Bob Cook from the FAA will be retiring after this week. You may not know the name but you certainly know his work.
He has been involved in a tremendous amount of rulemaking and policy making efforts at the FAA. The one that sticks in my mind is 14 C.F.R. 21.137. Bob was part of the team tasked with coming up with a modern vision of quality assurance. It would have been very easy to create a subjective rule that was vague and made compliance difficult; instead, 14 C.F.R. 21.137 very clearly establishes objective criteria expected in a modern quality assurance system.
How did 14 C.F.R. 21.137 come into being? Bob once told me that they put together a wish list of quality system elements, and then he led a chopping block exercise in which they asked for each element (1) what safety value does it provide and (2) does the FAA really need to regulate this element? This exercise allowed them to remove many elements that were nice to have, but that were not necessary and therefore did not need to be part of the regulation. The result was a quality assurance regulation that serves as a model for the entire global industry. It is the sort of regulation that no one complains about – no one thinks it is overbearing and no one thinks it falls short of what it should address. That is a rare sort of regulation, indeed. This was the sort of reasonable approach to regulation that we always expected from Bob Cook.
Bob sent an email announcing his retirement. It read (in part):
To all those that I have worked with over this last 17 years in the FAA and 40+ in the aviation industry:
I will be retiring on June 23rd. I wish to thank each of you for helping to make my time at the FAA both enjoyable and rewarding. I have stated many times that this has been the best job I ever had, and I truly meant it. The managers and the management team I worked for (while being frustrating at times) provided me with every opportunity to learn and progress within the organization.
To those that I had the pleasure of working with on aviation issues I want to thank you for all the time, effort and concern you placed on the continuous improvement of quality within our industry. Your openness to share quality improvements and working, as an industry, through organizations such as the IAQG, AAQG, AIA, GAMA, and MARPA to establish quality standards and a quality system oversight processes that are used internationally, is one of the greatest achievements of which I had the pleasure to be involved.
* * *
After 40+ years of working in the aviation industry I expect it will be hard for me to just walk away so you may see me commenting on rulemaking as a concerned citizen. If you do, I hope to see a better response than “Thank you for your interest in aviation safety”. I will miss working with you on issues that makes our aviation industry the safest and most respected in the world.
* * *
Very Soon to be a Private Citizen
We will miss his attention to detail, his willingness to listen, and his commitment to safety.
If anyone wants to send Bob a thank-you or goodbye message, then he is still in the office this week, and his email is Robert.firstname.lastname@example.org.
MARPA is extremely pleased to announce that Peter Requa, Senior Director of Supply Chain Management-Technical Operations for Southwest Airlines, will serve as the Keynote Speaker for the 2017 MARPA Annual Conference in Orlando, Florida from October 25th -26th at the B Resort & Spa.
Peter has responsibility for Strategic Sourcing teams for purchase of maintenance materials and overhaul services for engines, component and airframe. He is also responsible for Material Planning, Technical Purchasing, Repair Administration, and Inventory Management in support of Southwest’s 700+ aircraft.
Peter began his career with United Airlines in 1988 at the San Francisco Maintenance Operations Center where he last held the position of Manager-Capital Planning. In 1998 he joined Reno Air, and following the acquisition by American Airlines in 2000, joined AirTran Airways as Director of Operations Administration overseeing Material Planning, Operations Financial Planning, Stores, Repair Administration, and Ground Support Equipment Maintenance. Following the acquisition of AirTran airways he made the transition to Southwest Airlines in 2011.
In its 46th year of service, Dallas-based Southwest Airlines continues to differentiate itself from other air carriers with exemplary Customer Service delivered by more than 54,000 Employees to more than 100 million Customers annually. Southwest proudly operates a network of 101 destinations in the United States and nine additional countries with more than 3,900 departures a day during peak travel season.
Southwest Airlines is the world’s largest operator of the Boeing 737, was the launch customer of the 737-300, 737-500, and -700, and will be the launch customer of the 737 MAX 7.
Southwest Airlines is one of many air carriers attending the MARPA Conference. The 2017 MARPA Annual Conference provides an excellent opportunity for our members to meet and network with their customers. It is also an opportunity to continue the ongoing discussion about the benefits and value of PMA parts. More Conference information is available online here.
A consultant recently told me that his client is planning to produce parts under NASM22529. He asked for advice about the process for showing compliance to get a PMA.
NASM22529 is an AIA/ NAS standard. It replaced a milspec of the same number that was retired in 1996. As an AIA (NAS) specification, it is recognized as the sort of industry specification that supports ‘standard parts’ under the FAA’s interpretation of the term.
Standards parts can be manufactured and sold without a PMA. The regulatory authority for this can be found at 14 C.F.R. § 21.9(a)(3). Therefore a PMA is not necessary in order to produce standard parts intended to be consumed in civil aviation.
While it is not necessary to seek FAA approval to manufacture a standard part,it is nonetheless possible to get a PMA for a standard part, and in some cases (like fasteners) it can also be possible to obtain a TSOA for a standard part.
There are a number of reasons why someone might seek to obtain FAA approval for a standard part. This sort of FAA approval can be valuable for marketing purposes.
If you seek FAA approval for a part, then the design of the part must be shown to meet the appropriate FAA standards, and the production quality assurance system must be developed to meet FAA requirements.
The same consultant also asked whether AS9100 certification satisfies all or most of the PMA requirements? The AS9100 series of specifications were specifically designed to support compliance to aviation regulatory standards, but compliance with AS9100 should not be confused with compliance to FAA regulations. The answer to this question can depend on the implementation of the AS9100 system.
AS9100 will typically satisfy requirements under 14 C.F.R. § 21.137, as well as certain other requirements, but it may does not satisfy all FAA approval requirements (A well-developed AS9100 system can be developed to provide management assurance of compliance with all of the relevant FAA requirements but it can also be developed to omit some of them).
The design side of the manufacturing process is a process that is particularly susceptible to a finding that the AS9100 system is not adequate, alone, to ensure compliance to FAA regulations.
Looking to learn more about PMAs? You may want to consider attending the MARPA Conference in Orlando on October 25-26, 2017. The FAA has confirmed that they will be teaching a “PMA 101” workshop as part of the Conference. You can find out more at http://pmaparts.org/annualconference/about.shtml
Are manufacturers required to drug test their receiving inspectors? A recent FAA legal interpretation explains that receiving inspectors typically are not subject to the DOT drug and alcohol testing rules.
The FAA has issued a legal interpretation that confirms that receiving inspectors who are receiving articles for stock are not performing maintenance activities, and therefore they are not among the personnel who are required to be subject to DOT-regulated drug and alcohol testing.
This effort was spearheaded by our industry colleagues at ARSA, but the final request for interpretation was jointly filed by 15 organizations (including MARPA).
The root of the issue is that the Part 120 requirements require air carriers to ensure that their maintenance subcontractors are tested under the drug and alcohol rules. This requirement is applied to those who perform aircraft maintenance duties – but those who do not perform such duties are not subject to the testing requirement. Inspection is described as a species of maintenance in the FAA’s definitions.
So what about manufacturers who produce in support of an air carrier’s maintenance efforts? Are their receiving inspectors performing maintenance when they inspect incoming articles?
The FAA explained:
14 CFR part 43 applies to the performance of maintenance and preventative maintenance. Sections 43.9 and 43.11 establish recordkeeping requirements for tasks associated with maintenance and preventative maintenance. These recordkeeping requirements have never been applied to tasks associated with receiving articles for stock. Individuals who perform receiving tasks ensure that there is no visible damage to the packaging or the enclosed items, and that the articles were obtained from an approved or acceptable source. Persons performing these tasks compare part numbers, serial numbers, quantity, etc. with the purchase order and confirm that the items match the purchase order and that they are not damaged. These tasks are not maintenance or preventative maintenance activities. Therefore, employees receiving items for stock are not safety sensitive employees under part 120 and should not be included in the pool of employees subject to drug and alcohol testing.