Manual 12684953

Manual 12684953
In this monthly column, Ric Peri of the AEA’s Washington, D.C. office, informs members of the latest regulatory updates.
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v i c e p r e s i d e n T o f G o v e r n m e n t & IND U S T RY A f f a i r s f o r a e a
You Can’t Regulate Perfection
“The truth is, it’s not possible to legislate perfection, even when the strictest regulations are in place.
The health of the system is in the hands of the men and women who ply their trade in the halls of finance.”
Maria Bartiromo, The Weekend That Changed Wall Street
hile Ms. Bartiromo was speaking about the financial industry,
the same holds true in most
every other regulated industry. You simply
cannot regulate perfection. Having said that,
the government’s desire for perfection in
aviation is no less compelling than it is for
Wall Street. As many of you know, I have
been mired waist-deep in a new initiative
called SMS (safety management system). It
isn’t an FAA initiative, or Transport Canada,
CASA, or EASA. It is, in fact, a worldwide
initiative—and it is focused on perfection.
While there are many elements of the financial collapse that aren’t anywhere near
the operations of aviation, there are some
very important lessons to be learned from
the battle on Wall Street.
First, truth is fleeting. What the public
believes is what the media reports. Statistically, the commercial aviation accident
rate in nearly the entire developed world
is zero. And while commercial aviation is
statistically perfect, on Aug. 27, 2006, 49
people in Lexington, Ky., would challenge
the concept of perfection. And on Feb. 12,
2009, the friends and family of the 50 people killed in Buffalo, N. Y., would point out
that aviation is not perfect. And in both ac16
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cidents, “breaking news” would report for
the next three or four days how aviation was
Then, the politicians begin to hear from
victim groups with statistically insignificant
facts that are extremely personal. The accident numbers are within the plus or minus
of standard deviation — statistically zero, it
didn’t happen. But for the victims of the rare
accident, it did happen. For the families of
the rare victim, it did happen. At this point,
statistics don’t matter. The fact is, for the
victim, their friends and families, even one
accident is one too many. Hence, the public
demands perfection, the politicians demand
perfection, and as a result, the government
regulatory bodies demand perfection.
So we take the next step toward regulatory perfection: SMS.
But this is where we need to take a step
back and do what the International Civil
Aviation Organization suggests: perform a
GAP analysis. This is a management system
that is being introduced for all of aviation.
The management structure of flight operations is distinctly different from the management structure of a maintenance small
business. This isn’t to say that the generalizations of the ICAO program cannot be
applied to maintenance organizations, but it
may not look the same as the structure of a
flight operations-type organization.
Plus, keep in mind that ICAO was designed to take industry best practices and
universally apply them to all international
flight operations. What were the “industry
best practices” that were the focus? Communications, non-punitive employee reporting, and risk assessment, analysis and
mitigation. Fancy words. But what do they
really mean?
Encourage communications within the
work force to help management see what
they might miss in their daily activity. For
an air carrier, this may be having flight
crews report what they experience thousands of miles away. For maintenance, it
is what happens in the shops, hangars and
Nonpunitive reporting is encouraging the
international community to adopt programs
such as the NASA aviation safety reporting
system (ASRS). The ASRS collects voluntarily submitted aviation safety incident/situation reports from pilots, mechanics, controllers and others. A submission to ASRS is
considered nonpunitive and unless there is
evidence of criminal activity or willful dis-
We must not fear the challenge of perfection, but, rather,
use it to review and promote what we are doing right and
correct and amend those things we could do better.
regard of the regulations, the FAA will not
seek enforcement actions on the submitter.
The international community wants to encourage taking this concept a bit further by
opening the door to employees to admit errors without the fear of job loss.
As you read this, you say, “But I already
do this, so why do we need more rules?”
Remember, I am referring to industry best
practices. In my view, the AEA membership, in general, does represent the best
practices. But I also can count the many
times when members cite competitors who
don’t exercise best practices. And, noncertified maintenance shops won’t be held to
the same industry practices.
An interesting perspective of this initiative is the GAP analysis that even the
authorities seem to have ignored. They all
know what this should look like (in their
mind’s eye) and fail to perform even the
most basic analysis of the regulations.
Part 43 prescribes the rules governing
the maintenance, preventive maintenance,
rebuilding, and alteration of any aircraft
having a U.S. airworthiness certificate and
any airframe, aircraft engines, propellers,
appliances, and component parts of such
The Performance Rules (14 CFR 43.13)
prescribes the maintenance methods, techniques and practices that must be followed.
It also prescribes the tools, equipment and
test apparatus that must be used.
Then, Part 145 contains the management
system a certificated repair station must
follow related to its performance of main-
tenance, preventive maintenance, or alterations of an aircraft, airframe, aircraft engine,
propeller, appliance, or component part.
So, if the National Aviation Authority
already mandates a management system
for the safety and quality of a repair station, what more is needed? First, recognize your employee communications. You
don’t need to do more, you just need to tell
the authority what you already are doing.
Then, apply the risk management tools as
spelled out in ICAO for the strategic decisions that a repair station must make as a
function of their mandated management
What are “strategic decisions?” Part 145
requires sufficient work space and areas for
the proper segregation and protection of articles; the ability to segregated work areas
enabling environmentally hazardous or
sensitive operations; suitable racks, hoists,
trays, stands, and other segregation means;
space sufficient to segregate articles and
materials; and to ensure personnel perform
maintenance, preventive maintenance, or
alterations to the standards adequate ventilation, lighting, and control of temperature,
humidity, and other climatic conditions.
The SMS tools of ICAO allow for a decision to be made that is auditable by the
authorities and documented so the data can
be used at a later date when you choose to
expand your business further. Basically, it
should not significantly change a well-run
As the New Year begins, we must look
toward the future. We must find a compro-
mise between the demands of our customers — the vocal public and politicians for
the agencies, and the industry customers
who must pay the price for perfection. It’s
not free. At times, they seem to be at odds
with each other. But we should promote
the price of perfection and allow our customers to demand reasonableness from the
politicians and special interest groups.
We must promote what we are already
doing. As an AEA member, we strive to
exhibit industry’s best practices. We need
to advertise the benefits of perfection
alongside the latest sales price. We should
defend the prices we charge for industry’s
best practices. We must not fear the challenge of perfection, but, rather, use it to
review and promote what we are doing
right and correct and amend those things
we could do better.
I need your help. Over the next year
we will be listening to the FAA (and other
NAAs) as they continue on their regulatory quest to perfection. We know that if
we allow them to place another bureaucratic layer over the small businesses, industry will fail. Let’s work together to find
the solutions that are workable, reasonable
and are the industry’s best practices. Remember, no matter how unrealistic it may
seem, in the public’s view, anything short
of perfection is unacceptable for the aviation industry. q
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