Avionics News September 2022 - 21

THE VIEW FROM WASHINGTON
Continued from page 17
was military, they may not be fluent in the regulations. If
their background was in the airline industry, they may not
be aware of the differences between airline maintenance
and general aviation maintenance. Performing an informal
needs assessment may help you show that your repair
station is (1) in compliance with the regulations and (2) a
low-risk operation.
(2) Company manuals, policies, procedures, and
practices, including quality control processes,
particularly those associated with ensuring
compliance with maintenance (including
inspection), preventative maintenance, and
alteration procedures established to show
compliance with 14 CFR Part 145.
This is an essential element. Our manuals, policies,
procedures, and practices define how the repair station
complies with the regulatory requirements and assures
airworthiness. Typically, a repair station takes a hands-off
approach where we " hope " the new inspector takes the
time and initiative to read and understand our programs. I
suggest this is unrealistic! Just like the value of requiring
new employees to receive indoctrination on your repair
station's operations, taking the time to introduce your new
inspector to your operations may help to show compliance
and risk management.
(3) Department of Transportation hazardous material
requirements, general Occupational Safety and Health
Administration, Environmental Protection Agency,
and other local, state, and federal laws requiring
training for different categories of employees.
This is an excellent reminder that, although the surveyor/
inspector may be a government employee, they are not
exempt from workplace OSHA training requirements.
The repair station is an industrial workplace; as such, any
visitor has basic requirements to step onto the hangar or
shop. But an inspector who is allowed to visit unescorted
must be fully trained and documented in all aspects of
workplace safety.
(4) Maintenance human factors. The FAA concurs
with European authorities in that human factors
training related to maintenance practices would
provide an additional margin of safety to the repair
industry. A human factors training program should be
related to maintenance practices where possible.
How many errors are caused by a surveyor's visit to
your facility? I know this sounds counterintuitive, but the
immediate effect of having a surveyor/inspector on-site
is often overlooked. The impact that the inspector's
personality, approach and conversation can, and often does,
have a negative effect on the performance of maintenance.
Addressing the unintended consequences of a surveyance
on the quality of the work performed is an important topic
to have with a new inspector who may not readily identify
their impact.
(5) Computer systems and software, as applicable
to the repair station's maintenance (including
inspection), preventative maintenance, and alteration
systems and procedures.
The modern repair station is digitally connected. Take
the time to show the new inspector your Internet of Things,
or IoT. Showing how your computer system connects
shipping, receiving, processing data management and
recordkeeping helps to show that you are controlling the
computer, managing the resource, and using the efficiency
of the network to more efficiently and effectively manage
the repair station processes.
(6) Facility security.
Every repair station has a facility security program
(49 CFR Part 1554, Aircraft Repair Station Security).
Some are supplemented by an airport security program.
Nonetheless, the government employee is not exempt
from complying with your security program. Are your
doors open to all visitors without restrictions? Do you
require visitors to check in with a receptionist? Do you
require all visitors to be escorted? As with the other
topics, taking the time to train (and document the training)
with your new surveyor/inspector will help minimize
security escapes in the future, and more importantly, show
a professionally run business.
The purpose of the repair station's initial training
program is to ensure new employees performing
maintenance are capable of performing their assigned tasks.
Is it reasonable that taking the time to get to know your
new inspector and introduce your inspector to the repair
station's operations, policies, procedures, and practices
could help them perform their assigned tasks in an efficient
and effective manner?
Is it reasonable that, just as a repair station benefits
from an effective employee indoctrination training,
the repair station could benefit from offering the same
familiarization training to your surveyor/inspector so
they thoroughly understand your system before they
attempt to audit and oversee your operation? q
AVIONICS NEWS * SEPTEMBER 2022 21
Avionics News September 2022

Table of Contents for the Digital Edition of Avionics News September 2022
