Avionics News November 2016 - 71

THE VIEW FROM WASHINGTON
Continued from page 11

eliminate or control their associated risk. We do this
by performing design assessments and performance
assessments based on system safety principals.
The immediate thought is this: Doesn't 14 CFR
Parts 145, 43 and 91 already do this? And the answer
is either yes, it does, or the agency is woefully
deficient in fulfilling its statutory duties. I can assure
you it is the former rather than the latter.
Of course, the agency has designed and
promulgated appropriate effective safety standards as
is required by the Federal Aviation Act. So you ask, if
this is all true, then why more bureaucracy? I would
suggest, that is actually the answer, developing a riskbased oversight program that reduces the bureaucracy
for those who are low risk, thereby allowing increased
oversight for those who need it.
The AEA has been working hard during the past
decade to reduce the overall risk of the avionics sector
through training, education and outreach with an eye
toward the resultant benefit of a low-risk sector of
the aviation industry. The association has been using
the concepts of risk identification, management and
mitigation, as well as continuous improvement in all
AEA events, courses and communications.
I know that 99 percent of the AEA members are
absolutely safe! I'm extremely comfortable making
that statement and supporting it with my visits to
the membership's businesses, as well as through
conversations at the AEA Connect Conferences, the
annual AEA International Convention & Trade Show,
plus the occasional phone calls.
So the question is, if we are already safe and
fully compliant with the regulations, why this added
burden? Simply put, as an industry, we must be able
to explain what our risks are and how we control
them.
14 CFR Section 145.5 (a) states that "No person
may operate as a certificated repair station without,
or in violation of, a repair station certificate, ratings,
or operations specifications issued under this Part."
Then, the regulations require the repair station to
possess the "housing, facilities, equipment, material,
technical data, processes, and trained personnel"
appropriate to the requested ratings and operations

specifications. The regulations then require the repair
station to define its infrastructure (housing, facilities,
equipment, personnel) in its repair station manual,
then its processes and quality system in its quality
control manual.
The regulations are good at clearly establishing
the minimum standards. To define how the manuals
should be written, Advisory Circular 145-9 contains
the design and organization of the manuals. But going
back to the late 1990s, the intent of the 1999 Part 145
Notice of Proposed Rulemaking was to shift the repair
stations to a quality assurance-based approach to
managing repair stations.
This is why the basis of the repair station
quality control system is to define the "system and
procedures" for each element. It is your business, you
have a vested interest in your business running like
your business, not some government cookie-cutter
business. But when you look at the regulations for a
quality system, section 145.211 (a) requires a repair
station to establish and maintain a quality control
system that ensures the airworthiness of the articles.
So the regulations tell us "what" is needed; the AC
tells us "how to document" it; and now SAS provides
"what to consider" while ensuring the airworthiness
of the articles we maintain.
Contrary to most of the phone calls, while the name
of the program may be new, the terms and concepts
are not. And while there is no regulatory mandate
for Safety Management Systems within a repair
station, the concept of risk assessment, management
and mitigation are all common to SMS and available
to all AEA members through the association's SMS
program. The association has been using these terms
and concepts in training, education and outreach for
more than a decade.
Unfortunately, there are new terms (responsibilities,
controls, process measures), but there is nothing
that every successful business currently does not do
every day. The better we can articulate our risks and
our controls of those risks, the more comfortable the
agency will be with industry and the more it will
focus its efforts on businesses that don't know their
risks, nor how to control them.
So as your ASI stumbles with this new language,
don't shoot the messenger. They are learning as they
go, too. q
avionics news

november

2016

Table of Contents for the Digital Edition of Avionics News November 2016