A key expectation related in the new CASS guidance Advisory Circular is that air carriers will periodically report status on each of the 10 elements of the air carrier’s maintenance program. This means not just meeting and talking about delay and cancellations, air turn backs, the number of pilot reports, or nonroutine write-ups generated during a planned maintenance visit. Maintenance training should be reported on and discussed – is the training being provided, effective; how is effectiveness being measured? Is the air carrier’s tool and test equipment program working as designed, what is being discovered when quality assurance does its audits? Are the air carrier’s manuals up-to-date, if not, why not? What are the hurdles and what is being done to remove those hurdles? Who is responsible? All 10 elements of the maintenance program do not necessarily have to be reported on every month, but all 10 elements (their status, their health, the successes, and failures) should be accounted for throughout the year.
Deficiencies in the maintenance program, their corrective actions and follow-up plans should be inherent to each CASS board or senior leadership team meeting.
Some indications that an air carrier’s CASS might need some attention are: Is the air carrier’s reliability program (FAA approved or not) subservient to CASS? If not, it should be. Does the air carrier have periodic CASS board meetings or reliability board meetings? Does the air carrier have a CASS manager and/or CASS director, or does it have a reliability manager and/or director? CASS is mandated; reliability programs are not. Is the air carrier accomplishing genuine root cause analysis, which includes human factor considerations, or is a “Band-aid” approach to corrective actions being used? When corrective actions are implemented, do they have follow-up plans to determine if the corrective actions were effective?
CASS has been around since 1964 and SMS, as a rule, is within sight. Both CASS and SMS have some common traits. For example, CASS is expected to reflect the size and complexity of each air carrier, there is not one CASS model that is good for all. The same goes for SMS, each SMS will be designed to reflect the air carrier’s size, culture, and complexity. CASS was created to help enhance safety; the same can be said for SMS. If air carriers take a close look at what an effective CASS should be and make it so, it is not inconceivable that their “new” CASS could serve as a primary maintenance feed to the overall organization’s SMS. This is another good reason for an air carrier to have an effective CASS – when SMS becomes law, many air carriers’ maintenance organizations may be able to achieve compliance using their CASS as the foundation.
The CASS regulation mandates continuous surveillance and measurement of both performance (is the air carrier doing things right?) and effectiveness (is the air carrier doing the right things?). Determination of performance and effectiveness for each of the 10 elements that comprise the maintenance program can help the air carrier realize a positive ROI from its CASS.
Lastly, it should noted that while CASS is mandated for certain U.S. air carriers, any organization can benefit from an effective CASS. Guidance provided in Advisory Circular 120-79 (as revised) can be used to help develop a very effective and beneficial business plan. Not only will it provide a higher awareness to safety, but it will also provide a more effective means to manage the organization’s economics.
Dave Nakata is vice president, Consulting Services for EmpowerMX. He has been with EmpowerMX since 2002; prior to that he was with two major U.S. air carriers for a total of 35 years. The FAA recognized Nakata as a CASS subject matter expert; he was selected to help train FAA ASIs in CASS, maintenance programs, reliability programs, and MSG-3. EmpowerMX (www.EmpowerMX.com) provides aircraft maintenance software and maintenance/engineering consulting services to the air transport industry. You can contact Nakata at firstname.lastname@example.org or (612) 239-6671.
EmpowerMX offers aviation maintenance software solutions and consulting services. For technical support contact (651) 788-8888 or email@example.com.
EmpowerMX will collaborate with the carrier’s Maintenance and Engineering (M&E) department to identify and close gaps in its CASS.
CASS (FAR 121.373) Frequently ignored . . . source of violations By Stephen P. Prentice Some big name brand airlines have recently been nailed for failing to implement or maintain an...
These classes were a continuation of a four year-long relationship between the FAA and EmpowerMX.