FAA wants/needs your input
Your real world experiences with all FAA sources MATTER
Think data, SMS and risks
Working group will evaluate advisory material, policies and provide feedback.
Sean Broderick | Jan 19, 2018
One of aviation’s most knowledgeable and best informed writers, Sean Broderick, has flagged an important FAA action. Everyone who works in the Part 145 environment, from executives to AMTs on the shop floor, should read the Aviation Rulemaking Advisory Committee-New Task (Part 145 Working Group).
As Sean noted:
“The rules apply to the 4,800 FAA-certified repair stations, including 800 located outside the U.S. ‘When guidance documents do not reflect current regulatory requirements and FAA…policies, the outcome is an uneven and inconsistent application of agency guidance and standards,’ FAA explains. ‘The Part 145 Working Group will provide recommendations to the FAA to support the goal of consistent and clear guidance documents.’ Among the key focus areas will be revamping guidance so it fits with the agency's emerging, systems-focused oversight philosophy. ‘The agency's policies advocate performance-based oversight,’ FAA explains. ‘However, guidance documents, particularly those directed at the agency's workforce are often prescription-based.’ … ‘We’re thrilled to see progress getting made on what is a vital task for industry – whether the average repair station recognizes it or not,’ Sarah MacLeod, ARSA executive director and a past ARAC participant, tells MRO Network. ‘This is a chance for those of us coping with the agency’s guidance to recommend a method for aligning what the FAA repair station rule actually requires with agency expectations. There’s a long way to go, but this is a good day for maintenance compliance.’ The group will have 24 months to develop a draft.”
Those of you, who are wise enough to be a member of ARSA, Ms. McLeod will create some process by which the association will accumulate and reflect your thoughts.
Other Part 145 professionals read the tasks assigned to the ARAC
(1) Perform a comprehensive review of internal and external guidance material, in relation to the current laws and regulations, that pertain to certificating and overseeing all part 145 repair stations. This review will include pertinent—
(a) FAA Orders, Notices, Advisory Circulars, Job Aids and Safety Assurance System (SAS) Data Collection Tools. (b) Laws and executive orders, particularly those associated with inclusion of small business and paperwork reduction act requirements in agency policy and guidance. (2) Develop recommendations on improvements to— (a) Internal and external guidance material to ensure it is: (i) Aligned and compliant with the aviation safety regulations, other laws and executive orders reviewed in (1)(b). (ii) Annotated to the applicable rule, other law or executive order; and, (iii) Consistently numbered to ensure a comprehensive relationship between the guidance document and the annotated rule, law or executive order. (iv) Developed to communicate the agency's expectations for compliance to the public and the FAA workforce in a comprehensive and consistent manner, including the tools necessary to ensure the application and evaluation of compliance includes performance-based oversight. (b) Oversight by the FAA's domestic and foreign workforce vis-à-vis the amount, type, scope, and complexity of work being performed and the certificate holders' size. (3) Develop a preliminary and final report containing recommendations based on the analysis and findings. The reports should document both majority and dissenting positions on the recommendations and the rationale for each position. Disagreements should be documented, including the reason and rationale for each position.
Now think about the last time an FAA inspector visited your facility and try to recall all of the arguments, which you had about his/her interpretations of the FARs. Then, gather your co-workers and discuss ACs, ADs, FAA Handbook language and any other relevant documents. Focus on the words which made no sense to you; try to recall the language of an AD which instructed you to do something totally absurd. Look around for whatever FAA form which caused you great pain when filling it out.
Step back from the past practices between you and the FAA. Think about the current SMS regime and then ask yourself and your team
- “What are the critical risk factors on which we should focus?
- Based on your knowledge of how to manage the airworthiness of the powerplants/airframes/avionics/parts which you approve, what are the critical criteria on which you focus?
- What data, currently not available (you may have the numbers, but they are too small to be statistically reliable) would help. Aggregated Part 145 experience may help project where you should put your attention.
- Ask the collective wisdom of your group for their ideas for improvement?”
Assign the best writer in your team to put your collective “gripes” into plain English. Delete the expletives and polish up the descriptions. Your practical, shop floor knowledge is literally a different language; so, make sure that terms and jargon are clear.
Submit your magnus opus to Sarah MacLeod or ask
Paul M. Cloutier,
Federal Aviation Administration,
800 Independence Avenue SW,
Washington, DC 20591,
to share your suggestions with the Task Force.
If you fail to submit your ideas, you may no longer complain about the FAA.
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