Avionics News August 2015 - 13

The bottom line is every successful business
embraces continuous improvement. Sometimes it's
obvious and sometimes a bit less obvious.

underlying cause of a future noncompliance situation" as a
concern. The AC goes on to ex plain that a " concern is not, at
the time of the ex amination, an ex ample of noncompliance
with a standard. If so, it would be a finding." In most cases,
and certainly at the time of a walkthrough, your new inspector hasn' t done their investigative homework to actually
identify the " noncompliance," only that they have a concern.
Or in many cases, simply a recommendation.
H owever, this is not to say that the information is not
valuable. Listen from the inspector' s perspective. Sure,
you' ve been down this path a doz en times - a new inspector,
and a new demand. There are two elements to this scenario.
First, whoever this " new person" is, they' re disrupting your
business. Y ou' re attitude is, " Just tell me what you want, and
I' ll edit my manual so you' ll go away and I can get back to
work."
There are two problems with this. First, that' s how you got
in this situation in the first place - adding things you didn' t
understand to your manual to satisfy the last individual.
Second, it' s more likely the changes to your manual won' t
represent what you actually do - your business.
W hen a new inspector comes in like a storm trooper,
defend from making j udgements based on a first impression.
R emember, the inspector' s first impression of you may show
your warts - take the high road and listen! Listen from the
inspector' s perspective. Translate " I don' t like your manual"
to " we need to look at your business to ensure it meets the
regulations."
There are three documents that define your business: the
repair station manual, which defines your organiz ation and
infrastructure that supports maintenance; a q uality control
manual, which documents your q uality system to ensure
airworthiness; and a training program, which commits the
repair station to a defined process to ensure only q ualified
people perform and inspect maintenance.
So when your inspector sites a " dislike" with your repair
station manual elements, it can be interpreted as either
you don' t completely describe your organiz ation or your
organiz ation may not be adeq uate for what you want to do.
Listening and discussing the issue is the only way to understand which way their concern lies.

If their dislike is in the q uality system, again, it could be
that you didn' t completely capture what you do to ensure airworthiness, or that what you do could lead to q uality escapes
in the future. W ithout an open and honest discussion, there is
no way to know which direction to take.
Y ou run a successful business. It didn' t get that way by
chance or by being stuck in the 1 96 0s. Y ou' ve changed,
adapted and moderniz ed. But many shops have manuals
that describe business and processes the way they looked a
decade or two ago. D o they really represent your business
today?
The req uirements for a q uality control system are q uite
interesting, particularly for a sick-minded person like me
who actually likes to read them. For ex ample, 1 4 CFR
1 45 .21 1 ( a) first and foremost req uires the repair station to
" establish and maintain a q uality control system acceptable
to the FAA that ensures the airworthiness of the articles on
which the repair station or any of its contractors performs
maintenance, preventive maintenance or alterations." So let' s
look at this one sentence for a moment. Y ou must:
1 . Establish a q uality control system that ensures airworthiness of the articles that you work on.
2. K eep the q uality system current ( update the q uality
system as your business changes) .
3. The q uality system must be acceptable to the FAA
(not approved).
4. The q uality system also applies to any contractors/
subcontractors.
It is only after you " establish and maintain a q uality control system" that the regulations req uire the repair station to
" prepare and keep current a q uality control manual" ( 1 4 CFR
1 45 .21 1 ( c) ) .
The other thing that 1 4 CFR 1 45 .21 1 ( c) defines is the
req uirement that when describing your q uality system, you
need to define the " system and procedures used" to satisfy
each of the q uality system req uirements contained in 1 4
CFR 1 45 .21 1 ( c) ( 1 ) . So for each item listed in your q uality
Continued on page 71
AVIONICS NEWS

AUGUST

2015

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Table of Contents for the Digital Edition of Avionics News August 2015