I detect that I have set a new personal record (woohoo!) for the amount of acronyms in a blog article title at four. If you’re reading this, you probably already have a good handle on what they mean, but more on that later.
Before we get started I wanted to make a suggestion to those of you who are responsible for maintaining those pesky Approved Supplier Lists required by nearly all quality standards. Many of you give automatic approval to firms who are accredited, for example, to the ASA-100, and are shown on the FAA’s listing of AC 00-56 accredited distributors. For firms who are accredited disassemblers and recyclers, the listing of such firms is maintained by the Aircraft Fleet and Recycling Association (AFRA) on the Directory Tab of their https://afraassociation.org/ website. For AFRA accredited listed firms, you too can also give them automatic approval for those services. Royboy’s counsel: As with the ASA-100, don’t confuse membership with accreditation. Although membership is always encouraged, membership alone does not guarantee a bona fide quality system.
A PRIMER:
Many years ago, with the forecasted accelerating growth of aircraft retirements, the industry recognized a need to retire and recycle aircraft in an orderly and uniform manor. AFRA, the Aircraft Fleet and Recycling Association (AFRA) stepped up and worked with many industry leaders to develop the Best Management Practices (BMP) for Disassembling and Recycling Aircraft. The BMP was and remains the basis for establishing a quality system to perform this work. It is also the basis for accreditation. Firms who demonstrably implement and uphold the BMP are audited, and upon passing are placed on AFRA’s list as previously mentioned. The BMP has been continuously updated by AFRA committees.
ASA and AFRA
All of you who attend the ASA conference will notice that the ASA and AFRA hold their conferences jointly. This is not coincidental. The members of each organization actually conduct a good deal of business with each other, and it is not unusual to find firms holding dual memberships and/or accreditations in each association.
IATA:
First, a little bit about IATA. From their website at www.iata.org:
“The International Air Transport Association (IATA) is the trade association for the world’s airlines, representing some 290 airlines or 82% of total air traffic. We support many areas of aviation activity and help formulate industry policy on critical aviation issues.”
That is really an understatement. For all of us that fly, IATA has been a globally accepted influencer and facilitator for airline business. For example, they have established standards and guidance for Baggage handling and ID, addressing tariffs, Airline coding, scheduling, ticketing and reservations, security, loading, fuels, costing, dangerous goods, finance, accounting, and leasing among many others. IATA’s stated mission is to represent, lead, and serve the airline industry. IATA has been presenting regularly at the ASA/AFRA conference and they always provide valuable global industry insight.
IATA’s BIPAD:
At 101 pages, IATA’s BIPAD document, Best Industry Practices for Aircraft Decommissioning, is rich in guidance aimed at aircraft owners or operators regarding business processes and operational experience from best practices in the industry. On the other hand, AFRA’s BMP is primarily aimed at firms actually performing aircraft disassembly and recycling. From my analysis, I concluded that the two documents are complementary, and in fact the BIPAD cites the AFRA BMP frequently. I like the BIPAD because for anyone contemplating an active entry into the disassembly and recycling market, the BIPAD provides additional data and guidance which could establish the basis for a business plan. There are some interesting and indeed welcomed sections of the BIPAD that I like. For example:
ICAO’s influence.
Like IATA, the International Civil Aviation Organisation has, and continues to exert a great influence on existing and emerging global aviation regulations and procedures. The BIPAD acknowledges this with the following:
“The International Civil Aviation Organization (ICAO) supports activities related to aircraft end-of-life and recycling. At its 39th Assembly in 2016, States were requested to: “consider policies to encourage the introduction of more fuel-efficient aircraft in the market, and work together through ICAO to exchange information and develop guidance for best practices on aircraft end-of-life such as through aircraft recycling” 9.
ICAO has signed a Memorandum of Understanding (MoU) with the Aircraft Fleet Recycling Association (AFRA) to enhance cooperation and development of best practices for the management of aircraft end-of-life processing 10.
In its Environmental Report 2016, ICAO has further reiterated the need for aircraft life cycle assessments which includes a report of best practices implemented by AFRA and Bombardier in managing an aircraft’s end-of-life 11.”
It should be clear that ICAO, IATA, and AFRA are harmonized in their support of orderly and standardized aircraft retirement practices as embodied in the BMP and BIPAD.
By the way, for those you wishing that someday there would be a single set of globally accepted regulations, it will likely come from IATA and/or ICAO. Imagine, a Repair Station/AMO who only needs a single 145 approval rather than ten to do business internationally. Just sayin…
Over ‘n out
Roy “Royboy” Resto
President/FAA-DAR
AimSolutionsConsulting.com
A banal cliché overheard during political campaigns is ‘working together’. I figuratively roll my eyes at the lack of creativity in that diluted, overused utterance. Fortunately, despite cynics, there really are examples in governance where that term bore fruit.
Every government organization has its head; the Administrator, or Director for example. An oft heard refrain among those leaders is that the goals of the organization can’t be met without the active participation of industry; in other words, working together (there’s that term) to achieve mutual goals. So…are there any examples of such collaboration? Without question, a paragon model has been the FAA’s Advisory Circular 00-56. Later in this article are some interesting statistics and facts, but let’s not get ahead of the story.
To understand the profound impact the AC had on the industry, it’s important to understand the environment that existed at the time of its creation.
Bogus Parts: those were the trigger words on everyone’s lips in the early 90’s. News programs and articles were saturating the marketplace warning of the perils of bogus parts. In fact there was such a tumult that Politicians held public hearing on the issues, and many independent ‘experts’, airline representatives, trade Associations, and FAA employees, among others gave testimony which at times painted a dire picture, and in some instances a somewhat sensationalistic, scary portrayal of the issues. At the conclusion of the hearings the Senate gave the FAA a list of problems that had to be fixed. In response the FAA established a special office whose charter was to fix the problems contributing to Unapproved Parts (or now commonly called SUPs – Suspected Unapproved Parts). Most of you recall Ken Reilly who headed that office for a long time and who, for his efforts was a recipient of the prestigious ASA “Eddy” award. But, back to the AC…
One of the problems cited by the Senate for the FAA to fix regarded the state of distributors. Unlike manufacturers, operators, and repair stations, distributors were not regulated, had no oversight, and were not required to implement and follow aviation style quality systems. It was felt that if bogus parts were to find their way into the industry, the weak link would be the distributors who supplied parts to both manufacturers and operators. There were some in the industry (and at first I counted myself among them) which took the position that distributors should be regulated and certificated by the FAA. At the time I recall a number being bandied-about was 2000 regarding the estimate of the number of distributors (including stockists and brokers) globally. Certificate that! As you can imagine, the FAA was not going to be funded to regulate even a fraction of that number. So, the standoff stood; what to do about the wild-west among distributors? Enter the draft of the AC 00-56, ‘Voluntary Distributor Accreditation Program.’ To be sure, there was government-industry collaboration in writing, editing, and fielding it. A few names that come to mind in that campaign are Dennis Piotrowski, Ed Glueckler, and Al Michaels (also an “Eddy” recipient) among others.
Out came the initial FAA AC. The Air Transport Association (now Airlines for America, A4A) distributed it to their constituent airline members, and here was my first exposure to it. I was working for a major airline and was handed the job of determining what the airline’s position was going to be regarding its substance. In a rather large meeting held with the heads of Purchasing, Material Control, and QA, I introduced the AC and solicited feedback. There were, and still are two lines in the AC that stood out to this management group: “We (the FAA) consider obtaining parts through accredited distributors is a sound safety practice.” And “If a certificated customer uses an accredited distributor, and voluntarily reports any known potential violations of 14 CFR rules, we would recognize the fact that the certificate holder obtained the part from an accredited distributor as a mitigating circumstance in any subsequent administrative or enforcement action.”
The terms, “…sound safety practice”, and “…mitigating circumstance…” rang pretty well for this safety conscience airline. It took about 15 minutes of discussion and a senior Director gave the order to send out a letter to all its after-market distributors which stated they had a year to become accredited or risk being dropped from the airline’s approved supplier list, and oh yes, I was to administer this, and out went the famous letter to its suppliers. So-much for being a ‘voluntary’ program. Other airlines and manufacturers saw the benefits of the program and similarly used the program as a basis to approve their distributors. Thus steadily, the AC became a success and gained global acceptance.
Interesting: When the AC was being drafted there was the thorny issue of who would administer the listing of firms meeting the requirements of accreditation; the “Database Listing”. This is not just a simple matter of posting a listing on a web site. There are administrative procedures that must be followed, records kept, follow-ups, and yes the web site upkeep. Read paragraph 10 of the AC and you’ll get the picture. At first it was thought that the FAA would perform this task, but alas, this too was not likely to get funded. The ASA volunteered. In the AC, the FAA delegates the keeping of the Database to the ASA. It’s an unheralded fact that the ASA has been flawlessly performing this mission pro bono since the AC’s inception; bravo ASA!
The FAA has twice updated the AC and participated in ride-along audits. The AC and the accreditation program is a living document. Every day there’s countless activity in many parts of the world triggered by the AC; Manuals being updated, external and internal audits being performed, training imparted, records updated, findings and non-conformities being addressed, Approved Suppliers Lists being updated, documents generated, orderly scrapping of parts, inspections performed, and rosters updated, just to name a few, and all in conformity with… AC 00-56.
25 years of a very effective cooperative effort between government and industry.
Roy ‘Royboy’ Resto
www.AimSolutionsConsulting.com
Last year the ASA recorded 41 Repeat Findings during audits. What behaviors (or lack thereof) contribute to the likelihood of new or repeat findings?
I was recently in a hotel listening to the local news broadcast. An area leader was celebrating the now wide-spread availability of Narcan in the community, Narcan being the medication used to help save those who are experiencing an opioid overdose. Narcan has been very successful in bringing down the rate of deaths due to opioid overdoses. In the news story there was plenty of high fives and back slapping for admittedly the good news of the availability of this important lifesaving medication, but there was nary a word about the community’s epidemic of opioid addictions, and what, if anything, was being done to address it’s causes. This issue, as with most social issues, are glaringly devoid of Root Cause Analysis.
Regarding Root Cause Analysis, herein RCA, a common quote goes like this:
As an auditor of various Quality Systems, it has been observed that many Corrective Action Procedures contain a provision for Root Cause Analysis, but upon examination the RCA section appears superficial - the person(s) processing the NCR (Non-Conforming Report) or CAR (Corrective Action Report/Request) is mostly focused on fixing the noted discrepancy but not on the Root Cause. That’s disappointing because it is well known that failure to fix the Root Cause greatly increases the chances that the noted issue will repeat itself.
To be clear, the intent of this article is not to teach you about all the RCA methods, because literally many books and training courses address this in detail, but to bring to your attention the usefulness of this technique to really crush those troubling NCRs which may or may not be repeat offenders. Nonetheless, a quick primer on the topic follows.
So, what exactly is RCA?
According to the ASQ1:
“A root cause is defined as a factor that caused a nonconformance and should be permanently eliminated through process improvement. The root cause is the core issue—the highest-level cause—that sets in motion the entire cause-and-effect reaction that ultimately leads to the problem(s).”
“Root cause analysis (RCA) is defined as a collective term that describes a wide range of approaches, tools, and techniques used to uncover causes of problems. Some RCA approaches are geared more toward identifying true root causes than others, some are more general problem-solving techniques, and others simply offer support for the core activity of root cause analysis.”
If you were a full devotee of the topic, you would have been introduced to the many methods available to perform the analysis such as:
Notice the 5 Whys method. For firms seeking an easy to use and understand method, the 5 Whys seems to be popular. On the ASA website for ASA-100 audits is an example of how to perform and enter Root Causes on intelex responses. This one is for a self-life part which was not on the self-life tracking listings2:
The key to successful 5 Why analysis is to be brutally frank and do not stop the ‘why’ questions until the answers have been exhausted; it may be more, or it may be less than 5.
An organization held in the highest regard for root cause identification is the National Transportation Safety Board, NTSB. They perform their analysis and investigations with the singular focus of identifying the root causes of the accidents. There can be no question that their stalwart analyses have made significant and profound contributions to the level of safety we enjoy today. Indeed, they perform this in an atmosphere usually charged with external parties exhibiting emotions, and who have parochial interests, and who wish to protect their constituencies from criticisms or other actions, but the NTSB remains neutral and focused. Bravo NTSB…
1 - https://asq.org/quality-resources/root-cause-analysis
2 - https://www.aviationsuppliers.org/ASA/files/ccLibraryFiles/Filename/000000001743/ASA-100NCRSample-ShelfLifeIdentification.pdf
It has been 22 years since the ATA Spec 106 was updated, and it is now at revision 2023.1. The proper and full name of this document is ATA Specification 106, Sources & Approved Parts Qualification Guidelines (herein ‘the spec’). In this article the following will be presented:
COMMON MISCONCEPTIONS
INTERESTING FACTS ABOUT THE SPEC
And there you have it, the birth of the Non-Incident Statement
WHAT HAS CHANGED WITH THE FORM?
Section 3-1 paragraph D of the spec which refers to paragraph C:
Although the above paragraphs appear to have some minor issues with the cross references, the following can be reasonably concluded:
USE OF THE FORM TO COMPLY WITH THE ASA-100
Likely contributory to the mistaken perception that the ASA requires use of this form and/or that it is an ASA form, is that many accredited firms use it to comply with a section of the ASA-100 standard. Section 10 of the standard is titled: Certification and Release of Materials. Its paragraph B:
“B. Additionally, a certified statement disclosing the following should be issued about the material or parts, certifying that they were or were not:
1) subjected to conditions of extreme stress, heat or environment,
2) previously installed in a public aircraft, such as a government use aircraft or a military aircraft.”
To date, the form most used to express these statements is the ATA Spec 106.
CONTINUING ISSUES WITH THE 106 FORM
THE ASA STATEMENT FORM
For all the reasons cited above, the ASA’s QA Committee worked on developing the ASA Statement Form 2020. It brings into the 21st century the desired information and retains the one-page summary of the essential data needed to expedite the receiving process – BRAVO! Here’s the link to the form, training, and detailed instructions:
https://www.aviationsuppliers.org/asa-statement-form-2020
Most importantly:
It has been a long time since I’ve seen a customer’s PO specifically call for an ATA Spec 106 from their supplier. If your customer uses generic titles in their Terms & Conditions requiring your ‘C of C’, or ‘Material Certification’ then you are free to use the ASA Statement Form… make it happen!
This article was written without the use of any AI apps or programs.
Me at home: ‘Honey, where’s the ketchup, did you finish it?’
Wife: ‘It’s in the fridge’
Me: ‘I looked, it’s not there’
The sound of pounding footsteps on a mission are heard marching to the fridge, whereupon an impressive and commanding opening swing of the door is given, the wife’s hand swivels like a whip, tip towards the now mysteriously reappeared bottle of ketchup and voila, there it is. I bow and kiss her backhand then meekishly apply the condiment.
Occasionally solutions to our problems are right in front of us, and like ketchup on a burger, sometimes it’s advisable to add additional words to season our documents for the many reasons we’ll discuss.
What are one of the entries that all these forms have in common?
As you’ve likely deduced, these all have provisions for Remarks. From my experience this feature is one of the most underutilized blocks in any form.
Use of this block can prevent a customer from rejecting your part or be used to explain issues that might otherwise cause angst upon receipt. Let’s look at some real-world examples.
There was no problem with the customer and the Igniters were accepted.
The part was accepted with no problems.
By the way, I wrote an article on the importance of MRO Tear Down reports which I hope you’ll find interesting. Here’s the link:
https://www.aviationsuppliers.org/THE-VALUE-OF-TEAR-DOWN-REPORTS
Even though the fresh tag is now in Inspected status, under this simple example Royboy would support you marketing the part in New condition since the part still has zero Operating Time and Cycles, which is the de facto definition for New parts.
By the way, regarding the ‘silly’ requirement in my characterization, here’s another article I wrote directly challenging it:
https://www.aviationsuppliers.org/aftermarket-tags-overhauled-vs-repaired-vs-2-years
TO MANUFACTURERS AND MROS.
If your parts have shelf life, PLEASE put this information in the Remarks Block of your Airworthiness Release Certificate; some of you do and some of you don’t, and it may get overlooked on page 3 of your certs or Tear Down Report.
IN SUMMARY: Regardless of what form and ERP system you are using, these all have provisions for the addition of free text. Use it for Remarks!
This article was written without the use of AI assistance.