Pilot's Guide to Avionics 2011-2012 - 88

IT’S THE FAA’S FAULT, RIGHT?
Continued from page 87

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The more I ask this question, the more answers I receive: “Does your manual represent your business?” The AEA does not provide a repair station manual template for a reason — your manual must represent and describe your business, not someone else’s business . In the past few months, I have talked with a number of AEA members who began the conversation with, “My new inspector wants to change my manual .” And I ask, “Why?” In most cases, I’ll ask the shop to email the manual to me . In one case, when reviewing the latest version of a shop’s manual, I asked, “Is this how you run your business?” The shop owner responded, “Well, no, it’s what my last inspector had me add to the manual .” I know we joke about this all the time, but what two FAA inspectors agree with one another? I would make the argument that we could run a blind test in which we have FAA headquarters, the instructors at the FAA institute and the local FSDO write a half a dozen manuals, then submit them to six different third-party FSDOs for review and acceptance, and none of them would pass . Simple fact: It might not be right, but they simply don’t agree with one another . Another AEA member called me recently about a request to change his shop’s manual . During each of the past couple of inspections, the repair station’s inspector mentioned the receiving inspection . From asking questions and reviewing the manual, I discovered there was a huge disconnect between “what” the shop did and “how” the shop described it in its manual . The shop was doing the work correctly; however, it completely omitted the process from its manual . Simple fix: Write down what you just told me . If you changed your manual to appease your previous inspec- 88 -

tor, don’t complain when the new inspector doesn’t agree with the old inspector and you have to change your manual again . It’s the path you chose, not the path required by the regulations . The decision is simple: Does my inspector control the content of my manual, or does my manual represent my business? If my inspector controls the content of my manual, my new inspector gets the same courtesy . On the other hand, if my manual represents my business, I control my manual . There are only four reasons to change your manual — period: • Your manual does not represent your processes, personnel or facilities . • Your processes do not conform to the regulations . • Your processes are correct technically, but they might be difficult to follow consistently . • You have changed (or are planning to change) your business and you need to add or remove a process . During the 2010 AEA convention, FAA Administrator Randy Babbitt made a point of mentioning what happens when no one is watching . He said he doesn’t care too much about how someone performs on a check ride; he is more concerned about how someone performs when they aren’t on a check ride . I think this is a powerful message: How are we performing when the bosses are gone? It’s 2 a .m . and we’re tired; are our processes simple and straight-forward, resulting in a compliant program? Or, are we relying on a marginal program that takes for granted that humans do the right thing every time? Sure, the FAA is involved in nearly every facet of the aviation industry, but it is not solely responsible for the outcome and burdens of our decisions . It really isn’t always the FAA’s fault . q
Ric Peri is the AEA’s vice president of government and industry affairs.

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Pilot's Guide to Avionics 2011-2012

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