaint related to design of the 737 MAX expressing concern that managers rejected engineering suggestions to include a system that could detect malfunctioning AOA sensors. Why had he not taken such strong action during aircraft design? Ewbank said, in the complaint, that “fear of retaliation was high.” 9 Recall that the NTSB determined that the AOA sensors malfunctioned in both of the disasters.10

For a final insight into Boeing’s culture, listen to some of the internal 737 MAX messages in documents delivered, in January 2020, by Boeing to congressional investigators: 11,12

  • Boeing employee referring to colleagues involved in the development of the troubled plane: "This airplane is designed by clowns who in turn are supervised by monkeys."
  • Boeing employee referring to an exchange of information with the FAA: "I still haven't been forgiven by God for the covering up I did last year."
  • Boeing employee referring to FAA officials watching a complicated presentation given by Boeing personnel: “It was like dogs watching TV.”
  • Boeing employee speaking to another employee: "Would you put your family on a Max simulator-trained aircraft? I wouldn't." The other employee said "No."

Boeing officials apologized to the FAA, Congress, its airline customers, and the flying public for the statements noting that they were “inconsistent with Boeing values.”

Finally, consider the view of a former Boeing test pilot quoted in Peter Robison’s 2021 book Flying Blind: The 737 MAX Tragedy and the Fall of Boeing. He said that executives “never paid a price…Boeing got away with murder.”

In an interview with Consumer News and Business Channel (CNBC) on November 5, 2019, David Calhoun, chairperson of the Boeing board, mentioned the company’s internal investigations of the 737 MAX 8 disasters in October 2018 and March 2019. When asked what those investigations revealed about what had happened within the company in the design of the 737 MAX 8, Calhoun said, “Nobody was hiding anything. It was set of engineering decisions that ended up being wrong.” 13

On December 22, almost seven weeks later, the board fired CEO Dennis Muilenburg, a graduate aerospace engineer, apparently because he was not “winning back the confidence” of the traveling public, the FAA, airlines, and suppliers. Calhoun was named to replace him.14 Muilenburg’s reputation and other considerations aside, he left the company in solid personal financial shape—with “$62 million in vested incentive awards, stock, and retirement benefits.” 15

In licensure-exemption cultures, major engineering decisions are often made by, or made in response to pressure from, bottom-line managers or others, not by licensed engineers. Examples appear throughout this chapter.

Chairman Calhoun’s CNBC interview answer and the Boeing board’s discharge of Muilenburg may have been convenient for them and corporate executives because it cast blame downward in the organizational hierarchy, onto “engineering decisions” and, therefore, engineers. However, engineers may not have made the key engineering-related decisions because in that culture, they are rarely in responsible charge. Boeing engineers are employees.

And all of this is both legal—because of state licensure-exemption laws—and disturbing. Why disturbing? Because the best engineering that the U.S. engineers have to offer via their formal education, continuing education, licensure responsibilities, and ethics obligations cannot thrive within a licensure-exemption culture like that at Boeing and similar organizations, as illustrated in this chapter.

Cited Sources:

1) Armstrong, S. C. 2005. Engineering and Product Development Management: A Holistic Approach. Cambridge, UK: Cambridge University Press.

2) Useem, J. 2016. “What Was Volkswagen Thinking?” The Atlantic, January/February, pp. 26-28.

3) National Council of Examiners for Engineering and Surveying (NCEES). 2013. “Industrial Exemption Task Force.”

4) Werner, A. 1919. PE and Fellow NSPE, personal communication with author, October 13, 2019. He allowed use, with attribution, of a portion of his July 4, 2019 post to a NSPE blog.

5) U.S. House of Representatives, Committee on Transportation and Infrastructure. 2019. “Hearing—The Boeing 737 MAX: Examining the Federal Aviation Administration’s Oversight of the Aircraft’s Certification.” December 11,, accessed January 1, 2020.

6) CBS News. 2019. “FAA Analysis Flagged 737 MAX Risks before Fatal Crash.” December 11,, accessed January 1, 2020. 

7) Schaper, D. 2019. “Boeing’s Cultural Shift.” NPR, Weekend Edition, October 26,, accessed December 31, 2019.

8) U.S. House of Representatives, The House Committee on Transportation & Infrastructure. 2020. “The Boeing 737 MAX Aircraft: Costs, Consequences, and Lessons from its Design, Development, and Certification – Preliminary Investigative Findings.”

9) Kitroeff, N., D. Gelles, and J. Nicas. 2019. “Boeing 737 MAX Safety System Was Vetoed, Engineer Says.” New York Times, October 29,, accessed July 10, 2020.

10) National Transportation Safety Board (NTSB). 2019. “Safety Recommendation Report -- Assumptions Used in the Safety Assessment Process and the Effects of Multiple Alerts and Indications on Pilot Performance.”

11) Schaper, D. and V. Romo. 2020. “Boeing Employees Mocked FAA in Internal Messages before 737 Max Disasters.” NPR-Business, January 9,, accessed January 10, 2021.

12) Kitroeff, N. 2020. “Boeing Employees Mocked FAA and Flouted Safety in Internal Messages.” January 11, The New York Times,, accessed January 10, 2021.

13) CNBC. 2019. “Watch CNBC’s Full Interview with Boeing Chairman David Calhoun.” Squawk Box, November 5, 2019,, accessed May 11, 2020.

14) Tangel, A. and D. Cameron. 2019. “Boeing Ousts CEO Amid Crisis.” The Wall Street Journal. December 24, 2019.

15) Pasztor, A. and A. Sider. 2020. “Chatter at Boeing Undercuts Its Defense of Max Stance.” The Wall Street Journal, January 11-12, 2020.

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