Avionics News February 2014 - 13

The real issue is what we do with the information and
how we manage it. Yes, manage it.
For the sake of simplicity, let's look at the third-party
"information" provided by your civil aviation surveyor
(FAA inspector for those in the U.S.). Sure, their purpose
is to ensure you are complying with the regulations. In
a perfect world, the review of regulatory compliance
would be when your manuals (expositions) were
reviewed and accepted, then the review and audit would
simply be a matter of asking, "Are you doing what you
said you would do in your procedures manual?" So for
the rest of this discussion, I will use the FAA model
for review; it's the worst-case scenario from a quality
system perspective. So your inspector has identified
some areas of concern; now what?
If you are participating in the AEA SMS program, you
know we have built in a checklist/process for addressing
audit findings from any source, including the FAA,
through the following procedures.
Step 1: Investigate the item. Remember, a
discrepancy or finding is the result of a "conclusion"
of a variance to the standard. So we shouldn't make
assumptions, but rather investigate the item. Is what
the audit saw, in fact, valid? Years ago, I had an auditor
who was looking for one thing and saw something out

of context, resulting in a write up. Once the item was
investigated, we were able to resolve it by addressing the
misconception on the part of our auditor.
Step 2: Cull out the valid concerns from invalid
concerns.
Step 3: Investigate the valid concerns. This
investigation is an interesting step. There are three
possible scenarios: You (the repair station) are following
your manual but the manual procedures are in error;
you are not following your accepted procedures; or the
procedure you are performing is wrong and not listed
in the manual. When we talk about "the manual," it
may be the repair station manuals (expositions) or the
maintenance procedures in the maintenance manual, ICA
or other maintenance data.
Step 4: Ask why. This is drilling down to the root
cause, not just a superficial cause of the failure, but the
foundational cause or, in many cases, causes. You might
be able to find the cause by simply asking and answering
"why" once. But in many cases, you must continue
asking why until you cannot drill down any further. As
you begin drilling down to the root cause, you may find,
and likely will find, there are multiple paths that need to
be investigated.
For example, let's assume there was a simple
error made by a technician. Why didn't they follow
procedures? It may be that the technician was distracted.
Perhaps he or she was texting, listening to music,
conversing, late for an appointment, a child was sick
or there was an airshow outside. There could be a
hundred reasons to be distracted. Why was he or
she distracted?
Or maybe, the technician wasn't trained
properly. Why? Was there an assumption
that he or she had adequate training? This
leads us down another path; why didn't
our screening process in our repair station
training program catch the lapse? Maybe we
didn't provide enough time, or the training
was expensive. Again, we drill down
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Avionics News February 2014

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