The “trick,” if you want to call it that, to regulatory compliance is to read the rule. Every time, in every case, for every issue or question: Start with “What does the rule say?”
Each month in its member newsletter, the Aeronautical Repair Station Association (ARSA) produces a quick, simple training sheet focusing on a specific section of Title 14 of the Code of Federal Regulaitons (14 CFR). A while back there was one question, regarding §145.213:
True or False: A certificated repair station must inspect each article for which it has completed work to determine whether the entire article is airworthy before it can be approved for return to service.
FALSE! A certificated repair station must inspect each article on which it has performed maintenance, preventive maintenance or alterations before approving that article for return to service (§145.213(a)); but the approval for return to service is only for the work performed (§§145.213(b) and 43.9(a)(4)).
Considering the question, one member commented: “[Question 4] is a trick question and most people will say ‘true,’ but we know different! I say trick question, but what I really mean is it makes you read what the rule really says.”
Isn’t that interesting? A “trick” question is simply one where you have to read the rule, understand it and apply it in the real world. This is a simple truth: Regulatory compliance starts and ends with understanding the regulations.
While this example comes from the U.S., it applies across the aviation world. Going a step further: Truly knowing the rules means taking an active part in developing (or rehabilitating) them. Regulatory agencies serve many masters—elected officials, internal politics, certificate holders and the general public—and they won’t understand your needs without help.
ARSA works in this service every day, I’m proud to say. For those out there who want to get active, I invite you to join us at the 2017 Strategic Leadership Conference in Washington on Oct. 18-19 (see arsa.org/slc-2017). Come for the chance to “engage for effect.”
Brett Levanto is vice president of operations at Obadal, Filler, MacLeod & Klein. He provides strategic and logistical support for the Aeronautical Repair Station Association.