International Team Developing Safety Management Tools to Facilitate SMS/SSP Implementation (SM-ICG)

The world’s authorities are working together to harmonize the way that they develop and implement state safety programs. This will lead to a better worldwide understanding of Safety Management Systems (SMS), and it is resulting in tools meant to make it easier for companies to implement SMS programs, and for national aviation authorities to develop and run their state safety programs.  This is tremendously important for the next generation of aviation safety.

On the third day of the EASA/FAA International Safety Conference in Cologne, a panel discussed the activities of the Safety Management International Collaboration Group (SM-ICG). Andrew Larsen is the SM-ICG Chair, and he also works for Transport Canada. The SM-ICG was created to promote a common global understanding of safety management principles, and to facilitate their application across the international aviation community.

Amer Younassi, who manages the FAA’s Aircraft Certification International Division, was one of the SM-ICG founders. He intended the group to facilitate collaboration on the development of safety management and state safety programs, and he is particularly proud of the fact that the SM-ICG has grown to reflect a truly international community of experts.

Safety management is still new to the aviation community, and so it is critical to share the lessons that are being learned in order to facilitate success across the international community. The SM-ICG allows collaboration on the development of a common understanding of both SMS and state safety programs (SSP).

SM-ICG was founded in 2009 by FAA, EASA and TCCA, and SM-ICG has grown to a membership of 18 different regulatory authorities. ICAO serves as both an observer and an advisor to the group.

SM-ICG has been working to standardize terminology associated with SMS and SSPs, so that we can discuss SMS internationally without getting confused because we use the same terms to mean different things. Getting authorities to agree to common definitions has been a real success in the effort to harmonize international understanding of safety management. SM-ICG has also produced tools for safety performance measurement, both at the SMS level and at the state safety program level. Many authorities are using the SM-ICG tool as their primary tool for evaluating SMS programs, and the FAA used it to assess and endorse the NAS 9927 SMS standard. SM-ICG documents have been important to the development of FAA SMS guidance like FAA Order 8000.369 (Safety Management Systems) and FAA Order 8040.4 (Safety Risk Management Policy).

They are working on a number of projects, including ways to measure performance in a state safety program, hazard taxonomy examples, safety culture self-assessment tools, and a discussion of the role of the safety manager in the SMS program (ranging from a discussion of what is in their scope to recommendations about ways for the safety manager to communicate).

Younassi has found that the SM-ICG has been successful in developing tools that reflect an international experience with SMS and SSPs. He has found the SM-ICG tools to be useful to the regulators, and several of them are actively used by the FAA. These include SMS Inspector Competency Guidance, which has assisted the FAA in both identifying qualified FAA candidates and also in training the FAA inspector workforce. In fact, the FAA has developed job descriptions based on SMS Inspector Competency Guidance, and other countries are using this guidance to develop syllabi for inspector training.

Use of the SM-ICG tools is voluntary. The SM-ICG feels that successful SMSs and SSPs need to be customized to the implementers. But the tools being developed are meant to make implementation easier.

ASA asked about how SM-ICG can support smaller companies to ensre that SMS remains scalable. SM-ICG has recognized that there are very small entities in the industry, and this has always been on the mind of the participants. To support scalability, they’ve developed some tools with small businesses in mind, but Younassi admits that there are other tools that should be developed to specifically support the small business community. Larsen feels that one way that SM-ICG can assist smaller entities is to provide examples in their tools that focus on smaller SMS implementations.

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ASA Presents on Technology at Int’l Safety Meeting

ASA Director Brent Webb was a panelist at the 2019 EASA/FAA International Safety Conference, discussing the technology challenges (and solutions) facing the aviation industry.
Webb joined a distinguished panel of:
·Rachel Daeschler – Acting Certification Director, EASA
·Earl Lawrence – Executive Director, Aircraft Certification, FAA
·Francois Duclos – A350 and RPAS Chief Airworthiness Engineer, Airbus, and
·Lionel Wallace – Head of Airworthiness, Lilium
Webb discussed what he sees as the five pillars of digital transformation:
·Big data
·Digital twins
·Internet of things
·Digital certificates
·Blockchain
Webb discussed the ways we can use expanding developing technologies.  He explained that by using artificial intelligence and similar technologies, we will be able to capture the tribal knowledge of a retiring workforce to maintain and grow our knowledge base as the older generation retires.  Connecting devices through the internet of things can lead to better tracking of everything.  For example, we can track tools through RFID and ensure everything is put away (pr at least, not left in an aircraft).
Webb explained that there are high expectations from blockchain.  Blockchain is a tool that could solve a number of our problems; but the movement to a decentralized information sharing will take some political will, as well, because society is not used to decentralized information sharing.

Relevant Language from EASA’s Supplier Control Mechanisms

In an earlier post, we reported on EASA’s formal endorsement of FAA Advisory Circular (AC) 00-56 and the ASA-100 quality standard (endorsing them as an acceptable mechanism for ensuring that a supplier’s quality assurance system meets EASA expectations).

These two documents form an important part of EASA’s recent publication on supplier control mechanisms.

Some of the readers have asked me to provide the relevant language of EASA’s endorsement; they’ve noted that the entire Decision includes six annexes in addition to the actual EASA decision (and is thus too long to navigate).   In response to these inquiries, I have put together a short (five page) set of excerpts that show the supplier control implementation in the recently-published EASA AMCs and GMs.

You can find a copy of the excerpts here, at this link: ED Decision 2019-009-R – Supplier Control Mechanisms Added to European Law (excerpts).

In summary:

  • EASA AMC1 145.A.42(b)(i) provides that the procedures for the acceptance of components, standard parts and materials should include supplier evaluation procedures;
  • EASA GM2 145.A.42(b)(i) explains what a supplier is, in order to assess who must be controlled (find out more in our earlier article on supplier definition);
  • EASA GM3 145.A.42(b)(i) describes the elements that should be considered when evaluating a supplier’s quality system, and it explains that suppliers accredited to ASA-100 an AC 00-56 are acceptable;

 

Shipping an “As Removed” Oxygen Generator

Recently, an Association member asked us whether one is allowed to ship “As Removed” oxygen generators.

An “As Removed” oxygen generator can be expended or unexpended.  A critical distinction for oxygen generators is whether they have been expended (this is the real question – not whether they are “as removed”).  An expended oxygen generator is typically forbidden from transportation on an aircraft but is permitted to be shipped by highway, rail or maritime transportation.  49 C.F.R. § 173.168(f)(2)(ii).

Oxygen generator typically have a manufacturer’s expiration date printed on them.  It is also illegal to ship an oxygen generator by air after the manufacturer’s expiration date. 49 C.F.R. § 173.168(f)(2)(i).

In the United States, an unexpended oxygen generator (assuming it was unused, undamaged, and prior to the manufacturer’s expiration date) would be eligible for transport by air consistent with section 173.168.  This is true even when the oxygen generator has been removed from an aircraft.  A similar rule applies to international transportation subject to the ICAO rules – the ICAO standards forbid transport by air of oxygen generator that are unserviceable, have been expended (“used”) or have passed the manufacturer’s expiration date.  ICAO Technical Instructions for the Safe Transport of Dangerous Goods by Air, Special Condition A111.

Even when an oxygen generator is permitted to be shipped by air, it is typically limited to ‘cargo aircraft only’ configurations  – you can only ship an oxygen generator by passenger aircraft if you receive a special permit that allows this unusual configuration.

If you have an oxygen generator that cannot be shipped by air because of its configuration (e.g. expended, unserviceable, beyond manufacturer’s expiration date, etc.) then you should be looking at ground, rail or maritime transportation as options.

FAA Warns About Improperly Manufactured Leading Edge Slat Tracks for 737NG and 737MAX Aircraft

The FAA has issued a press release about 737 leading edge slat tracks may have been improperly manufactured and may not meet all applicable regulatory requirements for strength and durability.  According to the FAA, the issue affects both 737NG and 737MAX aircraft.

It is unknown whether any of these articles are in distributors’ inventories, or if all of them are still on-wing (although it is likely that they remain on-wing due to the age of the fleets).  Boeing claims that it has contacted all of the affected operators.

This issue appears to affect a significant number of aircraft.  Boeing claims that 21 of the 737NGs are likely affected but has nonetheless recommended inspecting a total of 133 of them.  The FAA press release indicates that the total number of 737MAX aircraft to be inspected is 179 (and Boeing claims that 20 of the aircraft are most likely to have the problematic slat tracks).

The FAA has pledged to issue an Airworthiness Directive (AD) to mandate Boeing’s service actions to identify and remove the discrepant parts from service.  We expect to see the AD, soon.  After the AD has been published, distributors are advised to examine the AD and ensure that they do not receive slat tracks from among the AD list.  The AD was still forthcoming as of this afternoon – ASA plans to publish follow-up information after the AD has been published.

Highlights of CCMA, 2019

For those who missed it, CCMA was a great conference at which professional relationships were being formed and strengthened. It also featured some really valuable learning opportunities.

ALTA CEO Luis Felipe de Oliveira opened the CCMA conference in Cancun with a call for more investment in airport infrastructure. He also highlighted customs burdens that the inhibit commerce through Latin America. He called for greater uniformity and less complexity in order to facilitate aviation as a global industry.

Big Data

CCMA Technical and Procurement Committee Chair Ahmad Zamany (VP Technical Operations, Copa Airlines) spoke about big data and its use in operations management. He noted that when an airline considers investing in “big data,” it has to assess the cost against the benefit. If current fleet dispatch reliability is at 99.2% and the airline believes that big data can get it to 99.5% then still has to assess the benefits of that dispatch reliability against the costs.  There will be a point (a cost), above which the investment is not warranted, especially if you would only be eliminating certain small delays that have minimal cost.

Zamany explained that the value of using “big data” to drive predictive maintenance may be higher than its value in mere dispatch reliability.  This is where sees the highest return on the investment into big data.  He also noted the safety benefits of such an implementation.

Chris Markou explained that the industry is impeded in using big data efficiently by industry participants who are willing independent and who do not share data. He exhorted the industry to find ways to share data more effectively and more generally.

There were also discussions about who owns the data generated by operations.  Air carriers complained that some OEMs are making the air carriers pay to access their own data.  Mauricio Rojas Arteaga was there from Skywise, (an Airbus company) and he pointed out that Airbus has invested in finding ways to share operational data more broadly with air carriers.  Zamany expressed his belief that the operational data belongs to the operator, because it is produced by the air carrier’s operations efforts.  Arteaga agreed with Zamany’s point – that the data belongs to the airline – but he explained that the analysis is the most important part, and that analysis is what air carriers are paying for.

Sebastian Binz of Eurowings said that operators need to be able to control the data as well as owning it.

Zamany notes that part of the problem is lack of standardization which makes it difficult to use and share and correlate information.

CFM-IATA

There were several discussions of the CFM-IATA Agreement.  Under that Agreement, CFM has pledged to prevent anti-competitive behavior and has established a mechanism to address allegations of this sort of behavior.  IATA hopes that this CFM commitment will serve as a model for other type certificate holders.

Gonzalo Yelpo, ALTA’s Legal Counsel, ALTA led a panel on this subject featuring:

  • Jason Dickstein, General Counsel, ASA
  • Daniel Kanter, Assistant General Counsel, Chief Counsel Global IATA Antitrust and Competition Law
  • Brian Ovington, Marketing Director, GE
  • Francisco Sanchez, VP Strategic Sourcing Technical & Supplier Management, LATAM Airlines

It is believed that this agreement could help reduce costs in parts and repairs, as well as encouraging new innovations that will help improve reliability and safety.  The ALTA community seemed very excited about this Agreement, with many asking questions about how best to use the Agreement, and some specifically asking about the methods for raising their concerns to the CFM Liaison Officer.

Labor Force and Diversity

Labor force development and diversity continue be important issues with panels on labor force as well as on Women in Aviation.  The Women in Aviation panel featured ASA Director Lee Kapel (CEO of TSI Aviation).  That panel noted that only 2.39% of the American maintenance personnel are women, and the panelists shared their views on how to bring more women in aviation careers.  A labor force panel discussed more generally how to attract the right talent and how to keep them engaged

Additive Manufacturing

Additive manufacturing was another hot topic.  We assisted in the learning process by discussing with the air-carrier-only-meeting and the technical committee meeting important factors like

  • how to get started
  • relying on traditional production processes (like supplier control) as a template for developing novel procedures that are specific to the requirements of additive manufacturing
  • the limits of additive manufacturing
  • ways for an air carrier to get the benefits without the investment, by encouraging their suppliers to use additive manufacturing where it is appropriate

ASA also shared a workshop stage with Satair’s additive manufacturing guru, Felix Hammerschmidt (Head of Additive Manufacturing Solutions).  Satair (an Airbus company) already has over 200 parts being produced using additive manufacturing.  Hammerschmidt discussed a number of the factors that influence additive manufacturing.  He also noted that in addition to production of part, Satair is also using additive manufacturing to produce tooling on an on-demand basis.  This means that Satair does not have to store that tooling in a warehouse, but when a customer need a tool it can be created and shipped immediately.  This increases efficiency and allows Satair to be immediately responsive to customer tooling needs.  Hammerschmidt estimated that Satair averages the creation and shipping of about one such tool per day.

Competition

All of these topics, above, ended up touching on competition, so it was fitting that the final panel should explicitly delve into competition.  Jonathan Berger (ALTON Consultancy Managing Director) moderated a panel about the value of competition in the MRO marketplace.  The panelists agreed that that competition was good for the airlines and good for the flying public – hopefully next year the panel will provide more solutions on how to preserve competition in the face of a rapidly consolidating industry.

CCMA Kicks Off

CCMA opened with over 600 regular supplier attendees and over 70 airline participants. ASA was invited to address the airline closed meeting on strategies for airline use of additive manufacturing and we discussed the importance of both supplier control and manufacturing process control over n implementing additive manufacturing as a production method. We also discussed the proposition that additive manufacturing is a technology that suppliers may be able to use to better support airline needs, so air carriers should be prepared to work with their suppliers on additive manufacturing methods.

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