If you’re reading this, then this blog somehow made it through the institutional censors. Of course, everyone abhors the thoughts of “censors”, so these guys refer to themselves by the more palatable term “proof readers”. Professional proof readers call themselves Editors, and if you make a living writing, you’d better be careful to appeal to your target audience lest you find yourself edited out the door. OK, enough fun with this sarcasm.
Businessmen and academia are perpetually analyzing the differences between legacy carriers and low cost carriers, and the contribution of those differences to profitability or the lack thereof. Having worked in both airline and MRO operations, there is one practice I’ve observed that perfectly illustrates an example of the demarcation of legacy and low cost airlines; many legacy airlines continue to cling to the practice of requiring their MRO shops to use their airline-specific component maintenance manuals, whereas the low cost carriers tell their MRO shops to use the OEM’s Component Maintenance Manuals (CMM’s).
Airlines that have their own component maintenance manuals call these manuals by various titles which include: Engineering Orders, Engineering Specification Orders, Engineering Repair Authorizations, Central Engineering Manual, and Engineering Specifications. These manuals usually contain information that is specific to that airline such as repairs, inspections, modifications, or part numbers that are variations of the OEM’s CMM. These manuals typically evolve because of the airline’s effort at operational and product improvements, and employee suggestion programs.
Before we go any further down the path I’ve suggested with this blog, I’d better point out two things before someone starts wagging their index finger at me. We all know there are FARs requiring repair stations to perform their work in accordance with the operator’s manual when the operator specifies such manuals; understood and acknowledged, and yes it will be so accomplished. The other is that I have to speak in generalities, so I must acknowledge that there are variations in carrier size, legacy or low cost, as to the use of these manuals. Nonetheless, for the purpose of this blog, I’m sticking to the characterization of legacy and low cost carriers I made earlier.
Consider this quick, yet characteristic example:
- You’re a repair station, and as such are expected to pay for the OEM subscriptions for the manuals required by your capabilities list. You, the repair station pays for the subscriptions and internal distribution costs of the publications. Routine, right?
- On the other hand assume you’re an airline with those peculiar airline manuals. You, the airline are responsible to pay for the publication and distribution costs to your internal shops or MRO suppliers.
If you have hundreds or perhaps thousands of those manuals, just the administration of those manuals is likely an intricate process.
Is that it? Lets amplify this a bit.
For those hundreds or thousands of airline manuals, the airline will have to:
- Staff a publications department
- Keep careful and controlled lists of suppliers or internal shops authorized to receive them
- Keep careful and controlled lists of the revision status of the manuals
- The airline will have to pay for the distribution costs, whether on CD, DVD, PDF, hard copy, or internet access
- Since nearly every airline manual uses portions and parts of the OEM manual (if not entirely), then every time the OEM sends out a revision to their manual, it most of time will require a revision to the airline manual. So, dedicated staff have to receive all these OEM manuals (usually the publications department) and process them for revision approval.
- Who approves of these OEM derived revisions? Usually the respective engineering staff. So yes, you will have additional engineering staff
- If you want to add something, anything, to the manual, this too will require engineering staff resources to research and initiate the revision. For example, if you wanted to include a repair that the OEM manual does not contain.
- The Quality Auditors over your MRO suppliers will have to assure your manuals are being used.
- You will have to consider that since you are imposing additional requirements on your MRO provider, that the additional handling costs associated with your peculiar requirements will be passed on to you
- And this one is a BIG DEAL often not thought of, or conveniently overlooked: If you surplus your parts inventory for any reason (fleet downsizing, fleet retirement, STC’s etc.), you must consider that all the serviceability documents hanging on your parts say they’ve been processed in accordance with your manuals. In order for someone to buy these otherwise serviceable parts, they will have to send them to a repair station to be processed per the OEM manual, and to possibly de-modify the part back to its original configuration. This means that either your parts are less marketable, or that your parts will cost less, to cover the required repair station visit; perhaps both
Is the bureaucracy and additional costs of this arrangement coming into focus?
Predictably, if you desire to eliminate this system, its biggest defenders will be those whose turf is being threatened. They may even cite the “S” word (safety), and that the airline has enjoyed operational advantages because of this system. Oh really? I don’t seem to recall that legacy airlines using these systems have any advantage in safety statistics, dispatch reliability, unit costs, or on-time performance, over the Low Cost Carriers (LCC). Hmm...
Lastly, unquestionably, there are situations where the airline must issue maintenance instructions not contained in any other OEM manuals, and for these their choice of ‘airline manual’ (ESO’s, EO’s, etc.) must be issued.
Legacy airlines who are in or threatened by bankruptcy, or LCC’s, must make hard choices regarding operational changes that can potentially contribute to greater efficiency. This blog suggests that eliminating these burdensome and bureaucratic systems will make their operations more efficient, reduce their repair and overhaul costs, and make their surplus inventory more marketable.
I have an airline buddy who actively participated in his company’s suggestion program. He informed me that the idea presented in this blog was the frequent subject of many suggestors...to no avail. When employees from different quarters make the same suggestion, the light should come on, somewhere, so why weren’t these approved? The defenders were too entrenched and numerous; music to ears of LCC’s.
♫ “And the band played on...” ♫
(Lyric from the Temptation’s, Ball of Confusion)