Avionics News February 2012 - 16

In this monthly column, Ric Peri of the AEA’s Washington, D.C., office, informs members of the latest regulatory updates.

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P E R I V I C E P R ES I D E N T O F G OV E R N M E N T & I N D U ST RY A F FA I RS FO R A EA

Can You Hear Me Now? T
here is a TV commercial for a wireless telecommunication company, which features a traveling technician who checks the reliability and quality of the system by repeatedly asking, “Can you hear me now?” The commercial reminds me of an AEA member who got sideways with the Federal Aviation Administration, because, in their inspector’s “personal opinion,” they were listening to the wrong voice. The repair station had a customer who requested a third party audit, which may or may not have gone beyond a reasonable audit. It doesn’t matter. The auditor found something that needed to be fixed, and when the repair station attempted to correct the finding, the FAA inspector rejected the corrective action because the audit was from the wrong source. This is ludicrous. Listening is fundamental to troubleshooting, and it is the foundation to every safety and quality system in modern business. Can you hear me now? There are three basic premises of any proactive safety or quality system: listening, hearing and acting. You must actively listen. Like a trained ear that can hear static when keying a radio, a trained business ear hears the static in business operations or the slight off-tone when processes aren’t running smoothly. These off-tones, or static, are displayed when employees, customers, aviation authorities or third party auditors identify faults in the business. Does it matter where the noise originates? And, you also must act on what you hear and troubleshoot the noise. I have read hundreds of business plans, which all claim to have a process to “listen” to employees, customers and audits. Successful entrepreneurs listen to any source that will help fine-tune the business. But, being able to hear the noise, regardless of the source, is difficult. There is a difference between hearing a random noise and tuning your troubleshooting ear to actually hear what the noise indicates. How many times have you troubleshot a system simply by hearing the noise and, having an experienced ear, knowing the fault indicated by the noise, which allows you to focus your troubleshooting efforts in a specific area?
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I once worked with a company that not only professed to have a quality assurance system, but also a safety management system. Yet, based on the noise I heard, the systems had degraded to a basic quality control process. The company professed to listen but didn’t troubleshoot the noise. It only evaluated the noise for basic “regulatory compliance” and never evaluated the process for a pending failure. The company never got any better, and it is reflected in the FAA audits. The inspector kept finding indicators of the same process faults, year after year. The Part 145 and EASA 145 requirements contain two basic

There are three basic premises of any proactive safety or quality system: listening, hearing and acting.
requirements: the design and organization of the maintenance business, as well as the process of aircraft maintenance, or the quality process. These are presented in the repair station manual and the quality control manual, respectively. FAA regulation section 145.211 (a) requires a certificated repair station to establish and maintain a quality control system that ensures the airworthiness of the articles on which the repair station performs maintenance. Then, paragraph (b) requires repair station personnel to follow the quality control system when performing maintenance. So, when you hear from employees, customers or auditors that the business is running a bit rough, listen to the noise. Use a trained ear to evaluate and troubleshoot the fault, and correct the discrepancy. I routinely get calls from AEA members after an FAA inspector audited them and wrote a finding (technically a suspected finding). As I discuss the issue with the member, I routinely ask them to describe their procedure for this particu-

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Avionics News February 2012

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