The FAA’s plan to use its new, data-driven, surveillance system to reduce audits should not encounter much resistance from airlines and repair stations, which spend too much time having different audit teams review the same information. But for members of those audit teams, the shift may not be so smooth—and the agency’s top executives know it.
“The hardest thing about this isn’t the mechanics or logistics,” says John Hickey, FAA’s deputy associate administrator of aviation safety. “It’s going to be cultural.”
The Safety Assurance System (SAS), which debuted last June in the certificate management office (CMO) responsible for Delta Air Lines, is designed to standardize risk management by allowing FAA to collect and share audit data internally. It serves as the safety assurance part of FAA’s internal safety management system (SMS) for its Flight Standards service, complementing the other three parts of an SMS: safety policy, safety risk management and safety promotion.
SAS is becoming the primary surveillance system for airlines flying under Part 121, operators covered by Part 135, and Part 145 repair stations. Eventually, it will be rolled out to cover more certificate holders. FAA manages more than 7,300 certificates, including 4,000 repair stations. An internal FAA tool, SAS imposes no new requirements on industry.
SAS is the key plank in FAA’s platform to boost risk-assessment while cutting the number of audits. Yet fewer audits mean less hands-on work for FAA staffers whose job it is to ensure certificate holders are complying with the regulations.
“A principal [inspector] of a CMO for an airline takes that [role] very personally,” Hickey told MRO executives at the Aeronautical Repair Station Association’s annual meeting in March. “If something goes wrong, they hold themselves accountable.”
Under the current system, a repair station with 10 airline customers can expect regular audits from at least 11 FAA teams—one from each CMO that oversees its customers, and one from the FAA office that oversees the repair station. SAS aims to change that by allowing results from one audit to be shared, avoiding duplication of effort that serves no purpose.
“Audits are good, but you can have too much of a good thing,” Hickey told the MRO executives. “The number of audits that you’re being asked to handle is going up, with no risk-based data decision-making to support safety or efficiency. We can’t have that.”
The system is designed to help inspectors collect information, spot trends and focus surveillance on the areas that need it most. Data collection can be supplemented by operators, who will be able to enter their own data into the system via a web portal. The objective: Combine FAA-collected observations with information provided by certificate holders such as through established Aviation Safety Action Program initiatives, to help pinpoint where additional surveillance is needed.
“We will focus on risk-based inspections supported by data, in lieu of random or calendar-based inspections,” Hickey says. “The end-game here is to put an end to an auditing philosophy that is based on the principle that ‘we do it this way because we’ve always done it this way.’ Why do I need to do inspections of five critical performance elements where I’ve never seen a finding from this airline in 10 years? We’re now going to have the authority and the orders to support the inspections that made those decisions.”
Long-term, Hickey says SAS should allow inspectors’ work to go further, which could have particular significance for repair stations, which work for multiple certificate holders. But getting there will require inspectors to trust in the system—which means placing trust in each other.
“When a CMO in Texas has aircraft being maintained in Oklahoma, we are going to have to get them to understand that they may not be the ones who go up there and audit the repair station,” he says. “It may be a locally based group, or a combination team, with representation from” the airline’s primary oversight office.
Hickey is confident that heeding lessons learned from previous efforts to revamp oversight will help ensure a smooth introduction for SAS. When the Air Transportation Oversight System was rolled out in the late 1990s, for example, the agency didn’t provide adequate training for its inspector workforce.
“We created the system and simply threw it out in the field,” Hickey recalls. “It took at least 10 years for FSDOs to come to grips with it. We’re not making the same mistake with SAS.”
FAA plans to roll SAS out to its CMOs and Flight Standards District Offices (FSDOs)—about 100 field offices in all. It is up and running in about 30 offices, says Steve Douglas, manager of FAA’s Aircraft Maintenance Division.
Aside from the reduction in audits, the shift should be all but transparent to industry, Douglas says. FAA offices that roll out SAS are supposed to send letters to the certificate holders they manage, informing them of the change and the availability of the new web portal.
The portal’s use will be woven into guidance to help industry comply with certain regulations. First up: allowing airlines to use it to submit updated lists of third-party maintenance vendors, which is part of the agency’s recently introduced contract maintenance rule. FAA says data formats will be standardized and simple, allowing industry to use familiar tools like Microsoft Excel to submit data to the agency.
The FAA’s ambitions go beyond streamlining its own processes. Douglas says the agency has had “early discussions” with European Aviation Safety Agency officials about working together to reduce audits among commonly certified repair stations. FAA has presented several papers to international conferences on the issue, notably at February’s International Civil Aviation Organization’s High-Level Safety Conference.
FAA STARTING PART 147 UPDATE
The long-needed revamping of FAA’s Part 147, the rules governing U.S. aircraft maintenance technician (AMT) schools, is underway, says the FAA’s Steve Douglas.
Part 147 lays out the minimum curriculum for AMT schools, such as how many instructional hours must be spent in specific areas. Updating the standards, largely untouched since 1970, is now “a priority” within the agency’s Fight Standards group and drafting of the proposed rule has started.
Douglas says one change in the new rule will be moving the curriculum requirements into Operations Specifications, where they can be changed quickly, as opposed to leaving them in the regulation itself, which is harder to change.
Outdated curriculum requirements are one of the main complaints industry has about the current Part 147.