Having worked for a major airline, the tragic memory of one of our aircraft crashing into the side of a mountain remains vivid. I was the senior QA member of management at the facility where this aircraft had all its major maintenance performed. I was off duty when the news broke. I called my on-duty staff and instructed them to sequester all the records for the aircraft in anticipation of the investigation review. As the sun rose the next day, the call came to hand these over. My thoughts immediately evolved to the quality of these records; were they accurate, where there any mistakes?
In another case, a major airline’s aircraft crashed into the coastal Pacific Ocean. During the long investigation I did some consulting work for the airline directly related to the accident. Their records too, were carefully investigated.
It is natural for investigators of records, upon seeing lapses in accuracy, thoroughness, or mistakes made, to conclude that such behaviors may extend to other things; if they can’t get this straight, what else are they messing up?
From the moment you are born until your death, you are creating records, in this case your Birth and Death Certificates. In fact, on paper you don’t exist, or have really perished, until these records are presented upon demand. And so it is for aircraft. From the moment metal is being cut until its certificate of destruction or mutilation, there is a torrential slew of records being created.
So…how good are your records?
Quality Audits of Records:
A significant amount of time is spent during an audit looking at records; training records, scrap records, CAR records, Management Reviews, self-audit records, etc., but this article will focus on parts records.
During an audit I like to review at least two complete sets of records of parts already shipped. The records reviewed include all the documents sent to the customer with the part, and I also ask to see the customer’s PO or RO (Purchase Order, Repair Order). These records tend to be very rich in auditable material and are frequent sources of Non-Conformity Reports, NCRs. For example:
- Did your shipment meet all the customer’s requirements? Note that this extends to more than just PN, QTY and ship-to. Failure to read and heed those pesky T&Cs (the Terms and Conditions on a typical PO or RO) is a frequent NCR.
- Who signed your C of C/Material Cert? Are they authorized to do so (cross checked to the Roster)?
- Where was the part obtained from? Are they on the Approved Suppliers List?
- Did you send the part to a repair station/AMO? Are they on the Approved Suppliers List?
- Whomever you claim to have trace to, is the chain of custody acceptably documented?
- Are part numbers, serial numbers, and condition in harmony?
- If there were any deviations from what the customer required, was there reasonable documentation in the record showing the customer’s acceptance of the deviation?
- Customer’s PO/RO T&C’s: The ones frequently missed include:
- PMAs will not be accepted without prior approval. Then I find an 8130-3 whose comments field clearly states it’s a PMA, but there is no evidence of customer acceptance. This is a frequent note seen on customer T&Cs, and unfortunately the customers don’t seem to make a distinction between PMA done under license and those that are ‘substitute part number’ PMA. In the absence of such a distinction, any PMA provided must be accepted by the customer.
- DER Repairs must be accepted but got missed.
- The Airworthiness Release Certificate must be a Dual or Triple release, but the tag supplied is a single release.
- The customer asked for an overhaul condition, but a repaired part was supplied.
- A serial number was specified but a different one was shipped.
- Are emails records? For example, there will be a deviation from the customer’s PO/RO, or the customer has accepted your PMA part, and the customer’s acceptance of the deviation or PMA occurs on an email. POH-LEEZE have this email copied to the computer system applicable record, for example, in the Sales Order record. Simply having it on the salesperson’s personal company email is not a reasonably accessible record, and it can be easily deleted. In nearly all instances where I find this, the salesperson knew this should be added to the Sales Order record but forgot. If the salesperson is no longer with the firm, good luck finding the email.
- Drop Shipments: With the increase in drop shipments, we’re seeing a corresponding increase in NCRs regarding the drop shipment. This is always evidenced by a review of records. Nearly all the drop ship NCRs are for the previously cited reasons in this article. Many drop shipments are for Rush or AOG orders. Make sure the persons approving the drop shipment are not conflicted by the lure of the sale versus a quality review of available documents, pictures, and the customer’s PO; there, I said it and I meant it.
- Life Limited Parts: Due to the safety considerations of LLPs, these records must be as close to impeccable as possible.
Standards and Regulations for Records:
In aviation, nearly every standard and regulation will address record keeping. This applies to the entire spectrum of aviation firms such as manufacturers, distributors, repair station/AMOs, and operators. A small sampling follows:
- ASA-100, Distributor Quality System Standard, paragraph 12:
- “The distributor shall maintain documentation of traceability for at least 7 years…
- The distributor shall have a system in place governing the storage, distribution, and retrieval of documents…
- All life-limited parts shall have records…
- Records shall be protected against damage, alteration, deterioration, and loss.”
- Note: ISO/EN/AS quality standards have switched from using the term ‘records’ to ‘retain documented information.’
- EN/AS 9110, Requirements for Aviation Maintenance Organizations, “… the details of the system used to maintain and retain documented information of the work performed for each article or product,” and many others.
Record Retention Period:
The retention period by which you are required to have the records on file and accessible vary considerably by type of operation being performed, the Quality System you are accredited to, and any requirements your customer may impose. Because of this, these periods may vary from between 2-10 years. For those of you who may be burdened with paper records, a 10-year requirement is easily noted by the stacks of those banker boxes gathering dust in your warehouse. Make sure these boxes are carefully indexed for ease of retrieval.
Back to my airline stories.
In the case of my airline’s accident, the NTSB concluded that the accident was due to pilot error and technology challenges. The maintenance performed as evidenced in the records was not cited.
Regarding the aircraft that crashed into the ocean, maintenance was heavily implicated, and all the records were meticulously reviewed; the source of the parts, tear-down reports, the maintenance performed, and logbooks among many others.
Would you have felt comfortable if any of your records were in the lineup?
Over ‘n out
Roy “Royboy” Resto