CAVU Café: Royboy’s Prose & Cons, Page 13 of 17

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

Keep Your Manuals Current!

Posted By Roy Resto | October 10, 2014

During my youthful days at a major airline, I distinctly recall a close friend who had just been promoted to an important position. After a while, I asked him ‘What could you have done to be better prepared for the job?’ Without hesitation, he said ‘I wish I had been more familiar with the GPM.’


Every airline has a GMM (General Maintenance Manual) or equivalent GPM (General Procedures Manual). It is thee operations manual for instructions on how the Maintenance Division conducts its business, and you will be held accountable as a department head to assure you perform applicable portions. From that point forward I made it my business to read it whenever I could, to personally file all the revisions in our department’s copies, and to make myself the go-to person regarding its contents. It served me well in my career there, and it became a life-long custom to’ know the manual’ in any firm I was in.


Through the performance of many CASE Audits, Internal Audits, Supplier Audits, and consulting engagements, I’ve had exposure to hundreds of manuals. In my mind I early established a firm observation regarding the evident correlation between the vibrancy of a given quality system and the state of its manual; a vibrant and robust quality system will have a continuously evolving and updated manual.


So what? Why invest all that energy in keeping it updated? Consider the following:

  • It is a direct reflection of your firm, it’s the written ‘you’
  • Every regulatory or quality standard requires you to keep it current

  • Your major customers may ask for a copy during their decision making process about awarding business

  • You’re telling your employees ‘this is how we operate’; it is likely the nearest written reflection of the key attributes you’d like your firm to emanate in its culture

  • Every regulatory or quality auditor will begin and end with your manual in their hands

Unfortunately (you knew this was coming), there are too many manuals out there that are not current. Now, I understand there are firms with scheduled revision service, for example quarterly, who await that time for publishing their updates, but I’m not talking about those. If I may speak frankly, I mean those who seem downright careless or lazy about making the changes; there, I said it and I meant it. Consider the following:

  • Employees who look for direction in those manuals, only to find outdated guidance, will develop habits to neglect going there at all

  • It’s usually ‘low hanging fruit’ for external auditors

  • It may establish a negative first impression of your firm to customers, auditors, and employees

So, Royboy, are you suggesting I publish a revision every time I find a misspelled word? Of course not you silly wabbit. On the other hand, it is simply not reasonable to find several major processes or procedures out of whack with actual operations, the applicable standard, or regulation. The most common excuse I’ve heard is ‘I’ve just been soooo busy!’ Hmm. Imagine what could happen if and airline’s flight manual was not kept updated…


Roy ‘Royboy’ Resto

www.AimSolutionsConsulting.com

Fully profiled on linked In at www.linkedin.com/in/royresto

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MILITARY MRO, WHERE IS IT GOING?

Posted By Roy Resto | May 27, 2014

For those of you who contribute either directly or indirectly to the military Maintenance, Repair, and Overhaul (MRO) market, fasten your seat belts, realignment is coming.


We often hear the civilian global MRO market quantified in the $50 billion range; that’s indeed huge. If that impresses you, consider this: as recently as 2011, the global military MRO market was valued at $66 billion, and that excludes China and Russia. On the other hand, that value fell to $62.5 and $60.7 billion respectively for 2012 and 20131, so what’s going on?


There are several factors influencing the attenuation of this market:

  • First the obvious; sequestration mandated caps. Do I need to dwell on this factor? Probably not.

  • There will be continuing, but a more sudden and steep drop off in what is called Overseas Contingency Obligations (OCO). Generally, this is spending to cover the over-and-above necessity of ‘surged’ MRO for assets involved in contingency operations like Libya, Iraq, and Afghanistan. Iraq and Libya are behind us, and Afghanistan is winding down. To get a handle on the breadth of what will be going away, consider that in the current fiscal year OCO spending is $85 billion3.

  • Cutbacks in military force structure: As the size of the Federal Government contracts in order to mitigate deficit spending, the same contraction will occur in the military. For MRO, look for the services to draw down or eliminate MRO-intensive legacy weapons systems.

  • Globally, what the US calls ‘sequestration’ the world calls ‘austerity’. This has tentacles into every nation’s defense budgets, and the spending drawdown is evident.

The question is, are these trends triggering any other activity or changes? The answer is, of course they are. Here are some examples:

  • A Pentagon program called Better Buying Power. Decades ago, ‘prime’ suppliers would accomplish most work in-house. Compare this to today where the primes subcontract up to 60-70% of the work. In realization of this, programs like Better Buying Power are ‘flowing down’ the pressure to those subcontractors to create greater efficiencies and savings; to the point of rewriting long standing deals in some cases2. Put any other way, the subcontractors are feeling squeezed as margins are being scrutinized for adjustments. In some cases the Pentagon is placing so-called integrated cost analysis teams at contractor facilities to learn about their cost structures. Activity like this is influenced by the perception that in the past some contracts were awarded which, in light of today’s environment seemed too generous.

  • As the cuts become deeper, pressure will be applied to rattle and change long held doctrinal practices among the military services. A recent example being bandied in the media is the fate of the MRO- intensive USAF A-10. If this fleet is grounded, will that mean the USAF will relinquish its Close Air Support (CAS) mission? It was not too long ago that under similar economic pressure the USAF relinquished its Airborne Electronic Warfare (EW) mission to the Navy by grounding its MRO intensive F-111 and F-4G fleets.

  • What about the Depots? The Depots are those enormous MRO bases run by the various government military services. The Depots mostly came into being after WW II, when the Pentagon was worried that the huge post-war draw down would erode civilian industrial capacity and their desire to support continuing MRO needs. Because of this, Congress mandated that a percentage of MRO work be kept in-house (the Depots), and today that percentage is referred to as the 50-50 rule: At least 50% on average, must be accomplished by organic organizations – the Depots. Their share of the work is largely monopolistic; not subject to classic competition as is the remaining 50% work that is outsourced to contractors. In today’s robust MRO environment, is there really a need for the 50-50 law?

Predictably detracting from a collegial discussion to answer that question, are two powerful factors: The Depot unions and politicians. The Depot unions are adept at mobilizing protests and their local politicians at the faintest sounds of reforming military MRO, and why not? They have a long history of successfully providing quality MRO services which includes specialized needs peculiar only to the military. On the other hand, there are those that argue that Depots are hampered by being bloated and bureaucratic; that the lack of a profit incentive (compared to industry contractors) does not drive continuous efficiency growth; and further, that the absence of competitive bidding for all MRO work means the tax payers may not be getting the best value for the investment. They also contend that if the work is being accomplished on US soil by US citizens, why shouldn’t 100% of the military MRO work be open to free competition among all qualified parties, Depots and contractors alike? Watch the fur fly


It’s also interesting to note another trend in some Depots: They’re getting FAA Repair Station certificates. This is interesting for these reasons:

    • This will make it easier for them to work on emerging military aircraft and systems being certified and maintained under FAA regulations.

    • They will compete for work previously accomplished exclusively by contractors.

    • Look for them to eventually seek work not traditionally associated with DoD work. For example, if they have extensive MRO capability for engines, who’s to say that same expertise can’t be applied to civilian engines?

  • Internationally, look for nations which are allied to explore pooling military assets to a greater extent. Think of this as fractional ownership for those expensive military systems. In Europe, AWACs aircraft are being jointly operated by several NATO nations, and recently, several countries stood-up a jointly operated C-17 Unit in Papa Hungary. Also in Europe, after the Libya campaign, there was a heightened awareness of the lack of air-to-air refueling aircraft. I expect some of these new aircraft to be jointly operated under similar fractional ownership, if not operated privately as suggested in the following.

  • Increased privatization of government services. Please go back one click to a previous blog I wrote titled “ACCELERATION OF PRIVATIZATION OF GOVERNMENTAL SERVICES”, or click http://www.aviationsuppliers.org/index.asp?bid=222&BlogEntryID=236&FormID=300

For the US alone, the defense maintenance sector counts total inventory of more than $350 billion worth of aircraft, missiles, and other vehicles being maintained by 650,000 military and civilian personnel3. With numbers like that, the debates are likely to be characterized and influenced by partisanship, local politics, interest groups, hidden agendas, and parochial interests. We see the same playing out globally. Hopefully those with bold, creative, and potentially effective solutions will not be drowned out.


Roy Resto


www.AimSolutionsConsulting.com


1 Source: ICG Analysis

2 Supplying Pressure. Aviation Week & Space Technology. Page 26, April 28, 2014

3Churning Out. Aviation Week & Space Technology. Page 225, May 12, 2014

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AIRCRAFT LEASING 101, AN INTRO

Posted By Roy Resto | April 22, 2014

Leasing activity for aircraft, engines, and major components appears to be on the rise. For example, for engines, the leasing market is now at $14-15 billion, with new leases of $2.5 billion coming on line each year, and an estimate that as much as 50% of spare engines globally are funded by operating leases1. For aircraft, over a third of the world’s airline fleet is now leased2, and is expected to rise to 50% by 20153. Distributors and MRO’s should take notice of these trends because the terms of the leases often give specific instructions and limitations regarding the parts used during the course of expected maintenance, and in some cases, the choices of MRO’s. Given these developments, I thought I’d take time to impart some introductory information on the practice.


By the way, are there any freshman college courses that still use the “101” for the course numbers?


Lessor: The firm with the asset that is being leased to an airline/operator.

Lessee: The firm operating the leased asset


Why Lease?


The need for increased levels of reliability and fuel efficiency has pushed technological innovation for aviation products to new heights. Technological risk, which in the past was reason for lengthy and more cautious product rollouts, has been greatly mitigated by the overwhelming need for fuel efficiency and reliability. All this has pushed prices to dizzying levels. Consider that a new GE90 engine for a 777 will cost close to $35 million, and the same new aircraft in the range of $300 Million. To buy will usually require substantial cash outlays, and consider that some banks have taken steps to reduce their exposure to the aviation industry, limiting in some cases, financing those buys. For any operator that is cash-challenged, wants to maintain a level of cash reserves, or liquidity, leasing would then seem increasingly attractive. A short list of additional reasons to lease may include:

  • The operator only has need of the asset for short term, seasonal or temporary use. E.g., the airline’s fleet of aircraft or engines are entering a cycle when heavy checks are due, and therefor will not be available for revenue operation; lease to make up the difference.

  • For an operating lease (discussed later), the asset does not appear on the lessee’s balance sheet.

  • The airline needs cash: The airline sells its owned aircraft or engines to a leasing firm, receives the cash, then gets the aircraft leased back which remain in service.

  • A “Wet Lease”, sometimes is a way for an operator to circumvent restrictions it may have on flying into certain countries. The restrictions may be imposed by political or NAA sources. In other words, if an airline is restricted from flying in certain countries, a Wet Lease may be a way to get your products or customers there. Commonly called ACMI, the lessee is leasing the Aircraft, Crew, Maintenance, and Insurance is provided. Most wet leases are not for this reason, however.

  • When dramatic economic changes occur either to the airline or in the operating environment, the leased assets can simply be returned under the terms of the agreement.

  • For lessors, there is the expectation that an otherwise idle asset will be generating steady income.



How?


There is literally a myriad of different leasing options, agreements, terms and conditions, with their own pro’s and con’s. For the purpose of this blog, I’ll just keep it simple, and please keep in mind there are variations for all of this.

WET LEASE:

  • Commonly called ACMI, the lessee is leasing the Aircraft, Crew, Maintenance, and Insurance is provided.

  • The period can go from one month to usually one to two years.

  • The Lessee has to provide all fuel, landing/handling/parking/storage fees, crew expenses including meals and transportation as well as visa fees, import duties where applicable, as well as local taxes. Furthermore, the Lessee has to provide passenger/luggage and cargo insurance and in some cases need to cover the costs for War Risk.

  • BTW, the term “Wet” at one time meant, and still in some agreements means, that fuel is provided.


DRY LEASE:


This is the lease of the basic aircraft without insurances, crew, maintenance etc. Usually a dry lease is the instrument of choice by leasing companies and banks. A dry lease requires the Lessee to put the aircraft on his own AOC (Airline Operating Certificate) and provide aircraft registration. There are generally two types of dry leases, an Operating Lease and a Finance Lease.


Operating Lease:

  • Generally a lease term that is short compared to the economic life of the aircraft being leased. An operating lease is commonly used to acquire aircraft for a term of 2-7 years.

  • With an operating lease the aircraft doesn't appear on the Lessee’s balance sheet.

  • Operating Leasing has grown from 3% of the world fleet in 1980 to 35% today, and is expected to rise to 50% in the next decade3.

Finance Lease: also known as a capital lease, is defined when one of the following conditions are met:

  • At the end of the lease term the Lessee has the option to purchase the aircraft at an agreed price.

  • The lease payments are more than 90% of the market value of the aircraft.

  • The term of the lease is over 75% of the aircraft's usable life.

With a finance lease the aircraft appears on the Lessee's balance sheet, because it is viewed as a purchase.


Leasing’s impact on Distributors and MRO’s:

Since the Lessor’s own the asset, there is an expected strong need to enter into agreements which in their eyes maintains and protects the value of the asset; that’s its future marketability is not compromised during the lease. Consider the following in many cases:

  • The lessor will require that the lessee maintain cash reserves to cover the cost of certain scheduled maintenance checks, and further that those checks be performed by MRO’s defined by the lessor.

  • The lessor wants the asset to be maintained in strict Configuration Control. This may mean that alternative PMA parts or DER repairs are not allowed or are closely controlled.

  • Replacement parts used in maintenance may be required to be in new or overhauled condition rather than Repaired, or Inspected.

  • There may be restrictions on exchanges and control of Life Limited Parts

For Distributors and MRO’s, if leasing is increasing, who then is the relationship with? Who is the customer? The Lessor, the airline, both? How about the OEM’s? Nearly every OEM has its own financing and leasing organizations. In other words, there are both independent and OEM lessors. In the face of increasing leasing activity, Distributors and MRO’s should consider diversifying their customer base to include these lessors.


Lease Returns


Based on feedback I’ve had from my aviation friends, it is a rare lease return that will not involve some form of contesting. Teams from the lessor and lessee will be formed to examine every iota of the agreement for compliance. Areas that typically require further resolution include:

  • Were all the AD’s and required Service Bulletins closed out?

  • The status of remaining time or cycles for Life Limited Parts.

  • Were any major scheduled maintenance checks about to become due?

  • Were any parts or assemblies modified to non-standard configurations as defined by the agreement?

  • Anticipated life remaining of Tires and Brakes

  • Are there any installed leased or pooled parts that must be returned to, for example, to a Pooling group?

In settling the particulars of the lease return which often has to be negotiated, Distributors and MRO’s will often find themselves in the settled solutions, e.g., in resultant exchanged parts and MRO activity.


I hope you’ve found this blog (course number LeasingEco101) informative. Please leave a comment on this blog site. We’d particularly like to hear from Distributors and MRO’s involved in leasing activity.


Over ‘n out


Roy “Royboy” Resto

Aim Solutions Consulting

www.AIMSolutionsConsulting.com


1 “Leasing Options for Sourcing Spare Engines”. Aircraft Commerce. Issue No. 90, October November 2013.


2 http://www.economist.com/node/21543195


3 Laurence Vigeant-Langlois, PHD. ”Overview of the Aircraft Leasing Industry”. Presentation to the Air Transportation Systems Engineering class, George Mason University. CIT Group.

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ESD: The Shocking Truth - By: Roy Resto

Posted By Roy Resto | February 14, 2014

I’m sure many of you have noticed movies that replicate the patterns, plots, themes, and scenarios of the blockbuster shows. Today’s predictable formulae might involve guns, car chases, government conspiracies, and of course the 2 minutes of sexual this-or-that, never mind the plot. Another subtle pattern you’ve likely noticed is the role of the supporting hero; you know, the one who comes up with that tantalizing bit of information that seems to break the logjam of suspense. A long running favorite for this role is the computer geek/hacker who seems to easily penetrate any system and after a furious 100-words-per-minute staccato keyboard performance, the antagonists are as good as wet toast. Another emergent supporting-hero-favorite is the forensics expert. Of course, if the role is that of a computer forensics expert, the actor/actress will likely be up for an Academy Award. So, how about forensics for ESD, does it exist?

 

If I have to explain what Electro-Static-Discharge is, and its danger to ESD sensitive aircraft parts, then this is probably not a blog for you; I’m going to avoid a long droning theoretical explanation of the phenomenon. Rather, I want to point out real world issues that hopefully heighten your awareness of the menace for your employees, and aid you in your training of the topic.

 

It is estimated that in today’s electronics environment, up to 60% of device failures are ESD caused1. This statistic is not for aviation alone, but for all electronics market segments. So, does it apply to aviation? I am not aware of any studies or statistics that could authoritatively address the question. Forensics to determine whether failures of aviation electronics are ESD-caused do exist, so why don’t we have a better handle on this peril? The fact is we can’t afford it. We want the failed part fixed and back in service as quickly as possible and at the lowest price. Otherwise, every Avionics Repair Station would have to be equipped with scanning electron microscopes and the specialized equipment to disassemble integrated circuits at the microscopic level in order to scan it for ESD damage…quite unlikely. To be clear, it is not being suggested that this level of forensics be applied to every failure in order to quantify the issue. What should be emphatic is that the degree of ESD caused failures is not routinely or authoritatively quantified, so the 60% figure may be applicable at best, or understated at worst. If so, how observant are your employees regarding ESD protective processes and procedures?

 

 

 

ESD sensitive parts that have been damaged will manifest such damage in one of several ways upon being installed on

the aircraft:

 

a) Immediate failure of the part when the component/system is tested.

 

b) The part fails much sooner than its designed Mean Time Between Failure (MTBF) figure.

 

c) The part exhibits intermittent or random failures.

 

For those you who are or have been avionics technicians, you absolutely abhor intermittent failures; the rule is it never fails when you’re working it, right?

 

Just as significant is the potential for ESD caused failures to contribute to a part becoming a rogue or chronic part due to its many as-yet uncorrected failures. This is tied to the part’s intermittent or random failures. There is another blog devoted exclusively to Chronic and Rogue parts; check it out at this link:

 

http://www.aviationsuppliers.org/index.asp?bid=222&BlogEntryID=19&FormID=300

 

A major factor contributing to ESD damage is lack of heightened awareness regarding the ease in which damage occurs. For example, the average person can feel a discharge on a doorknob if it is greater than 3500 volts; hear the discharge if it is greater than 5000 volts, and see it if it is greater than 8000 volts. By comparison, damage to integrated circuits occurs at fractions of those voltages. This means that the person imparting the damage will not have felt, seen or heard the discharge; nobody knows it occurred, and there will be no forensic investigation of the fact.

 

How about parts just removed from the aircraft? Do your Technicians immediately put on the ESD caps, or does the unit get shipped all the way to the repair shop sans caps? If so, they may have just raised your repair costs by causing additional damage not related to the removal reason. Ask your repair shops how often this occurs, it may surprise you.

 

Finally, I’ve got to say it, I have noticed that at Airlines, Repair Stations, and Distributors, there seems to be a lack of familiarization among internal quality auditors with their own published ESD procedures. If so, this too contributes to our lack of being able to quantify non-compliance and therefor its likely effect on product reliability and cost, and as we all know, we can’t fix what we can’t quantify, or can we?

 

    

For the Distributor/Stockist community, I’m pleased to report the ASA is working on a Best Practice for ESD protection in the workplace; it will be available later this year. Of course there are many ESD Standards, but this no attempt to be a standard; rather a simple Best Practice document available exclusively for Distributor/Stockist operations.

 

For the novice, all this should be shocking; I’ll not remain static on the subject, I must discharge my duties.

 

Your comments left here are most welcome.

 

1ESD Control Handbook, Static Control Measures; 3M Corporation.

 

Roy RESTO
Fully Profiled on Linked-In
www.linkedin.com/in/royresto

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DETERMINING THE ENGLISH-SPEAKING PROFICIENCY OF AVIATION APPLICANTS AND EMPLOYEES

Posted By Roy Resto | January 08, 2014

I was once in Miami and a friend shared a story. He works in a Repair Station there that performs maintenance on aircraft, and has frequent FAA visits. It seems one day an FAA Inspector expressed concerns to him that he had doubts some Repair Station Technicians and Inspectors could competently comprehend English as contained in Quality and Maintenance Manuals. The person responded; “Then why did you issue them A&P and Repairman Certificates?” It is, after all, the FAA’s responsibility to determine such competency before issuing the certificates. I’d caution at this point to resist the temptation to think this is an example of Inspector bias or variation in interpretation of regulations…it is not.

 

In most parts of the world, English is the international language of aviation. Flight Deck instruments are in English, as are flight manuals and maintenance instructions. The process of communication is very fragile and subject to varying levels of understanding at the slightest nuance of expression or interpretation. We all know of person’s who speak English as their primary and only language, yet we can’t quite understand them; Yogi Berra and Leo Gorcey of the Bowery Boys (http://en.wikipedia.org/wiki/Leo_Gorcey) comes to mind, both of whom easily massacre the English language in expressing themselves. Fortunately neither turned wrenches or yokes.

 

The FAA has an Advisory Circular 60-28A titled “English Language Skill Standards Required by 14 CFR Parts 61, 63, and 65”, and it makes proper reference to the efforts of the International Civil Aviation Organisation (ICAO) to establish a basis for evaluating English language skills, and has 6 levels of Proficiency. Level 1 being “Pre-Elementary” and 6 “Expert”. The acceptable minimum level of proficiency is 4 “Operational”.

 

To establish a person’s proficiency level, they are evaluated in 6 areas: Pronunciation, Structure, Vocabulary, Fluency, Comprehension, and Interactions.

 

For example, at “Operational” Level 4, “Fluency” would mean”

“Produces stretches of language at an appropriate tempo. There may be occasional loss of fluency on transition from rehearsed or formulaic speech to spontaneous interaction, but this does not present effective communication. Can make limited use of discourse markers or connectors. Fillers are not distracting.”

The more you peel back the layers of ICAO’s efforts, the more you’ll be impressed with the science it brings. More than that, whether an employer, the FAA, or any other CAA, the ICAO literature brings a level of standardisation that when followed, levels the playing field.

 

So, you ask, how do I administer a test? According to AC 60-28A:

“If deemed necessary by the examiner and/or the ASI in order to assist the determination of the applicant’s English language proficiency, the examiner will require the applicant to read a section of a technical manual. After completing this step, the examiner will require the applicant to write and explain his or her interpretation of the reading. An appropriate technical manual in this sense means an Airplane Flight Manual (AFM), a maintenance manual, or any other publication appropriate for the certificate or desired rating.”

It could be that easy.

 

For pilots we all understand that there can be no compromise in this process, but what about certain maintenance technicians? It turns out there is some latitude. According to AC 60-28A:

 

“(3) Mechanics and Repairmen. Eligibility requirements contained in §§ 65.71(a)(2) and 65.101(a)(6) require an applicant for a Mechanic or a Repairman Certificate and associated ratings to be able to read, write, speak, and understand the English language. An applicant who does not meet this requirement (Royboy’s underline), and who is employed outside of the United States by a U.S. air carrier, will have his or her certificate endorsed, “Valid only outside the United States.””

Although there are some in the aviation community who would question why a person who failed the English test should be granted a certificate as reflected by this Regulation, and yes it is an FAR, I have to say I support it wholeheartedly, and it’s based on my own experiences. I recall one example I had when working for a major airline many years ago. I was doing a Quality Station Audit of our operation in Mexico City and spent a couple of days with the line maintenance staff consisting of all Mexicans, very few of which spoke passable English. I was very impressed with their technical acumen and compliance with published maintenance manual procedures. I quickly learned from this and other experiences that I should not judge a technician’s technical competence based on his inability to express himself precisely in English.

 

On the other hand I have to hand it to air traffic controllers who deal with international traffic. I’ve heard a lot of exchanges that left me scratching my head as to what was said. That’s another good reason for the expansion of pilot-controller text messaging that is slowly gaining operational implementation; it called CPDLC-Controller-Pilot Data Link Communications. These text messages don’t have heavy accents, slang, or intonations. Neat, huh?

 

So what’s your opinion about this stuff? Leave a comment on this web site. You can do so anonymously if desired.

 

Over ‘n out

 

Roy “Royboy” Resto

Fully Profiled on Linked In at:

www.linkedin.com/in/royresto

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AIR CARRIER RELIABILITY PROGRAMS UPDATE

Posted By Roy Resto | December 11, 2013

For those of you involved in Airline Reliability Programs, and particularly for those who attended my session titled “Deferrals Per MEL and Airline Reliability Programs” at the 2013 ASA Conference, I want to give you an update on efforts to revise key FAA Advisory Circulars.

 

In 2005 there was an accident involving a Turboprop which crashed into a department store garden center shortly after takeoff from Manchester-Boston Regional Airport (MHT). The aircraft was destroyed and the pilot of the cargo flight was seriously injured. The National Transportation Safety Board (NTSB) determined that the probable cause of this accident was the pilot’s misapplication of flight controls following an engine failure. Contributing to the accident was the failure of the engine’s sun gear, which resulted in the loss of engine power. Contributing to the sun gear failure were the engine manufacturer’s grandfathering of previously recommended, but less reliable, maintenance standards, the Federal Aviation Administration’s (FAA) acceptance of the engine manufacturer’s grandfathering, the operator’s inadequate maintenance practices, and the FAA’s inadequate oversight of the operator. The NTSB subsequently issued Safety Recommendations A-09-108 through -111. In its report, two of the NTSB recommendations were that the FAA:

“Resolve the differences between Advisory Circular (AC) 120-17A and AC 120-16E in regard to Federal Aviation Administration philosophy and use of on-condition maintenance programs. (A-09-110)


Once the differences noted in Safety Recommendation A-09-110 are resolved, review existing on-condition maintenance programs to ensure that they are compatible with the most current accepted philosophy. (A-09-111)”

FAA AC 120-16 is titled “Air Carrier Maintenance Programs”

 

FAA AC120-17 is titled “Maintenance Control by Reliability Programs”

 

According to a recent Federal Register notice, the FAA assigned a new task to the Aviation Rulemaking Advisory Committee (ARAC) to provide recommendations regarding the outdated AC 120-17. According to feedback I received, this group had its first meeting in the beginning of December 2013.

 

For all of you involved in US Part 121 Airline Reliability Programs, I have no doubt your written procedures includes a reference to AC 120-17. Although this AC was a significant and historic contributor to Reliability Programs, this AC is in fact quite outdated at its current “A” revision dated March 27, 1978. Among the AC’s many outdated passages is a key reference to the ATA’s equally historic Specification MSG-2 (Maintenance Steering Group) titled “Airline/Manufacturer Maintenance Program Planning.” The latest version of this document is MSG-3.

 

It will likely take some time for the final revisions to be published. Regardless, this is a welcome updating of this significant AC.

 

Your comments are welcome on the blog site.

 

Roy RESTO
Fully Profiled on Linked-In
www.linkedin.com/in/royresto

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