During the past six months, the Airlines for America Engineering, Maintenance and Materiel Council (EMMC) has refocused its energies on addressing a smaller population of key process improvements that have a high impact on all airlines. One of the major ones involves working with the FAA on managing airworthiness directive (AD) exceptions.
As background, in August 2011, the FAA released the final report for the Airworthiness Directive Aviation Rulemaking Committee (AD ARC), which was the result of many months of effort among industry leaders to refine the AD process.
The overarching goal of the committee was to identify enhanced procedures for the development of AD requirements and technical instructions, with the expectation that safety aspects would be improved as well. The recommendations from this committee yielded new or revised FAA and industry guidance, as well as the release of agency policy memoranda on specific AD process issues.
Since the release of the new guidance, the FAA, aircraft operators and OEMs have been working to implement these procedures within their businesses. Some of the more notable changes were the introduction of Required for Compliance (RC) elements into the service bulletin instructions authored by the OEMs, an enhanced lead airline process under ATA Spec 111 and best practices for operators to maintain AD compliance under Advisory Circular 20-176. The improvements are yielding better service bulletins and a reduced need for Alternative Methods of Compliance (AMOCs) to cover technical corrections within the OEM documentation. When required, AMOCs represent a cumbersome and inefficient use of valuable FAA, OEM and operator resources.
The benefits of the process improvements from the AD ARC will continue to take hold as new service bulletins are issued with the RC elements as standard protocol. However, the volume of AMOCs continues to be high, as operators are still implementing ADs that were not written under the new guidance. Recognizing that most of these enhancements are forward-looking, we continue to look for ways to apply the same methodology in reverse for the handling of minor -deviations to the ADs.
In the absence of RC elements within older bulletins, operators are obligated to pursue an AMOC for any variance to the specific language for all steps.
To enhance the management of AD exceptions, the EMMC is focused on using the current methodologies that were approved by the FAA through the AD ARC, and applying them to the management of variations that continue to be identified through incorporation of ADs. With Boeing as a key partner in developing its own internal procedures for risk assessment of incoming requests, we are collectively starting to see possibilities for a path forward to drive down the need for AMOCs. The mechanisms within the FAA and Boeing to implement the “RC assessments in reverse” are still being ironed out, but there is clear alignment on the opportunity to chip away even further on the high volume of AMOCs.
The AMOC reduction strategy is an example of where the EMMC continues to see opportunities with the FAA to identify business processes that can be streamlined to benefit operators and the agency, but also drive safer products for the industry as a whole. With the recent inclusion of safety management concepts into every part of the airline business, the collective energies of its partners can focus on the chances for safety improvements versus the commitment of resources to the sometimes cumbersome administrative aspects of existing processes.
Using the AD exception management process improvements as a template, we hope this will trigger similar enhancements elsewhere with the commitments of the FAA, operators and OEMs to optimize the business for safety and efficiency.