The normal ongoing surveillance of Arrow Air by the FAA did not identify any deficiencies in Arrow Air's ability to comply with applicable FARs or established FAA procedures. Both assigned principal inspectors testified at the Board's public inquiry that, during their surveillance, they noted no significant discrepancies in Arrow Air's methods of operation.

In contrast, the special inspection conducted in January and February 1986 noted numerous examples of non-compliance with FARs and established FAA procedures in certain areas of Arrow Air operations. In some cases, findings of the 1986 inspection were similar to those made during the NATI conducted in 1984. Although, according to the FAA, many of the findings were later determined to be of a minor nature and enforcement action resulted in civil penalties or warning/correction letters in only 10 cases, the Board is concerned that routine surveillance, characterized by the FAA to be the most thorough in the company's history, was unable to identify these deficiencies.

As a result of the 1984 inspection, numerous recommendations had been made with respect to increased surveillance and follow-up. According to the FAA, in the months preceding the accident, their surveillance and follow-up of Arrow Air was executed to a greater degree, both in quality and quantity, than ever before in the company's history. Nevertheless, the Board notes that, in the months preceding the accident, the assistant operations inspector position at Arrow Air had been vacant and that the POI assigned to Arrow Air testified at the Board's public inquiry that the resources available to him for surveillance of Arrow Air were inadequate.