Avionics News May 2015 - 33

no jurisdiction to enforce a repair station's voluntary business
cess should include a checklist of what is being provided to the
processes, but that doesn't stop some inspectors from trying.
customer (keys, logbooks, maintenance release, flight manual
Therefore, it works best for you to place these voluntary business
supplement, logbook label), and the customer should be asked to
processes in a separate manual. In fact, your business process
sign the checklist to acknowledge receipt (make sure the words
management system manual could be your primary manual (a
above the signature line say that the customer is acknowledging
higher-level manual), and it could incorporate by reference the
receipt of each checked item).
FAA-regulated provisions found in your repair station manual
In an ideal situation, the checklist should guide a pick-up
and quality manual.
discussion with the customer in which you review the work
performed. This gives you a chance to
double-check that the paperwork is correct,
and it also gives the customer a chance to
Developing and using standard return documentation
review the work performed. Sometimes, the
procedures can help protect the repair station by creating a
customer thought work was being accomplished that was not documented, or was
repeatable process that allows the repair station to repeatedly
outside the work order; if the customer had
expectations that were not fulfilled, then it is
apply its own best practices to every transaction.
best to identify them at pick-up, rather than
after the aircraft has left your shop.
Check the documentation
What do inspectors always check when they audit your facility? They check the paperwork. I have run into a number of
repair stations that put their souls into their work. They do excellent work. But they do not put the same measure of effort into
the documentation.
If we know the FAA inspectors are going to look at our paperwork, first, then we should make every effort to ensure that this
provides them with the right impression of the facility.
Don't treat the paperwork as an unwanted burden. Treat it as
an important part of the process. At a practical level, this means
preparing the paperwork in a methodical fashion and having
mechanisms in place to catch errors before the documents are
signed.
One method to catch errors is simply to have a supervisor
review the paperwork for accuracy. Treat the paperwork like a
required inspection item. But sometimes, this is not enough to
catch the errors. The return process mentioned above (reviewing the paperwork with the customer when he or she picks up
the aircraft) can also serve as an important opportunity to check
the paperwork. Don't be afraid to check the paperwork multiple
times before it is finalized.
Implementing the processes
Most of the time, these processes will not be required by the
regulations. Adoption of them is voluntary. I have seen repair
stations that place voluntary processes in their repair station
manual or their quality manual. I recommend against doing that.
If you place voluntary processes in your repair station
manual or your quality manual, then you run the risk that the
local FSDO may wish to enforce those processes. The FAA has

What if the aircraft is not ready?
Sometimes the customer wants to take the aircraft back before
the work is complete. The customer may need to operate the aircraft immediately, or the customer may be moving the aircraft to
another facility for other work. This can pose a problem if your
work is incomplete when the customer wants to take the aircraft.
A repair station can approve its work on an aircraft for return
to service even though the aircraft itself might not be airworthy.
But if the work itself is incomplete, then the required maintenance record should indicate the state of completion (or lack of
completion). Here are just a few tips for situations like this.
* Slow down. When the customer wants his or her aircraft,
he or she usually wants it now. There is a tendency to
rush in order to meet the customer's demands. But this is
exactly the time that you don't want to rush.
* Use a written process. Situations like this are often rushed
even when you try to slow them down. Developing and
using a special checklist for situations like this makes it
more likely that you will remember to complete all of the
important details.
* Check your agreement with the customer. If there is a
written agreement related to the work, then check it to see
if it describes a process for a situation like this.
* Check your paperwork to make sure you are not asserting an inaccurate airworthiness condition. Often, repair
stations use boilerplate language that covers 99 percent
of the transactions. But in an unusual transaction like
this, the boilerplate might be inaccurate. If parts of your
boilerplate are inaccurate, then cross them out. Don't let
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avionics news

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2015

Avionics News May 2015

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