I’d like to add a new choice of terms to our ever evolving aviation lexicon. When an aircraft reaches the end of its life and it’s being parted out, we’re not removing the parts- we’re harvesting the parts from the legacy asset.

A word that has managed to survive the trendy, revisionist makeovers is ‘cannibalize’, as in cannibalizing aircraft parts. Used interchangeably is the equally, potentially offensive word, ‘robbed’ aircraft parts. My, oh my, I want to retreat to a safe place and curl into a fetal position at the use of such utterances. We certainly need kinder-gentler expressions! But guess what? They’re here to stay. Get over it.

So…what are we talking about? A likely scenario:

An aircraft is at the gate for the first flight of the day and passengers are loading. By the way, at any given airline, the bank of first flights is closely monitored in real time by many different organizations, and the percentage of flights making it out of the chocks on time is a key performance metric; this, since any delay or cancellation is going to have a cascading effect on the subsequent flights of the day. For the first flight of the day, the flight crew has to perform lengthier aircraft systems checks, and during these checks our air crew observes a fail during a bite test (Built-In-Test-Equipment). The air crew consults its MEL (Minimum Equipment List) and confirms the failure can’t be deferred; it must be fixed. The aircrew calls its Maintenance Operations Control center (MOC), who dispatches technicians to the aircraft. The techs note that the Fault Isolation Manual (FIM) requires the replacement of an LRU (Line Replaceable Unit). The problem is there is zero stock; and the parts-pooling partners are similarly zero stock; drats! These savvy technicians know however, that an identical aircraft is parked on the ramp awaiting lengthy repairs due to a bird strike. The techs call MOC for authorization to take the part off the idle asset, and use it on the now-waiting aircraft full of passengers. Twenty minute later the techs are on the flight deck signing off the offending write-up with the aircrew, and minutes later the tug spews its first puff of smoke as the aircraft backs out of the gate. In many an airline’s GMM or GPM (General Maintenance Manual or General Procedures Manual; in the USAF the equivalent is Air Force Instruction 21-101, Aircraft and Equipment Maintenance Management), this procedure is referred to as cannibalizing or robbing the part. To be sure, there are probably, other more kinder-and-gentler titles of the procedure, but these are the prevalent ones.

In the USAF, the same action is also called cannibalizing, and only certain Maintenance Management persons are certified to authorize such an action on the scene. I had this certification. Without doubt, cannibalizing or robbing must always be an option of last resort; all efforts must be expended to locate the part first from normal supply channels. It is no surprise then, that cannibalization rates in the airlines or military are a closely monitored metric since it reflects on the effectiveness of the inventory control system. Higher cannibalization rates tend to be accepted through clenched teeth for parts that are out of production. Higher rates may also be the natural consequence of operators who deliberately choose to be under-spared for certain assets to conserve cash.

Up to this point, the process to rob that part sounds easy…but it’s not. Consider the following:

• Before the part is robbed (yes I switched to using this other term, from cannibalizing, since it’s easier to type), you must establish that the aircraft being robbed from has no existing write-ups against the system you intend to rob the part from. This is routinely accomplished by exam of the aircraft log book or equivalent electronic listing. In many cases you’re looking for the associated ATA chapter system. The idea here is that if the ATA system you intend to rob the part from has no write-ups, you can reasonably conclude the part remains in airworthy serviceable as installed.
• The logbook entries in both the aircraft involved must be made precisely and in accordance with the written procedures.
• In many cases, the part was initially ordered against the original aircraft with the write-up before the discovery of zero-inventory was confirmed. Since the part has now been robbed to fill the need, procedures must include that the part-order be amended to show that the aircraft robbed-from is now in need of it.
• Many procedures I’ve seen require that as soon as the part is removed from the robbed-from aircraft, a tag must be affixed. Often it is this tag that facilitates the corrections to inventory orders previously discussed.
• There are two special cases for close attention when considering robbing a part:

           o Is it a part that has scheduled overhaul or other maintenance requirements? If so, the airline’s tracking system must be amended to show the current                    installed-position of the part.

           o Is the part an LLP, Life Limited Part? My experience is that these parts are rarely robbed since nearly all require extensive disassembly in order to                          facilitate the removal and installation. Nonetheless, it remains a possibility and must be carefully considered for remaining time or cycles and to be                        tracked as concerns its current installed position.

How about swapping?

Swapping exists for one reason: To facilitate the troubleshooting process. For example, an aircraft has a write-up, but experience has shown that several LRUs (Line Replaceable Units) are equally capable of causing the fault. Any experienced technician will tell you that there has never been written a perfect Troubleshooting Logic Tree or FIM. Swapping parts that are the same part number to see if the fault is eliminated, or follows to the other swapped position, is really a great troubleshooting tool to confirm the source of the fault. This also helps reduce those pesky No-Fault-Found (NFF) charges. There are two scenarios for swapping:

     1. Swapping in the same aircraft tail number:

         Due to redundant aircraft systems, it is not unusual to find the same part number LRU installed for a Right or Left system, or in some cases a left, center,               and right system, or system 1, 2, 3, or colored systems. It’s been my experience that technicians often perform this type of troubleshooting without the                 necessity of informing anyone or filling out any tags or other documentation. The conscientious technician always will return the parts to their original                   positions once the troubleshooting process has concluded. In some cases the airline may have a hard rule that any such activity is strictly documented                   in accordance with their manuals, and for good reasons.

     2. Swapping between aircraft of different tail numbers.

         In some cases, this is the preferred or only option for swapping during troubleshooting. In this circumstance there are usually strict controls on                             documenting the actions taken.

If you know of any kinder-gentler, mood-ameliorating terms in use to describe these actions don’t hesitate to post a comment.

Over ‘n out

Roy “Royboy” Resto

www.AimSolutionsConsulting.com

Many of you buy and sell avionics parts and/or have Repair Stations/Approved Maintenance Organisations. As such I’d like to share with you the options that exist globally regarding the credentials which avionics technicians may bring to your attention during the hiring process, including the relatively new NCATT (National Center for Aircraft Technician Training) Certification.

Before starting, since this article is addressing a global topic, we need to point out that generally, the terms Technician, Mechanic, and Engineer will all mean the same thing; their use varies geographically.

BACKGROUND

As with any evolving field of interest, when advancements produce increased levels of complexity, an expected progression would be new fields of expertise, and so it has been for avionics (Aviation Electronics). During and after WW II, aircraft electronic systems became increasingly complex, particularly in the fields of communication and navigation. Technicians who demonstrated talents in these systems were singled out for their aptitude. Despite this recognition, certifications for aircraft maintenance technicians remained stubbornly centered around airframe and powerplant qualifications, with avionics training coming under the airframe category. So, where are we today with certification for avionics technicians? Currently the dominant patterns for maintenance technician certification are the ICAO, EASA, and FAA models.

ICAO

In past articles I’ve shared my hope that in the future the world would go to a single set of globally recognized and accepted aviation regulations. This desire stems from the dizzying number of duplicative certifications a company might require doing business globally. When this happens, it is likely that ICAO will be the organisation which establishes the standards everyone follows. This is likely because ICAO is not anchored to any nation-state, and therefor does not carry any political or geographic ‘baggage’ which might otherwise arouse the sensitivities of any nations. So, who is ICAO?

The International Civil Aviation Organisation (ICAO) is a specialized agency of the United Nations and is funded and directed by 193 national governments to support their diplomacy and cooperation in air transport. ICAO is always quick to point out that they are not a global regulator but that “The stipulations ICAO standards contain never supersede the primacy of national regulatory requirements.¹” This is an important distinction; a country’s civil aviation authority maintains its jurisdictional sovereignty over its nation’s aviation operations while implementing globally accepted ICAO standards. It’s this distinction which makes conceivable the promise of ICAO being the global model.

ICAO’s standards are contained in 19 Annexes, and Annex 1 is titled “Personnel Licensing” and contains a section 4.2, Aircraft maintenance (technician/engineer/mechanic). This section further refers to ICAO Training Manual Doc 7192, and its Part D-1 which specifically addresses Aircraft Maintenance (Technician/Engineer/Mechanic), and includes Avionics, Radio, Autoflight, and Instruments.

The ICAO standards, although valuable as a global influencer, do not require that Aircraft Maintenance Engineers have a specific license for Avionics.

EASA

The European Aviation Safety Agency has its part 66 regulation which deals with the licensing of Aircraft Maintenance Engineering personal. This licensing falls into 3 categories:

  CATEGORY A

       Category A1 – Certifying Mechanic Piston Engine powered Fixed-wing Aircrafts.

       Category A2 – Certifying Mechanic Turbine Engine powered Fixed-wing Aircraft.

       Category A3 – Certifying Mechanic Piston Engine powered Helicopter.

       Category A4 – Certifying Mechanic Turbine Engine Powered Helicopters.

  CATEGORY B

       B1.1 – Certifying Technician Piston Engine powered Fixed wing Aircrafts

       B1.2 – Certifying Technician Turbine Engine powered Fixed wing Aircraft.

       B1.3 – Certifying Technician Piston Engine powered Helicopter.

       B1.4 – Certifying Technician Turbine Engine powered Helicopters

       B2 – Certifying Technician Avionics

       B3 – Certifying Technician Ultra Light Aircraft.

   CATEGORY C

       Category C – Certifying Engineer.

Significantly, note that which I have bolded, the B2. To the best of my knowledge this represents the first instance of a Civil Aviation Authority certifying the Avionics specialty. Many countries have copied the EASA model for licensure of AMEs.

FAA

The Federal Aviation Administration regulation for mechanics falls under Part 65, Certification, Airmen other then Flight Crew Members, and its subpart D addresses Mechanics. Mechanics can have an Airframe and/or Powerplant certificate (A&P). There is no certificate available from the FAA for avionics. Note however that regarding the privileges and limitations of mechanics, FAR 65.81(a) states that

My italics. Note the A&P limitations on instruments. So, how does FAR 1 define instruments?

That definition curiously includes topics which many of us would include as avionics. The go-around for this limitation has always been to obtain a Repairman Certificate for those systems. Repairman Certificates are not quite ‘Certifications’ such as an A&P, however, since they are only active with the employer you are with, and upon your departure must be surrendered. The pesky question in the US then, is how have employers recognized any level of license to equate with avionics/electronics knowledge for hiring purposes?

The FCC, Federal Communications Commission has licensing options for those engaging in operations on the radio frequencies, for example, radio station operators, TV stations, and amateur operators (AKA Hams). Engineers which work on and can sign off on work performed for radio station and TV station transmitters must have a General Radio-Telephone Operators license, commonly called a GRO. In the past this was called the First-Class FCC license. The GRO test is a difficult test whereby you must know electronic circuits of all kinds, a plethora of electronics formulas, and FCC regulations. The GRO has the option to have additional endorsements, and one of those is a ship radar endorsement.

Although not aviation specific, the GRO was for decades, and continues to be, an acceptable measure that the possessor knows their electronics, which applies to avionics. In fact, many job descriptions for avionics technicians included the desired GRO license, and the radar endorsement was very good to have. For example, many repair stations and airlines hired avionics technicians based on their having the FCC GRO. I should know, in addition to my A&P and I have the GRO with the radar endorsement and was hired into a major airline as an avionics technician based on this credential.

Nonetheless, there is the continued and correct perception that the FCC GRO is not aviation specific, and there does not appear to be any FAA efforts to address this or to have any certifications of avionics technicians. In recognition of this, NCATT, the National Center for Aerospace & Transportation Technologies, created the Aircraft Electronics Technician (AET) certification.

ASTM NCATT

In 2014 the standards setting organization ASTM absorbed the aviation technician certification products that the National Center for Aerospace and Transportation Technologies developed.

The NCATT 61-page study guide² for the Aircraft Electronics Technician details an impressive list of topics the student will be tested on. There are 90 questions and the passing grade is 73%. In addition to these core requirements, there available several endorsements in the following areas:

• Autonomous Navigation Systems (ANS) (AET Endorsement)
• Dependent Navigation Systems (DNS) (AET Endorsement)
• Onboard Communications & Safety Systems (OCS) (AET Endorsement)
• Radio Communication Systems (RCS) (AET Endorsement)
• Aerospace/Aircraft Assembly (AAA)
• Foreign Object Elimination (FOE)
• Unmanned Aircraft Systems Certification (UAS)

Each endorsement has its own 50 questions with a passing grade of 70%

Significantly, the Aircraft Electronics Association (AEA) endorses this program, and the FAA, in response to an October 2018 petition from the AEA, formally recognized ASTM’s National Center for Aerospace and Transportation Technologies (NCATT) Aircraft Electronics Technician (AET) certification as equivalent to formal training when showing eligibility for earning a repairman certificate³.

Keep in mind however, that like the FCC GRO, the AET certificate does not empower you to perform Return to Service actions; you still need an FAA Airframe or Repairman certificate. This contrasts with the EASA model (B2) which does permit this.

Over ‘n out

Roy ‘Royboy’ Resto

AimSolutionsConsulting.com

1 https://www.icao.int/about-icao/Pages/default.aspx

2 https://www.spacetec.us/wp-content/uploads/2019/03/AET-Study-Guide-v5-12.pdf

3 https://generalaviationnews.com/2019/01/10/faa-recognizes-aircraft-electronics-technician-certification/

A noticeable trend which should give all of us pause for circumspection is that of training vs competency. The noticeable trend is that on paper, employees have the documented training, but in practice the corresponding skills are noticeably lacking. Overall, the issue of training in our challenged and evolving environment is well known. For background on this, read this prior article titled “Critical Need for Training Including Executives”:

https://www.aviationsuppliers.org/critical-need-for-training-including-executives

In this article, however, I want to focus on the topic of competency… to be competent. A simple definition: Competence is the proven ability to apply knowledge and skills to achieve desired results consistently.¹

For those of you who may be IAS/ISO/EN/AS accredited by, for example 9001, 9110, 9100, or 9120, these contain a section 7.2 titled Competence. Minimally it contains this:

7.2 Competence

The organization shall:

1. determine the necessary competence of person(s) doing work under its control that affects the performance and effectiveness of the quality management system;
2. ensure that these persons are competent on the basis of appropriate education, training, or experience;
3. where applicable, take actions to acquire the necessary competence, and evaluate the effectiveness of the actions taken;
4. retain appropriate documented information as evidence of competence;

Two tales from personal experience:

• One of the hardest exams I have ever taken was for the FCC General Radiotelephone Operators License with a Radar Endorsement. Formally this was called the FCC 1^st Class. You had to have detailed knowledge of electronic theory and regulations, and you had to have the electronic formulas memorized and be able to apply them. To this day many avionics MROs accept this as proof that you know electronics. The problem was that I had the head knowledge of electronics but had to go on to OJT to learn how to troubleshoot and do basic testing using the many forms of equipment; initially I had the training but not the competency on the topic. The FCC exam, although tough, did not test for this.

• On the other hand, as a certificated pilot and mechanic, the tests for these consist of 3 parts, the written, the oral, and the practical. The oral and practical portions of the exam are designed to exhibit a minimum level of competency to the satisfaction of the Examiner.

How to Assess Competence¹

The following is a good listing:

- Observation and supervision

- Performance metrics

- Simulation or scenario-based testing

- Peer or manager reviews

- Certification or licensing

Becoming and/or demonstrating competence

• Observation and Supervision – Example: Supervised OJT: If there is an area of weakness with ASA-100 accredited firms it is that OJT is rarely performed and documented despite the standard stating in 4.C:
  • All training, both formal (classroom) and on-the-job training (OJT), shall be documented and the records shall be maintained for all employees who underwent training.

Classic OJT involves a trainer sitting side by side with the trainee. The best OJT models include a checklist of the tasks the employee is to be trained in, and to demonstrate competence in its performance to the satisfaction of the instructor.

• Performance Metrics: Competence is verified through performance, and requires feedback, practice, and evaluation. Performance Metrics is a broad topic and can be applied corporately as in this article titled “23 Employee Performance Metrics to Track”² or tracked to individual performance. Consider productivity and quality of the performed tasks. Also consider data which may reside in your system and through root cause analysis be found to be tied to employee performance, for example:
  • RMAs issued to customers to return products and are connected to employee errors
  • Customer Complaints
  • Results of surveys

• Simulation or scenario-based testing: I like using this. For example, I have a test I use in my consulting business which is designed to check for competence in detecting errors in part’s trace, condition, and documentation. It has pictures, and many samples of typical documents. The test consists of writing any detected issues on a Receiving Discrepancy Log. This is not a knowledge test, it’s a test of the application of previously acquired knowledge.

I remember an interesting test from a customer when I worked at an MRO. The customer utilized us as a subcontractor to perform Non-Destructive Testing (NDT) on their parts using specialized equipment operated by highly trained inspectors to find any cracks in the metal products sent for testing. Every 3 years when it came time for us to be reevaluated as a supplier/subcontractor, the customer would send us a part with a known crack which could not be detected visually; it could only be detected by a skilled inspector using specialized NDT equipment. I know because the inspector brought to my attention that he had rejected the part on a red tag returned to the customer with a scrap recommendation and here it was back again 3 years later. The customer admitted to this tactic, and we remained on their Approved Supplier List.

• Certification or Licensing. There are already a number of certifications or licenses which incorporate various methods to assess competence in our arena, for example:
  • IAS/AS/EN/ISO/IOSA/CASE Auditing
  • 6 Sigma Belts
  • Hazmat/DG
  • Maintenance Technicians
  • Pilots
  • Forklift and other heavy machinery operations
  • NDT/NDI Inspectors
  • Dispatchers

Over ‘n out

Roy ‘Royboy’ Resto
AimSolutionsConsulting.com

Written without the aid of AI generated content

1 – Information from Sam O’Connor’s PowerPoint titled “Training Vs. Competence”

2 - https://www.aihr.com/blog/employee-performance-metrics/