CAVU Café: Royboy’s Prose & Cons, Page 16 of 17

We continue to hear reports that operators are bleeding cash, and that every aspect of spending is being reviewed. With this in mind, we’re seeing airlines open up to using PMA parts, parts traced to foreign airlines, and increasing use of aftermarket parts (AKA the ‘surplus’ market). With the proper controls in place, these practices save the operators considerable expense and lead time. And so it could be with two other sacred cows I’ll challenge: When buying aftermarket spares other than new, the condition demanded is Overhauled, and oh yes, that any tag must be less than two years old. Soapbox and microphone please!

OVERHAULED vs. REPAIRED or INSPECTED. I’m perplexed that so many purchasers continue to demand that parts, other than new, on the aftermarket must be in “Overhauled” (OH) condition. That’s for every part. Everyone knows that you will be charged more for OH condition than for Repaired or Inspected parts. When I question the practitioners of such requirements, the first answer I get is that “It’s our policy.” OK, what’s that policy based on? If the person wears glasses, they’re seen to slide the spectacles down to the tip of their nose, and lower their head; the better to give you direct eye contact while they give you the lecture you deserve. “Why, don’t you know (you silly boy) that Overhauled parts last longer on the airplane? This translates to requiring fewer spares.” And there it is, the reason for the policy. Here’s some thoughts to challenge that:

1. For the overwhelming majority (not all) of your parts, you will not be able to statistically prove
   that use of Overhauled parts vs. Repaired or Inspected last longer on the aircraft.
2. Most Component Maintenance Manuals (CMM) do not literally contain
   “overhaul” instructions.
3. Keep in mind that when you get a part with a serviceable tag from a repair station,
   an 8130-3 for example, the side that is signed says “Certifies that…was
   accomplished in accordance with Title 14, Code of Federal Regulations, Part 43
   and in respect to that work, the items are approved for return to service.” In other
   words, for either OH, Repaired, or Inspected parts, you are getting an airworthy
   product! Repaired or Inspected parts are no less airworthy than Overhauled parts.

Lets develop these a little. Item 1: Lets forget about statistics for a moment. First jot down a few parts you’d like to test and research. Start with your engineering department. Ask if any of the following address the parts you’ve chosen: MRB (Maintenance Review Board), MPD (Maintenance Planning Documents), and the MSG (Maintenance Steering Group) programs for your aircraft. A discussion of these programs is beyond the brevity of this blog, but your reliability engineer will assist. Suffice it to say that these programs form the basis for your Maintenance Operations. Do any of these address your components? Does it say anywhere that the part must be overhauled upon removal or replacement? There may be a few, but these are in the minority; it’s likely you will not find any such requirements for the majority of parts on your list. OK, lets assume you can’t substantiate the 100% Overhaul Policy through any of those documents. Talk to your reliability engineer and ask if there has been any past “history” forming the basis of the overhaul policy. If not, talk to the engineer and apprise them that you are switching your policy to accept Repaired or Inspected parts. The engineer will monitor the MTBF (Mean Time Between Failure) trends. If there is a correlation between MTBF negative trends and the use of Repaired and Inspected parts vs. Overhauled parts, then your policy would be vindicated. I’m here to prophesy to you that you’ll likely not see any such negative trends. Such data would form the statistical basis for your policy if it existed. If you don’t have it, why continue doing business the same expensive way? Read on please.

Item 2: Most Component Maintenance Manuals (CMM) do not literally contain “overhaul” instructions. If this is true how can repair stations accommodate your request to have parts overhauled? Lets look at an example. Lets assume you have a avionics computer of some sort. Its CMM does not contain any ‘overhaul’ instructions (just the typical inspection, check, and repair instructions), but you insist that it be in overhaul condition. They’ll be happy to accommodate you, and the expected higher fees they’ll charge, by following the FAA’s definition of ‘Overhaul’ found in FAR 43.2. It states that no person may describe a part as being overhauled unless “Using methods, techniques, and practices acceptable to the Administrator, it has been disassembled, cleaned, inspected, repaired as necessary, and reassembled; and it has been tested in accordance with…”. So, the CMM would not have required a disassembly and cleaning unless there was a failure of some sort, but because you insist on an Overhaul, they’ll do it anyway so as to meet the requirements of the FAA’s definition of Overhaul, and to be able to list its condition as such in block 12 of the 8130-3. Keep in mind this was a simplistic example, but it is quite realistic. One more thing, a subject for profound thought and fluttering of the eyebrows: there is a great body of folks in our industry whom believe that parts should not be disassembled unless specifically called for in a CMM because this act in itself greatly increases the risks that an error, bug, or mechanical deficiency could be introduced when reassembled; such is the reality when human factors are involved, so keep in mind that your insistence for fulfilling the requirement for an overhaul may introduce the very reliability problems you thought you’d avoid with the overhaul policy.

Item 3 speaks for itself.

I’d like to conclude the discussion on the OH requirement by addressing a veiled apprehension: You may be concerned about the parts you buy on the aftermarket, and thus have those concerns assuaged by having all the parts Overhauled. I may not be able to argue you out of that position, but I do suggest the following: Send it to the MRO of your choice, and ask them to inspect and repair the part as necessary. In addition, specifically ask for a hidden damage inspection on your Repair Order. They’ll look at it closer, and you’ll likely get charged less that a full overhaul. Cool idea huh? Oh, and one more thing (I feel the urge to pontificate): If you feel proud of the fact that you supposedly have a higher standard requiring the overhaul policy, I’m here to tell you that you’re selling yourself short. A higher standard than overhaul is the condition of “Rebuilt” (ref FAR 43.2). Yes this is an acceptable term for block 12 of an 8130-3. Your part will meet all the testing requirements of a new part with the exception that it did not just roll off the assembly line. Price that!

TWO YEAR TAGS: Another black and white policy that continues to make me shake my head in amazement is some operator’s policy that any parts purchased must have tags no older than two years. When I ask why, the glasses are seen to slide to the front of the nose again. “Don’t you know (you silly boy) that parts can deteriorate or degrade just sitting on the shelf?” Oh brother…, What are the historical arguments for this policy?

1. Concerns about deterioration of one sort or another
2. Concerns about SB’s, AD’s, or software changes that may have taken place while
   sitting on the shelf

Lets discuss these. Item 1: First, what ever happened to following manufacturer’s recommendations for shelf life as may be contained in a CMM if applicable? Typically, if there is a shelf or storage life, the CMM will contain it in its Storage section, or equivalent, of the manual. If it does not exist, why pay for the additional expense of having it sent back to a shop for a fresh tag? Alternatively, this is only defensible if you have supporting statistical or reliability issues as previously discussed. Do you?

Item 2: Questions about SB’s, AD’s, or software changes that may have taken place while on the shelf represent the best concerns for the 2 year tag defense.

Let’s not overlook the obvious, however: if this is indeed your concern, those issues could have manifested themselves in the two year time frame for the parts you’d accept with tags less than two years, right? So how do you currently address that possibility? The person is seen to retract the glasses to its proper position on the nose bridge. A probable response is that you know the product you are assigned to purchase, and thus would likely know about AD, SB, or software issues. Your Purchase Order (PO) should always include special instructions to your supplier that you require the part delivered with SB’s, AD’s or software installations accomplished when applicable. After all, there are many SB’s, AD’s and Software installations whose implementation method and requirements depends on the operator. Finally, we are fortunate that many SB’s, AD’s, and Software installations change the part number, so if you get the part number you’ve ordered you’ve likely got the AD, SB, or software level required. If still worried, put the required level on the PO.

Roger, Over ‘n out.

Reducing Turn Around Time (TAT) seems to be on a perpetual hit list among writers of journals, case studies, and contracts. Indeed, what a nobler topic to champion? Speedier TAT’s result in greater availability of the asset being turned around. For aircraft this means more Revenue Kilometer Miles; for engines and components, greater availability of spares, or a reduction in spares inventory- music to the ears of CFO’s. What irks me however, and compels me to pen this blog, is that most of what has been written seems to exhibit a myopic focus on a single contributor to TAT: the supplier, and further, to lack frank honesty and comprehensiveness. If the goal is greater availability of the asset, the enlightened discussion must transcend this single contributor. In this blog I hope to present a frank picture of the entire Rotable TAT Cycle logistics chain; the holistic view.

Many contracts with MRO providers will contain a TAT performance provision. These contracts likely define what TAT means, when the TAT ‘clock’ starts and stops, and the penalties for the lowly supplier not meeting the stated TAT’s. Let’s broaden our scope. Every operator, including Airlines, the Military, and General Aviation (collectively ‘operator’) has their system to control the logistics aspect of the operation deemed necessary to support the maintenance of the fleet. This system typically controls the allocation of the stations with the spares, the number of spares, minimum stocking levels, parts in the ‘pipeline’ etc. The holistic discussion of the Rotable TAT Cycle falls into four distinct divisions:

• Time at the operator during the removal process
• Freight time to and from the supplier
• Time at the supplier
• Time at the operator while being returned to stock

TIME AT THE OPERATOR DURING THE REMOVAL PROCESS: CREATING THE ‘HOLE’

Let’s put the hole in holistic. When should the whole TAT clock start? That is the fundamental segway into this holistic discussion. Simplistically, it starts at the operator. A Mechanic/Technician/Engineer (herein Technician) will draw the part from stock. At that point a ‘hole’ is recognized by the operator’s logistic system; that a spare is no longer available. Thumb on stopwatch please.

• For the sake of simplicity we are starting the stopwatch at the moment the part is drawn from stock. In fact there are many instances where the knowledge of the requirement to draw from stock was known well ahead of the moment of the draw. For example, let’s follow the rotable cycle of a cockpit window. During a maintenance check inspection, the cockpit window is written up for excessive crazing. It is known that the window will have to be replaced. How long did it take between this known condition, and the time the part was ordered and drawn from stock? If the part was not in stock, how long did it take for the backorder to be placed? Since there are so many variables in answering those questions, the answer is likely not easily quantifiable as an average, but the point is made that there is likely room for improvement as may be identified by Lean and Industrial Engineers. 
  
• So then, we are back to the window being drawn from stock, the clock ticking, and the ‘hole’ created in the logistics system  which now recognizes one less spare. Note the part requiring maintenance is still on the aircraft. A review of the AMM (Aircraft Maintenance Manual) reveals that several Avionics control panels will have to be removed to facilitate this maintenance, so there will a delay in the removal and installation of the cockpit window. The big-picture guys in Maintenance Control start to get nervous about this and other open maintenance jobs bumping up against the scheduled return to service tim for this aircraft. The installation and ‘signing off’ of this job now becomes the high priority for the Technician. The crazed window was removed and set aside while the serviceable window was installed and the paperwork completed to close the task and appease the honchos in Maintenance Control. It is not unusual that when crunch time comes for the return of the aircraft, and there are many open maintenance write-ups, technicians may get rapidly re-assigned to another task, and the turning-in of our unserviceable crazed window became a low priority, after all, getting the plane out on time is always the number one goal. Alternatively it may have been the end of his shift, and the Technician simply waits to turn-in the window until the next day, or ask a colleague on the other shift to turn it in. This action is not as easy as walking over to the stock room and giving it to them; paperwork must be accurately completed by the technician to accompany the window.
  
• The unserviceable window finally gets turned in to supply/stores. Now what? If it was the only part requiring processing, it is likely it would receive immediate attention, but during an aircraft maintenance check it is routinely one of many turn-ins during this shift, and the current priority of supply employees are to issue parts required to close out those other open write-ups. Finally, the supply employee starts to process the turn-ins. Originally, the serviceable issued window was given to the technician in its storage box made of foam-in-place protection. The Technician had to tear apart the box to get to the window. This rendered the box unusable, and the unserviceable window turned in without a box, so the supply person hopes to find an unused ATA Spec 300 package for our window. None found for our odd shaped window. A fresh foam-in-place box takes shape, or the part waits for the crating shop to make a properly protective shipping crate. Now the paperwork can commence to ship the part to the supplier. Paperwork and packaging now complete, the part is placed in a designated freight pick up area.
  
• Let’s summarize this segment of the Rotable TAT Cycle at the operator, and those areas we could measure for possible improvements.

                   o  How long did it take between the time the inspection’s write-up was created (which identified that the part needed 

                       replacement), and when the unserviceable part was removed?

                   o  If the part was not in stock, how long did it take between the time the inspection’s write-up was created (which 

                       identified that the part needed replacement), and when the backorder was created?

                   o  How long did it take for the part to issue once ordered? Did it have to be delivered from another warehouse or

                       location; a pick ticket issued and closed, the computer transactions, etc.?

                   o  How long did it take between the time the unserviceable part was removed at the aircraft, and then properly turned in

                       to supply?

                   o  What was the elapsed time since supply took-in the unserviceable part until it was placed for pickup?

FREIGHT TIME TO AND FROM THE SUPPLIER:

One time a colleague misspelled freight as fright, and of course it was not corrected by spellcheck. He became the person credited as putting the fright in freight. And indeed, fright is a component of freight, primarily due to its costs. Costs and delivery times vary widely from Sterling service to ground delivery. Let’s look at some of the variables

• Sometimes either the supplier or the operator will enjoy the upper hand in discounted freight costs. COMAT (the operator’s owned delivery assets such as its aircraft and counter-to-counter service) may also influence the picture. Either the supplier or operator may thus be tasked with the freight burden. 
  
• Historically, if the operator was responsible for freight, the days in transit to and from the supplier have not been used in calculating TAT. If however, the supplier was responsible, this transit time was included in traditional TAT calculations.  Hmmm. The holistic view must account for this time regardless.

TIME AT THE SUPPLIER:

As mentioned earlier, this segment of the rotable TAT cycle is nearly universally the single topic of discussion in published literature, so I’ll only dwell on a few of the more interesting variables.

• Suppliers with robust quality systems such as AS/EN or ISO standards usually have a myriad of internal performance measurements which will include TAT. When does their own clock start? Routinely, it starts when the work or repair order is opened. They may also apply this start of the clock to the customer’s TAT. What if the supplier is behind? What if the supplier’s manager decides to ‘park’ the just-delivered window for a couple of days before opening the repair order to relieve shop pressure? Hmmm….
  
• Some types of work at the supplier will require that the part be inspected, and a quote of the estimated costs submitted to the operator before work can commence. During the time the quote is submitted and approved, operators conveniently allow or require that the TAT clock be suspended. You would be surprised at the number of operators that harp on TAT, yet take seemingly extraordinary time in responding to the required quotes they have imposed.
  
• There are some instances where the spare parts used to repair or overhaul the rotable are provisioned or ordered by the operator. An efficiency study of this type of arrangement, and its contribution to TAT would be revealing.

TIME AT THE OPERATOR WHILE BEING RETURNED TO STOCK: FILLING THE HOLE

The delivery truck roll-up door opens and the boxed, now serviceable window is unloaded. Is that it? Is the hole now filled? Not so fast. Let’s look at some of the variables.

• The part is now put on the proverbial conveyer belt to be received. This may involve the time taken to fill out and attach the operator’s own serviceable tag
• Some operators will require a more thorough inspection of the part before being placed into stock. The part may go to a ‘home shop’ or QC area for the inspection. How much time will that take?
• Some operators will only receive parts at a centralized location. The hole may not exist at that location. This will require an additional shipment to the location with the need. This too was not likely to be on anyone’s stopwatch.

THE ’WHOLE’ IN HOLISTIC

Any research literature or informative article on TAT that does not reflect this holistic view does its audience a disservice, and helps perpetuate the view that the sole contributor in the Rotable TAT Cycle is the supplier (Industrial Engineers are heard to be clapping in the background). The bottom line is that in the Rotable Cycle, there is room for improvement at every level, and only by a frank and open discussion can improvements be made.

PS: I looked up “holistic” in the dictionary before I started to use it, and discovered there is nothing ‘Holy’ about it. Shouldn’t it be ‘wholistic’? Alas, my major was not in English…

A reader of my blogs once called me to ask my opinion of the practice of drop shipping; this because she wanted to draft some procedures for her Quality Manual and staff.

We need to initially distinguish the difference between ‘drop ship’ vs. ‘direct ship’, which many seem to confuse or use interchangeably. ‘Drop ship’ is a commercial term we use to describe that a part is being shipped from your supplier straight to your customer; it is not gong to be physically received at your facility. ‘Direct ship’ is used to describe that the manufacturer is not a Production Approval Holder (PAH), but the actual PAH is authorizing the non-PAH manufacturer to ship it anyway, usually by the written instrumentality of what’s commonly called a DSA, or Direct Ship Authorization. In this blog I’ll be discussing drop ships exclusively.

First, there's no formal guidance, regulations or established protocol regarding procedures for drop shipping. With that established, here's some good "Royboy" guidance.

I always try to discourage the practice of drop shipping because your customer is going to receive the part directly from your supplier, who may be a competing company. It's likely that your supplier will, as you likely do, put their company stickers on the boxes, have their logos posted prominently on paperwork, and occasionally they may mistakenly list the price they've charged you on that paperwork, which exposes you to the embarrassment of possibly explaining why you've added so much margin to the price you invoiced. All these may temp your customer to place the order with your supplier next time, instead of with you, unless of course the customer has credit problems with your supplier (a sarcastic, knowing smile should have alighted upon your face at that last comment). Regardless, the biggest reason not to drop ship parts is that your inspectors have not physically inspected the parts. Perhaps your own reject log witnesses to all the parts rejected for condition. There are other detractors from this practice, as I'm sure you'll agree. Despite these, you likely have to drop ship parts with some regularity. When doing that, here's what I suggest:

NEVER drop ship parts unless you've first examined the Serviceability and Trace documents via fax or email to assure it meets your standards and that of your customer's PO.

ALWAYS put in a disclaimer somewhere on your own shipping documents that clearly states something like: "NOTE: This part has been drop shipped to your facility at your urging. As such, (enter your company’s name) Inspectors have not physically inspected these parts." A great place to post this disclaimer is on your material cert. Perhaps a simple rubber stamp will suffice, or custom pull-down statements in your system could place the language on the paperwork. This type of disclaimer should mitigate any problems for you that may arise if your customer rejects the part due to their own physical inspection.

Be careful out there

A characteristic of human expression which seems to be on the wane is that of passion. You’ll know when a person is passionate about a topic of discussion when: the blood vessels in the neck are seen to bulge, the hand motionsbecome more expressive, and the tone of their voice changes to that level characterized as “don’t dare to interrupt me during my discourse or I’ll wag my finger at you.” That such impassioned expression is on the wane is a casual observation on my behalf, but if true, why? Two guesses would be that 1) We have become fixated on being politically correct and universally un-offensive, and 2) We have become shy and timid; afraid of rejection by counterpoint and what will be thought of us in the process. If you have ever had the opportunity to be involved in addressing issues of chronic or rogue parts for your company, you likely experienced at least lively conversation, if not downright impassioned exchanges.

There are certain parts or components that manifest the same recurring problems or writeups over and over again within a certain period. Such parts or are said to be exhibiting ‘chronic’ or ‘rogue’ histories. Maintenance folks have often called these offenders ‘Hangar Queens’ due to their frequent visits to the shop.

TYPICAL PATTERN

The typical pattern is that initially the shop will return the part to service with a ‘Could not duplicate’, or ‘No trouble found’, or that corrective actions did not eliminate the pesky, recurring writeup. This may occur a few times before the part is declared ‘chronic’ or ‘rogue.’ A simplistic definition for these parts is that they pass all the required Maintenance Manual tests and inspections, but do not last on the aircraft. Most shops or airlines establish a baseline, rule of thumb to make the determination that a part is chronic or rogue; for example, if a certain serial number part exhibits 3 removals in a six month period. These baselines vary widely depending on the family of parts, ATA chapter, and/or the airline or shop policy.

REALITY CHECK

I’ve had the sad experience to hear some end users of these parts express some pretty inflammatory remarks regarding the practices of the maintenance folks who repair these parts. This is sad because this uninformed view does not accommodate the reality that these parts will, and do exist, but until they are identified, the maintainers are doing everything according to the approved data and their training. In fact the maintainers take great pride in their art, and are the first to self-inflict umbrage when they learn that previous attempts to repair a part have failed. The real work and test of the maintainers starts after the part has been identified as chronic or rogue. Myopic critics abound too, on the side of the shops who must fix these units, about the operator’s methods. The uniformed critic needs to ask two questions: What causes this phenomenon, and what is typically done to address it?

CAUSES

The causes of chronic or rogue parts generally fall into these categories

• Variation: Variation in the manufacturing process: Anyone who has studied statistics in manufacturing will be familiar with the term “Variation.” The Holy Grail in manufacturing is to eliminate such variation in the product. Manufacturers with Six-Sigma processes for example, are said to exhibit the least variation in the product. Regardless, variation exists in any process, and that variation may exhibit itself in a particular serial number that will eventually end up on someone’s chronic list. To be totally honest in this tech log, I’d have to acknowledge that variation exists in the maintenance process as well. A manufacturer may have produced a flawless part, but later during maintenance, a technician may have accomplished a poor solder joint repair or improperly crimped a wire for example. These could lead to intermittent failures.
• Intermittent Failures: This is the bane of maintainers. These faults seemingly manifest themselves randomly, and of course, rarely in the shop. There are many causes which may include the following: Variation in the manufacturing or maintenance process as previously discussed; undetected wear; corrosion; abuse such as being dropped or mishandled; ESD damage; severe events such as lightning strikes, hard landings, landing gear collapse, or collisions with ground vehicles; coffee, water, lavatory leaks or other spills; failure of other parts in the system such as an over-voltage condition, etc.
• Software: This is quite specialized, but it does happen. Many parts are controlled by software and interact with other systems similarly controlled by software. Such software is routinely updated, and occasionally the new software causes the system to act in unforeseen ways. This naturally causes the pilots to writeup the system, and the aircraft technicians to take corrective, remove-and-replace actions; of course the shops can find nothing wrong with the units. It may be months before the operator or manufacturer correlates the failures with the new software, and in the meantime, the rogue list has grown significantly.
• False indicators: Sometimes the problem does not lie with the part, but with the airplane. Do rogue or chronic problems exist on the aircraft side? Of course they do, you silly wabbit. I’ve seen some problems on aircraft that defy troubleshooting logic and whose final fix may not occur until months later. In the mean time multiple removals of the same part may have occurred, and the repair shop is being asked what are they doing about the spikes in removals or chronic lists?

FIXING CHRONIC OR ROGUE PARTS

Remember that these parts all pass the tests required by the maintenance manuals, and I’ve never met a manual that had a troubleshooting section that addressed all problems. Fixing it will require a mixture of experience, logic, the process of elimination, and sometimes just plain old dumb luck. For those with experience in the area, the process starts with coming up with a written plan. Here’s a sampling of some common techniques that may be used in the plan.

• Check all the available data for correlation. For example: Are the parts coming from a single aircraft tail number; was there an event such as a new Service Bulletin or software revision that coincided with the rise in removals; is there a particular phase of flight that the problem manifests (cruise, landing or takeoff); was there any maintenance event that occurred in the history of the unit that seemed to usher in the rise of removals (such as a repair or replacement of anything); etc.
• Shake and bake: Subjecting the part to environmental extremes is commonly called ‘shake and bake’. This may involve putting the part into a freezer and then testing the part, putting the part in an oven then testing, and/or inducing a vibration during testing to see if anything fails. In fact this whole process can get quite sophisticated when you try to replicate the hot, cold, pressurized/unpressurized, or vibration environment that the particular part operates in.
• Under the magnifying glass: This means examining the suspected part under a microscope or magnification of some strength to look for flaws that may not otherwise be detected with the naked eye.
• Swapping parts: With the operator’s or airline’s permission, this involves swapping a subassembly from one unit into another and seeing if the problem follows. If the chronic unit comes back again, at least you’ve eliminated that subassembly from the list of possibilities, and the list narrows.
• Replace suspected parts: Although the shop doesn’t see hard failures, you can at least make a logical, educated estimate that the problem comes from a certain area in the unit, and simply replace a few parts. Some call this ‘shotgunning’, but sometimes it really works. This can get expensive, however, particularly if it does not yield immediate results.
• Flight testing: After a major effort to fix the problem, it may be possible to put the part on a flight test or operational aircraft accompanied typically by an engineer on the flight deck. If the part fails again, at least the engineer can gather more information as to the operational profile and crew procedures in affect at the time of failure; valuable insight.
• Shoot the horse for crying out loud! There comes a time in the life of a chronic or rogue unit where the combination of operational delays or cancellations, parts replaced, and labor costs reach a point where you could have purchased a new or aftermarket replacement part. Of course this means removing the rogue from service. This is difficult sometimes, because maintainers hate to give into a challenging problem. Management simply has to make this call, and in fact it may turn out to be the most cost effective solution.

WHAT SHOULD YOU DO WITH ROGUE PARTS THAT YOU’VE DECIDED TO REMOVE FROM SERVICE?

The obvious answer is to scrap the part. There are some in our industry however, that may try to salvage any value from the part, and recoup their losses by selling it on the aftermarket. This is unethical, and depending on the part, unsafe. The most unscrupulous of these persons would send the part to an unwitting repair station with the knowledge that the part is going to pass the routine tests. Now with a fresh 8130-3, the part is on its way to the aftermarket to start a new life with a new operator as a chronic unit. Fortunately, these types of persons who engage this activity are in a very small majority.

CAN’T WE ALL JUST GET ALONG?

Before I get off this soapbox and turn in my laser-pointer and lapel mike, a few words: As I alluded to earlier, as regards chronic or rogue parts, tempers can flare on both sides of the Operator-Shop relationship. Allegations of poor quality at the Shop, or poor troubleshooting at the operator’s aircraft abound in this arena. Exacerbating this is when the operator is experiencing operational delays or cancellations (a source of passionate [there’s that word again] debate at any operator), or making warranty demands on the shop for the rogue’s performance, and it may not be the shop’s fault! My humble wisdom:

• Operator: First acknowledge that occasionally you’ll own a part that becomes a rogue or chronic unit. Don’t be so fixated on turn-times, warranty claims, or allegations of poor quality that you actually dis-incentivize the shop from doing a proper job in addressing the rogue.
• Shop: Don’t get in the habit of writing off all those ‘no trouble found’ responses to the operator’s perceived lack of troubleshooting skills at their aircraft. If you see a chronic part developing, don’t be so fixated on turntime goals that you don’t accomplish a proper job of addressing the problem.
• Both: To the degree that most operators really want to encourage an atmosphere where their vendors are partners and team members, the environment should be characterized by a lack of fear to express problems, and for both parties to put aside the emotions and roll up their sleeves to fix the problem. Fortunately, most of you are just such players.

There are all kinds of deeper, more profound information regarding this subject, but this is just a primer on the issue.

By the way, it is my opinion that one of the characteristics of a true leader is that they unapologetically express certain issues with passion. Yes that can get you into trouble too, but hey, another leadership marker is the willingness to take measured risks…

Over ‘n out.

The famous General Douglas MacArthur is quoted as saying “Rules are mostly made to be broken and are too often for the lazy to hide behind”. At first I was surprised that this quote was attributed to a ranking member of the military known for strict adherence to rules and regulations, but on closer examination he was referring to the prosecution of battle plans, and I doubt he would tolerate the wear of an unkempt uniform out of regulations. In aviation we generally observe that the rules and regulations are black and white and to be followed, but from your particular vantage point a certain rule or regulation may seem like a square peg in a round hole. General MacArthur, when questioned about the apparent withdrawal of his troops, famously replied regarding his vantage: “We are not retreating. We are advancing in another direction”. And so it is with an exemption; it is not a retreat, but an advance in another direction.

To illustrate the exemption process lets use an example. Suppose you are a repair station with an airframe rating and your primary business is installing and maintaining In-Flight Entertainment systems, IFE. FAR 145.103 (b) says that “A certificated repair station with an airframe rating must provide suitable permanent housing to enclose the largest type and model of aircraft listed on its operations specifications.” Typically this means having a hangar. A customer requires that you perform a modification which is a maintenance action. The mod is pretty minor in terms of complexity, can be performed overnight, inside the aircraft, and at the customer’s line station gate as they have requested. Do you still need that hangar?

Looking at the work, the answer is no; looking at the FAR the answer is yes. A possible remedy would be to explore a request for an exemption. You will have to petition the FAA. According to FAR 11.17, “A petition for exemption is a request to FAA by an individual or entity asking for relief from the requirements of a current regulation.”

Critical to your petition would be your ability to demonstrate “The reasons why granting the exemption would not adversely affect safety, or how the exemption would provide a level of safety at least equal to that provided by the rule from which you seek exemption”. To familiarize yourself with the process, first read the applicable portions of FAR 11; it will be a quick read. Second, go to this FAA web site for the step by step procedure:

http://www.faa.gov/regulations_policies/rulemaking/petition/

Also be aware that if granting your petition would set a precedent, the FAA will most likely publish it for public comment in the Federal Register.

There are some circumstances where the situation for which you seek relief does not fit the intention of the exemption process. It may be that a possible remedy can be found in a waiver, deviation, or authorization. An example is an aircraft grounded for a maintenance issue at a location where there are no suitable maintenance resources. Petitioning for an exemption to the FAR’s regarding airworthiness in order to be able to ferry the aircraft to a maintenance base would not fit the intention of the exemption process. If it is found that the aircraft was nonetheless capable of safe flight, in this case requesting a Special Flight Permit would be the appropriate remedy. This is an example of an authorization issued for this one-time.

In my research I discovered that the FAA has at this date 15,210 records in its exemptions database, so there is considerable activity. Note that in this same database there are 3,624 records of petitions whose disposition is listed as “Denied”. There are many good reasons for denials beyond the brevity of this blog, but the conclusion is that in order to seek relief from the rules or regulations, you will have to follow the rules and regulations for such relief.

My humble counsel is to exhaust all reasonable means to meet a rule or regulation. If that will not work, consider the aforementioned. Fortunately, our industry is comprised of regulators and operators with sound procedures and a passion for safety, unlike sports according to George Orwell:

“Serious sport has nothing to do with fair play. It is bound up with hatred, jealousy, boastfulness, disregard of all rules and sadistic pleasure in witnessing violence. In other words, it is war minus the shooting.”

Be safe, play by the rules, will ya?

Is it possible to have too much of something? It seems kids never have enough toys; IT managers never have enough software, hardware or gadgets; Mechanics – tools; or pets - food. The list of seemingly insatiable objects is historical, and most, if not controlled, will get you in some kind of trouble. And so it is with inventories of aircraft parts.

Consider this: Worldwide the Jetliner fleet is comprised of about 17,200 aircraft. It is estimated that the global parts and components inventory to support that fleet is worth $44 billion. That’s $2.6 million per aircraft! Airlines hold about $1.6 million per aircraft with the balance held by OEM’s and suppliers. What this equates to is that “…airlines and operators have compiled around eight times the value of the inventory they actually need to support their fleets, simply because of difficult to resolve inefficiencies within the industry infracture.”¹ While there are many issues contributing to those inefficiencies, a continually evolving and improving concept is of sharing pooled parts among different operators.

In the days of regulation, when code-sharing and airline alliances were just ideas, everyone was conceivably a competitor. The idea of sharing parts with a possible competitor did not sit well in many board rooms. Having large inventories of parts was ingrained as a way to be operationally independent, and to reduce delays and cancellations. In today’s financially challenged environment, great pressures are being exerted to reduce inventories, and so the parts pooling concept is growing in popularity.

As early as 1948, a few European airlines met and started sharing parts and resources. An organization was needed to facilitate the process. Today that organization is the International Airline Technical Pool (IATP). It now has 111 airline members that share 9,088 parts valued at over $265 Million.² IATP, a nonprofit group, provides the structure, procedures, contacts, and administrative capability needed to make it work.

The parts pools are divided into 6 pools by letter groups:

• K: 707, 727, 737
• M: 747
• P: DC-9 and MD-80 series
• Q: All Airbus models, DC-10, MD-11
• S: 757, 767
• T: 777

If the concept works good for parts, what about other resources? The IATP also has pools of the following resources:

• Line Maintenance
• Maintenance up to and including ‘A’ checks
• Ground Handling Equipment and tools
• Access to 11 strategically placed Aircraft recovery kits (Kits that contain tools and equipment to help recover planes with collapsed landing gear, planes stuck in the mud or which have run off the runway/taxiway)

Here is a scenario that illustrates how the system would work for a typical airline. Suppose your airline is starting daily 777 service from your country to JFK. You would have to stock JFK with spares, trained line maintenance crews, tow bars, jacks, and ground support equipment. By joining IATP the airline can avoid having to make those capital investments at that location for just that one daily flight. The airline would pay a one-time entrance fee of $50,000, a membership fee of $1500 per season, and a $474 pool group (group T) fee per season. An example of the savings is the airline would have access to an Integrated Drive Generator for only $27,000 per year compared to the purchase price of an IDG at $450,000.

IATP itself does not perform any of the services; it just acts as a non-profit facilitator of the process. The services are performed by about 29 associate members of IATP who provide the parts, warehousing, maintenance, training, and ground handling. The majority of these associate members are not airlines, and all numbers cited change with some regularity.

Finally, the process to participate in IATP is not as easy as merely paying fees. In many countries the airline is required to gain approval from their Civil Aviation Authorities. These CAA’s are primarily concerned that the airline have published internal procedures to adequately control the process, and oh yes, the IATP will be in contact to judge the adequacy thereof, as well.

Overall, it’s a pretty neat system.

Gotta have more coffee, more coffee, more, more, more…

¹ “Pooling Pays”, Aviation Week & Space Technology, page 38, October 12, 2009

² “Pooling Together”, MRO Management, page 46, September 2009