Independence Day and the Importance of Systems Safety

Five years ago, FAA Deputy Director John Hickey spoke to ASA about the importance of systems safety.  He explained how we can achieve success in a system, and how the system can maintain success even in the face of change.  In the context of a safety management system, the system allows the personnel to change, without undermining the safety expectations of the system.

The elements of systems safety have come under fire, recently.

For example, you can see articles written about the need for the FAA to eliminate the designee program.  Articles suggest that it reflects an abdication of the FAA’s safety duties; but I have seen one excellent article explaining why the program works, and what we need to do in the future.

The designee program has been moving to a more systems-oriented focus for decades, now, with a emphasis on organizational designees (ODA).

The core of systems safety is creating systems that manage compliance and manage the right processes.  When those processes are incorrect, though, the result can be undesired.  Just as aviation has always sought to gather data and improve its systems, now is a time to continue to improve our systems.

ASA has always been focused on systems safety, with our emphasis on quality assurance systems implemented in accordance with ASA-100 and audited under the ASAAP program.  Distributor accreditation is a systems-based program that was audited by the FAA and found to improve safety in the industry.  Although the accreditation system is voluntary, it has become incredibly successful in the aviation industry because it is so effective in protecting the aircraft-parts-related safety of the aviation community.

On the fourth of July, American celebrates its Declaration of Independence, which was approved on July 4, 1776; but Americans point to a later document, the U.S. Constitution, as the backbone of the nation.  The U.S. Constitution became effective on July 4, 1789 – 230 years ago.  It established the system of America’s government.  Some people have posited that it might be more convenient to work outside of the Constitutional system, but that Constitutional system has worked well for America for quite a long time.  And when it has been found wanting, America has amended the Constitution rather than throwing it away.

As we approach the July 4th celebration of American independence, take a moment to think about how we can continue to improve aviation systems safety.

ASA will be examining safety systems as they apply to aircraft parts distribution at the Annual Conference in Montreal on July 14-16.

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;

 

Accreditation Alert! DRAFT AC 00-56B is out for comment!

The FAA has released for public comment AC 00-56B, which is the draft revision to the Voluntary Industry Distributor Accreditation Program (current version is AC 00-56A).

This draft FAA advisory circular (AC) describes a system for accrediting aircraft parts distributors based on compliance to a standard and certification of that compliance by FAA-acceptable accreditation organizations.  ASA has been part of this program since the beginning, and is an important FAA partner in the mission to improve aviation safety through effective management systems.

The FAA has strongly endorsed participation in the AC 00-56 program.  FAA is revising this AC to reflect the changes in regulatory requirements and industry practices since the last revision.

ASA met with its Quality Assurance Committee (QAC) on December 5 to review and examine this proposed change.  The QAC was generally supportive of the draft AC, and spent its time examining ways to further improve the document.  ASA is in the process of developing comments based on that QAC meeting.  Those comments will address subjects like these:

  • A transition mechanism for ensuring that industry has time to come into compliance with the new standards
  • Firming up an accurate description of the the relationship between the accreditation organization and the quality system standard holder
  • Firming up an accurate description of the the relationship between the accreditation organization and the FAA
  • Clarifying the definition of distributor
  • Clarifying the definition of Distributor Accreditation
  • Clarifying the definition of Quality System
  • Clarifying the definition of Traceability so it is consistent with current industry connotations
  • Using terminology that is consistent with other FAA guidance
  • Ensuring that FAA audit expectations are adequately described
  • Ensuring that FAA requirements for auditors adequately reflect current industry best practices
  • Clarifying the FAA’s changes in the quality system elements
  • Ensuring that citations to statutes and standards are correct
  • Updating the documentation matrix to reflect current standards and also to reflect the current global nature of the AC 00-56 program

The documentation matrix was subject to significant discussion, and the QAC worked on a proposal to further strengthen the matrix in order to support both current and future industry ‘best practices.’

The draft is open for public comment through January 4, 2015.  Comments should be delivered to

Robert McDonald
1625 K Street NW
Suite 300
Washington, DC 20006

Comments can also be emailed to Robert.CTR.McDonald@faa.gov or faxed to (202) 223-4615, Attn: Robert McDonald.

Please also send a copy of your comments to ASA, so that we can be sure that your views are reflected in the Association’s comments.

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