Avionics News January 2012 - 15

...For the industry, know the rules, know your processes and be able to explain to the auditor how your process meets the intended outcome of a regulatory requirement.

leadership tried to modernize the repair station regulations, only to be sabotaged by 418 pages of instructions prescribing what the 22 pages of the regulations mean. It breaks down to 118 pages of “public” guidance and 290 pages of the prescriptive inspector’s guidance, including 131 pages to describe the procedures to evaluate a repair station’s processes as a function of manual review and acceptance. But, it then offers 159 pages of prescriptive processes to be reviewed as a function of the FAA periodic audit. And, what is unheard of in the quality world, there is no correlation between the guidance for the development of repair station processes, the review and “acceptance” of those processes and the inspector’s required audit procedures of those processes. One of the modern systems I had the privilege to audit in Europe is the management of a business’s capabilities. The regulations (§ 145.201 (a)) specify that a repair station may perform maintenance, preventive maintenance or alterations on “any article for which it is rated and within the limitations in its operations specifications.” The regulations (§ 145.215 (a)) further allows a repair station with a limited rating to perform maintenance, preventive maintenance or alterations on an article, if the article is listed on a current capability list or their operations specifications. One particular facility has two capability lists; one, an unofficial list provided on its website for marketing purposes, and a second one printed twice a year for the local FAA office. The operational capability list is integrated within a very robust computer system that does not allow sales on a component whose part number is not contained in the capability system. The system will not generate a work order without an approved part number, and the work order prints the repair station’s capability (overhaul, repair or inspection) on each and every work order.

This system is the most robust, automated, fail proof digital system I have had the opportunity to work with in 40 years in aircraft maintenance. Yet, it is so modern in its design and concept that the FAA needs it “dumbed down” so it can “tick off” a box in its analog audit requirements issued by headquarters. The technicians need to know nothing about how the capability list is generated or what the capability list represents. The regulations about the capability list simply are background noise for the technicians. The management of this company has invested in technology to raise the decision process to the highest level, which allows technicians to focus on technical competency. The computer system simply does not allow the generation of work orders or return to service documents for any article that the repair station is not regulatorily capable to perform. So, while they have a very thorough process to manage the repair station’s capabilities, there is no formal “capability list.” It is, however, one of the most robust capability “systems” I have had the privilege to observe. How did we get here? I think through the same path Part 23 lost its way. The guidance materials have continued to grow and become more prescriptive as the guidance was developed, never deleting outdated or repeated guidance, but continuing to build upon a system until we have 131 pages of audit requirements for a repair station whose manual defining its processes seldom exceeds 25 pages. Essentially, we are a victim of our own creative success. Yes, we are, at least partially, to blame for the challenges we face. Although, I’m not sure blame is the correct word, and perhaps
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january

2012

Avionics News January 2012

Table of Contents for the Digital Edition of Avionics News January 2012