Avionics News February 2014 - 12

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

B Y

R I C

P E R I
A EA 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

The Elephant in the Shop:
Do You See It?

D

o you see it? That elephant in the middle of the
shop; the one you've been walking around for
a decade. It's big and bulky, blocks the clean
flow of production, and may even eats up profits. Now
do you see it?
I routinely have conversations with shops about
the results of audits. They may be conducted by
the local Federal Aviation Administration or other
authorities, or a vendor audit from a customer or
some third-party audit provider. But regardless
of the source, the responses are nearly always the
same - negative. And with a certain amount of
logic, this makes sense; none of us like to fail.
And if you've built the business from scratch, having an
outsider challenge your business is even worse. Or maybe
the item of "failure" was implemented to satisfy some
other long-ago need, and the new auditor isn't considering
this well-thought purpose. Or maybe it wasn't even that
long ago, but rather to satisfy your last auditor.
A third-party audit isn't all that bad. The auditors see
what you don't, won't or can't; they see the elephant.
As we developed the safety management program
for Aircraft Electronics Association members during
the last few years, we discovered a few things. First,
information is good. Second, we don't see what we don't
see. And third, process improvement takes everyone's
participation.
So let's look at the third-party audit. First, we get a
list from the auditor, but a list of what? Some would say
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"discrepancies," but according to the Merriam-Webster
dictionary, a discrepancy is defined as "the quality or state
of disagreeing or being at variance." But we really don't
know that yet. And some might call it a list of findings.
Except, according to the FAA Advisory Circular 145-5,

A t h i rd - p a r t y a u d i t i s n ' t a l l t h a t b a d .
The auditors see what you don't, won't
or can't; they see the elephant.

Repair Station Internal Evaluation Program, a finding is
"a conclusion, supported by evidence that there has been
or is a process or product that is not in compliance with
an established standard." In both cases, a discrepancy
and/or a finding are conclusions supported by evidence.
In the case of the initial list of "concerns" from an audit,
this list is simply information at this point; none of the
information has a conclusion or a validated variance. It is
simply a list of concerns.
And if you think about it, it isn't all that different than
an aircraft inspection. When we do a visual inspection,
we identify all areas of potential variation. So the initial
list can look rather daunting to the aircraft owner. But
the second step is the validation; is the item of concern
actually a variation? Is the deviation within published
limitations? Is it normal wear and tear?
Avionics News February 2014

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