Parts and Traceability

Parts and Traceability

Note: An encounter with a Regulator Inspector prompted me to post this!

Undocumented Part Flow

I just recently dealt with a customer that was having problems with authenticating aircraft parts to the satisfaction of the regulator. It seems that parts need to have “type design” authentication. What is “type design” authentication? I started by going to the Canadian Aviation Regulation, CAR 571 Appendix H. “Part Identification: Verify that the part has certification or sufficient documentation, or both as applicable, to ascertain that it is a genuine part (i.e. nomenclature, part number, serial number, time in service) and that the part corresponds to that documentation.” 

The key to authenticating a part is the term “genuine part.” In order to have a genuine part we need to know what authority deems a part genuine. The standard for aircraft parts comes from the aircraft manufacturer. 

Obviously parts directly from the Original Equipment Manufacturer, OEM, itself will have “Traceability” to the genuine standard. The problem comes in when parts are not from the OEM. These parts must be evaluated against OEM requirements. “Using all available information, conduct an inspection of the part in accordance with the instructions for continued airworthiness or available type design data, or with both as applicable, for the part. It may be necessary to evaluate the part by comparison with a known authentic part. The evaluation process may require the use of hardness tests to determine heat treatment of the material. Procedures may be required to determine various material processes that may have been conducted on the material such as shot peening. Test all primary structural parts to determine that they are of the same material and in the same material condition as the type design product, either by comparison with the type design data (e.g. drawings) or by conducting comparison tests with a known authentic part.” In this the type design standard is the OEM specifications on the part from the drawing, material specs, and design requirements. Now the installer must evaluate, (i.e. hardness test, metallurgical tests, coating inspection...etc.) Traceability comes form the OEM specification. It is the job of the installer to provide objective evidence that the specifications are directly from the OEM. Parts that have no certification documentation can be evaluated to a known authentic part. The known authentic part become the standard and must be traceable to the OEM. ALL supporting documentation for the known authentic part must be supplied with the part for traceability purposes. 

Aircraft Parts 

In the photo to the right, ALL the parts pictured meet form, Fit and function requirements but, There is one part that definitely should NOT be installed into the aircraft. The “airworthiness” requirement goes beyond fit. The part must “authenticated” for materials, finishes and special processes. Traceability for all these parameters to the OEM is essential. In case you missed it, one of the parts is made of wood. Hardly suitable for aircraft use. 

The Traceability connection between parts & the OEM. 

Yes, parts can fit and seem to work. The problem arises as to function over time and with the stresses of the application of the part. In all this it is essential to have the Documentation that supports ALL the characteristics that "authenticate" the part. The key is the STANDARD that has been established by the OEM. The documentation for the parts must be traceable  to that standard. This may require a company to inspect and test the part to verify traceable specifications. 



Your thoughts.........

We just fired the Accountable Executive...

We just fired the Accountable Executive...

NOTE: This post is from one of our frequent contributors to this blog, "Birdseye59604."

An owner or family member maybe appointed as the Accountable Executive (AE) and never change. Or, in a large organization the AE may be at the mercy of the Board of Directors or the Mayor and be fired for any reason at any time.  

An AE is the person in the enterprise who gets to "draw the line."  An AE draws  the line of the Safety Policy, Non-Punitive Reporting Policy, Human Resources, Financial Resources and the timeline for reports submitted to AE. 

At first glance some may find it to be a trivial event that a person who is not involved in the day to day operation is being fired on the spot. However, since the AE is the organizational authority  on drawing the line, an enterprise may end up in a a state of disorder due to absence of nonrecognition of authority. 

An AE may not be involved in the daily operation as they decide where to draw the line. 

An un-schedule and emotionally driven firing of an AE is different than a planned and organized change. With a scheduled removal of an AE there is a continuous line of authority to ensure an enterprise is conforming to regulatory compliance. 

After firing of an AE without a replacement the SMS Management Review may struggle to establish accountability to regulatory conformance and to document an SMS with continuing adequacy and effectiveness. Further, an internal Quality Assurance Program may establish organizational regularly non-compliance with their audits of processes, inspections and training of all personnel.

Just a short deviation from the drawn line may cause major events.

An enterprise without an AE is applying the wrong tool in the toolbox.

Your thoughts........

BirdsEye59604

A Plan for the Corrective Action Plans (CAP) and Processes

A Plan for the Corrective Action Plans (CAP) and Processes

NOTE: This post is from one of our frequent contributors to this blog, "Birdseye59604."

An Enterprise without a Plan for the Corrective Action Plans (CAP) is being lost in a Maze of Corrective Options.  The Maze of Corrective Options is a place of traditions and familiar operations, and it is a "safe place" to make decisions. It's a maze because for each decision made there is a fork in the road without a direction sign. 

CAPs are not just for making changes after surveillance findings of non-regulatory compliance, but also as internal corrections of processes that are giving non-desired outputs. There are generally speaking two types of CAPs. One is an immediate fix and the other is a long term repair. A fix considers the malfunction but not the cause, while a repair considers the problem in addition to the the process which lead to the malfunction.  

A fix is for the malfunction, while a repair considers malfunction in addition to the malfunction.

A fix is compatible to dumping a task on someone, while a repair is a delegation of organizational authority and responsibility to repair processes.  An Enterprise that has a clear commitments and directions of processes  when arriving the  fork in the road,  is avoiding the continuous dumping of  fixes  on whoever is most convenient available.  

A Process repair must be tailored to the vehicle it is intended to serve.

It might be tempting for an Enterprise to stay within the safety of an established process and fixing malfunctions.  By taking this approach  there is no one in the organization who accepts accountability and there is always  someone else who can be blamed when things go wrong. 

There are times when a CAP repair may not be effective. However, an Enterprise with a Plan for the Corrective Action Plans (CAP) has a map of how to make it back to fork in the road where  they took the wrong turn. 

Your thoughts.......

BirdsEye59604  

Best Practice (BP) and Customer Service

Best Practice (BP) and Customer Service

NOTE: This post is from one of our frequent contributors to this blog, "Birdseye59604."

It has been said that Best Practice (BP) is to apply better practices of quality in customer service. In someway that is correct, since operating by meeting minimum regulatory requirement only is not intended to produce satisfactory customer service. 

On that day when an enterprise was issued an aviation operating certificate, they were regulatory compliant. This was a static mode, where there had been no movements of aircraft or operation of the airport. Maintaining this status quo of regulatory compliance as it was at the issuance of an operation certificate is neither practical nor the intent of the certificate. 

Best Practice is to establish customer friendly Processes. 

An enterprise; when operating airplanes or airports must establish processes that is conforming to regulatory compliance. Establishing these operational processes is to go beyond what regulation requires. This is Best Practice; It's to establish processes above and beyond what the regulation requires and to maintain operational processes which are conforming to regulatory compliance.  

Is an airline required by regulations to employ baggage handlers and ground crews? However, as ground crews tasks are related to aircraft operations  they must be trained in operational procedures, and be qualified to advise the Captain.  A "thumbs up" when nose wheel is disconnected doesn't just say "have a safe trip". 

When going "where birds don't fly" processes are conforming to regularoty requirements. Flooded airports is regulatory compliant by NOTAM closed. 

An airport may be regulatory compliant by issuing a NOTAM of airport closed and an airline may be regulatory compliant by grounding airplanes. However, by doing that, there is lack of customer service. 

Best Practice (BP) is what an Enterprise does to ensure operational processes conform to regulatory compliance by developing and maintaining processes of regulatory requirements.

Your thoughts..........

BirdsEye59604