CAVU Café: Royboy’s Prose & Cons, Page 16 of 16![]() The views expressed in CAVU Café: Royboy’s Prose & Cons blog are those solely of the writer and are not necessarily shared by the Aviation Suppliers Association or the Association’s staff, members, or Board of Directors. About Roy Resto Reducing Component Turn Around Time, TAT: A Holistic ViewPosted By Roy Resto | July 21, 2011
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: 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.
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
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.
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 ’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… DROP SHIP PRECAUTIONSPosted By Roy Resto | May 27, 2011
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 CHRONIC OR ROGUE PARTSPosted By Roy Resto | May 10, 2011
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
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.
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:
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. EXEMPTIONS, WAIVERS, DEVIATIONS, AND AUTHORIZATIONSPosted By Roy Resto | April 18, 2011
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.” PARTS POOLINGPosted By Roy Resto | April 01, 2011
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:
If the concept works good for parts, what about other resources? The IATP also has pools of the following resources:
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 Stolen Aircraft Parts - By: Roy RestoPosted By Roy Resto | March 21, 2011
Welcome to the initial blog entry for CAVU Café: Royboy’s Prose & Cons. For those not familiar with the acronym, CAVU means Ceiling And Visibility Unlimited. It’s a term endeared in the hearts of aviators, and otherwise means great weather for flying. We hope you’ll enjoy the prose…unless you’re a con.
STOLEN AIRCRAFT PARTS By Roy Resto
“Pssst: hey bud, make ya a deal on a hot toilet seat… Don’t sit on this offer too long…we’re flush with inventory…”
You don’t have to search very hard to find news articles or press releases regarding stolen aircraft parts or whole aircraft. At the end of this blog is a short listing of links to such articles. If one believes that aircraft toilet seats cost $600, it becomes easy to understand why this commodity group continues to attract the attention of those involved in nefarious activities.
I became aware of this activity when I worked for a major airline. One of our aircraft had tragically crashed into a mountain side at night and in poor weather in a very remote area of jungle. By the time investigators reached, and were able to secure the area, it became evident that parts had been stolen from the sight. After a meticulous inventory, the airline was able to publish a list of parts reported stolen. I also experienced reports of mechanics showing me parts with stolen data plates, or evidence of attempts to pry-off data plates.
All attempts to ‘fence’ stolen aircraft parts will necessarily involve all types of fraud, laundering, and falsification of documents. This pattern did not escape the attention of the Suspected Unapproved Parts (SUPs) Steering committee. The charter of this committee was to work with the FAA’s then AVR-20 SUPs office, to jointly work on recommendations for solutions to known and developing unapproved parts issues. The committee was made up of representatives of trade associations (such as the Aviation Suppliers Association, ASA), Law Enforcement, Airlines, General Aviation, Distributors, Manufacturers, and Repair Stations. I’m proud to have served on the committee for over ten years. In the course of reviewing the circumstances of this activity, the committee observed:
All of this contributed to the conclusion that there was no way to ‘connect the dots’; how to answer the following:
Early on in the committee, I made the suggestion, that if a data base existed of such parts, the problem could be amplified, and resources brought to bear to minimize it. Admittedly, the idea was not a new one, in fact I know of two places that hosted such information. The problem here was a limited audience with one, and membership fees for the other. The challenge remained the creation of a credible, widely accessible, and widely known database. Early attempts to create such a new repository, although sincere, soon ran into the reality that the desired web site would require start up costs, a legal review, and on-going processing and maintenance. Because of this, those attempts dissolved.
The ASA however, continued to quietly entertain the idea of hosting it themselves, and discussions evolved at the Board of Director’s level supportive of the effort. This was aided in small part by the heralding of a Board member, yours truly. The potential of this data base to aid the aviation industry must not be underestimated. Its success as a deterrence to stolen aircraft/parts activity will rest with the degree to which the industry is apprised of its existence and participates in making data entries. The benefits of the data base will be:
The ASA will host the new database. For the ASA to engage this pro-bono effort speaks volumes of its commitment not only to its constituents, but to the aviation community in whole, since General Aviation, Commercial Aviation, and Military operators alike will all be able to participate and benefit from the data.
A very good introduction to the dark side of the aircraft parts business, is my blog on laundering of aircraft parts, soon to be posted.
By the way, I asked a salesperson friend to get pricing on toilet seats. The most expensive he found was $325.00 for New condition. For some reason none were available in Overhauled condition; they’re Expendable. What are the reasons for replacing a toilet seat? They break? Or perhaps wear? If so, there must be in-service dimensional checks to gauge wear, of course with a calibrated micrometer…nah….
Links to reports: http://www.oig.dot.gov/library-item/5018 http://www.oig.dot.gov/library-item/2917 http://www.oig.dot.gov/library-item/2950 http://www.oig.dot.gov/library-item/3298 http://www.oig.dot.gov/library-item/3653 http://www.nytimes.com/1997/05/08/nyregion/61-arrested-in-air-cargo-sting-near-kennedy.html |
