Much of what has been written above is applicable to a DER system but not to an ODA. There are very important distinctions between the DER system under 14 CFR 183.29, and the ODA system that Boeing has under 183.63. Unlike in the DER system, the ODA unit members at Boeing (the people making compliance findings) are isolated from the FAA staff to a significant extent, and are not directly overseen or supervised by FAA staff.