Avionics News August 2012 - 65

THE VIEW FROM WASHINGTON
Continued from page 15

the FAA order is explicit and prescriptive. There also appears to be a philosophical shift in the purpose of the orders. In the days of FAA Order 8300.10, the policy told the inspector the limitations. Today, most of the newer policies tell the inspector what he or she must do. The growth in the prescriptive nature of the FAA order shows an alarming direction. It reminds me of a scene in the movie “A Few Good Men.” Capt. Ross, in questioning Cpl. Barnes, makes the statement “I’m a Marine. Is there no book, no manual or pamphlet, no set of orders or regulations that lets me know that, as a Marine, one of my duties is to perform code reds?” This direction from headquarters on prescriptive directions also raises a warning from the same movie. Lt. Kaffee, in cross examining Cpl. Barnes, asked, “Would you turn to the page in this book that says where the mess hall is, please?” If you remember, the mess hall isn’t in the book, and yet Cpl. Barnes had somehow found his way to the mess hall and had “three squares a day.” Without guidance and direction from the leadership in Washington, D.C., I’m concerned the FAA order will continue to be so prescriptive that the FAA employees may need instructions on where to find the restaurants so they, too, can have three squares a day. The FAA hires professionals. The order must direct employees what not to do, not what to do every minute of the day. The prescriptive nature of the FAA orders issued by headquarters is a major factor in the lack of consistency when applying the regulations. The Industry When I shift to the industry, I’m reminded of the passion industry has voiced for standardization. Some shops get to do something other shops don’t. I’m also reminded of the frustration voiced by the membership during the years we operated the ADEOS program. I inherited the program when I joined the Aircraft Electronics Association staff 12 years ago. The issue was the promised discounts didn’t always materialize when the specific projects were actually estimated. Why wasn’t the cost for these projects meeting the promised, consistent (there’s that word again) pricing? Well, simply put, the projects weren’t standardized. Sure, there was

commonality in the equipment being installed, but the aircraft were different. Or, the equipment and aircraft were common, but the installation location was different. Or, maybe the equipment, aircraft and location were the same, but the interface was different. In order to receive consistent conformity with the standard, the design and operation of a repair station must be identical to the model we are judging consistency against. Each repair station is unique and is responsible to ensure its design and operation conform to the standard. It also is the responsibility of the repair station to be able to explain the standard and how the repair station conforms to the standard. Finally, the repair station must stand its ground. Often, the repair station business requires expanding the business model. These expanding businesses require the repair station to move beyond the norm, to move beyond the comfort zone of the standard. Remember, the standard is developed retroactively to address existing businesses, not proactively based on the best guess of what industry might look like in five years. When a repair station pursues new business on the fringe of the regulations, it must proactively work with the FAA to develop the waivers or exceptions to the regulatory standard so that it may conform to the standard. Recently, I attended a meeting with a dozen of the best chief inspectors in the general aviation repair-station industry to discuss what they called standardization. When asked why they didn’t defend their ground, they all stated time and repercussions. They had to pick their battles. I understand and appreciate the issues, but I also warn that it is a slippery slope. When it’s easier to capitulate than conform to the standard, you commit yourself to two changes: the one immediately under consideration and the corrective action when the next inspector finds the discrepancy. We all want standardization and a consistent application of standards. But, there are two significant deterrents to this goal. First, the agency, in its attempt to promote standardization, has created a barrier to consistency; this can and should be corrected. Second, we, as an industry, are not standard. It is exceptionally difficult for an auditor to audit something that is drawn outside of the lines. Today’s economy requires our businesses continue to be creative, develop new processes, find new customers and, in general, draw outside the lines. Together, we must continue to work toward a consistent conformity to the standard. q
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Avionics News August 2012

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