Two-Person Control

Does the death of a key employee – one responsible for completing reports and placing things in the public file — excuse licensee reporting and public file violations that follow? The answer is no, and the FCC’s latest decision levelling an $18,000 fine for public file violations after an employee death reaffirms the Commission’s long held policy that the licensee is ultimately responsible, regardless of an employee situation.

Which gets us back to the title of this article. For all FCC actions or requirements, we recommend that at least two persons be trained to properly and timely complete those requirements, and then cross-check each other at appropriate intervals to ensure that the actions are being taken. That way, if a key employee is hospitalized, takes a leave of absence, quits or passes away, the station’s required FCC actions are not forgotten, and the station avoids a later monetary forfeiture.