Avionics News January 2012 - 14

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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P E R I V I C E P R ES I D E N T O F G OV E R N M E N T & I N D U ST RY A F FA I RS FO R A EA

Say What You Do, Do What You Say T

he basic principle of a quality system is your manual Right before the AEA Central Regional Meeting in Kansas should describe your process, and your processes should City last November, the FAA kicked off the Part 23 aviation rulebe performed according to your manual. And, in the case making committee to modernize the aircraft certification regulaof repair stations, your processes (manual) must meet the stantions. The meeting was represented by NAAs from around the dards of the regulations. The more I work with AEA members, world, airframe manufacturers, lots of FAA staff and, of course, the more I think this is an area where we can do better; partly a well-represented AEA membership. One of the recommendabecause our manuals don’t reflect our business, partly because tions presented was the separation of “safety” standards from the inspector’s guidance (instructions) are analog, and partly be“design” standards. On the second day, this concept was further cause we don’t use our manuals for what they were envisioned to do. As I write this month’s column, it is It was the beginning of this century when passionate FAA Thanksgiving week in the U.S. I find leadership tried to modernize the repair station regulations, myself, as I have for the past four years, only to be sabotaged by 418 pages of instructions spending Thanksgiving week overseas working with European members and prescribing what the 22 pages of the regulations mean. attending a number of European Aviation Safety Agency meetings in Cologne, Germany. The view from Germany offers a robust quality system supported, as attendees described that the basic safety standards mandated by local national aviation authorities and incorporated (the Part 23 regulations) are not poorly written and generally not into EASA regulations. Some in the U.S. might call it an ISO the problem. Rather, the design standards described in the guid(international standards organization), or AS style quality sysance, advisory and policy materials were overly prescriptive and tems. While the vision of the 2001 Federal Aviation Administracost prohibitive for new entrants into the aircraft manufacturing tion rewrite of the repair station regulations was to incorporate industry or supported new and novel technologies presented many of the European principles of quality systems, the FAA’s by the avionics industry. The ARC was created with passion analog instructional guidance to inspectors do not easily allow from the FAA leadership and offers promise for improvements them. Generally speaking, the prescriptive approach to repair stato product and light aircraft certification in the next century. Of tion oversight caught in the FAA order 8900.1 and taught as the course, it takes half a decade for rulemaking to run from idea to “only” acceptable means to inspectors at the FAA’s academy in print, so we likely won’t see the results of this effort until nearly Oklahoma City, Okla., simply isn’t compatible with the perfor2020. mance-based system so very well demonstrated in Europe. It was the beginning of this century when passionate FAA
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january

2012

Avionics News January 2012

Table of Contents for the Digital Edition of Avionics News January 2012