The concept of required inspection items (RII) has been around for a long time, primarily in the airline industry. However, the key elements that constitute an RII system are applicable at all levels of the maintenance industry. An RII item is specific inspection of any maintenance action that, if improperly done, could result in immediate danger to an aircraft. If you are rigging flight controls, installing a propeller, or performing another maintenance action that affects flight critical systems then it’s certain that they involve an RII.
RII is defined in Part 135.427 and Part 121.369 of the FARs. These rules pertain to having the RII program described in the operator’s manual. If you are a Part 91 operator with an aircraft having 10 or more passenger seats, then these rules will apply under provisions in Part 91.401(c). Fractional Owner operating under a Continuous Airworthiness Maintenance Program (CAMP) will find RII mentioned in Part 91.1427. An RII item is defined as: A designation of the items of maintenance and alteration that must be inspected (required inspections) including at least those that could result in a failure, malfunction, or defect endangering the safe operation of the aircraft, if not performed properly or if improper parts or materials are used.
These programs are common to air carriers, but many general aviation technicians and managers would find the concept useful to incorporate as a routine activity. The implementation of an RII program as a safety enhancement is useful for any maintenance operation and, by definition, reduces the risk of avoidable maintenance errors.
An RII program
RII by definition is a key maintenance safety concept. The key elements of RII include:
• A list of items that are designated as “Required Inspection Items.”
Prior to operation of a new aircraft type the operator’s management will assemble a list of items that they feel meets the definition of RII. It includes mostly the systems or subsystems broken out by ATA category. Windows, flight controls, landing gear, engines, and propellers are good examples of what make the list. In selecting these items consider the key elements of each system as a critical point of control. These elements are defined in the method described in RII procedures.
• The method of performing required inspections.
The manual should define the scope of the required inspection as well as list the items — often the RII listing includes the method of inspection required. There are many formats that have been accepted. The list can include methods that correspond to the applicable item. For example: “ATA 71, Engine change, installation and rigging;” or a more specific example: “ATA 61, Propeller installation, verify propeller nut is properly threaded, witness the torque, and record torque wrench serial number and calibration. Verify that nut is properly safe tied with .032 stainless safety wire.” The latter example provides a more effective and efficient method for assuring work is done properly.
• A designation by occupational title of personnel authorized to perform each required inspection. People have to be designated as RII qualified inspectors.
Both maintenance repair and overhaul (MRO) organizations and airlines have inspectors, but they cannot do RII unless they have been trained and authorized to accomplish required inspections. A quality inspection is not a required inspection. Remember the definition? In fact someone outside the quality unit of the organization can be designated as RII, if they have had training and meet the qualifications deemed necessary by the operator’s procedures. Once the quality unit authorizes that person, they may accomplish RII.
There are rules for RII performance that each authorized inspector must follow:
• An inspector may not accomplish a required inspection on his own work; including training someone on that work.
• There are procedures for rejection of work by an RII inspector including procedures for override of the rejection by higher authority within the quality unit.
• If additional findings are made by the RII inspector, those findings must be bought back using internal procedures.
• And finally, work turnover: Each operator or agent working for an operator such as an MRO, must have procedures to ensure that required inspections, other maintenance, preventive maintenance, and alterations that are not completed as a result of shift changes or similar work interruptions are properly completed before the aircraft is released to service.
Books could be written on shift turnover and in fact there are some interesting analysis of shift turnover as it relates to accidents and incidents; mostly related to their mismanagement or lack of accomplishment. When managing work turnover one is managing a human factors process. The most common errors are errors of omission often resulting in incomplete work. The task of turnover is to connect the dots and keep them connecting to assure that things don’t fall through the cracks, i.e., no missed steps in the repair process.
Shift turnover is a communication task — something for which most mechanics are not well equipped. To be successful, shift turnover procedures have to be trained and enforced. They have to be used daily in a context that assures they are complete and effective. Anytime work is to be interrupted a turnover should be made. Processes for describing remaining work must be comprehensive in scope to assure that work is properly completed. For example, if there is only one shift then management must make it clear to personnel that a turnover should be made in preparation for picking up the job the following day. If it is to be covered on a task card then the means to accomplish a proper turnover must be part of the organization’s internal maintenance procedures. Audits to verify compliance should be accomplished often.
Turnover performance — audit findings
Shift turnover is often a weak area of compliance. Many maintenance organizations mention it in their training, but do not train personnel specifically in its use. There is an expectation of performance. When accomplishing compliance audits, I will review the daily shift turnover records. My efforts reveal many issues that include the following examples of noncompliance or concern:
1. General description of work progress — lack of detail when RII activity was present.
2. To-do list of things remaining. Entries are unrelated to specific tasks and their state of completion.
3. Anecdotal information related to HR or personnel performance.
4. Lack of safety information related to safety hazards present on the aircraft.
5. Only key elements of the check events themselves are often in the shift turnover.
6. The turnover in rare cases has been used as a place for documenting maintenance when it has not been recorded on the aircraft log or nonroutine paperwork.
Much of this information may be useful to the project manager, but does not serve the safety function that the shift turnover process was intended in the regulation.
Prioritization of work in progress
When I instruct technicians and inspectors on shift turnover, I like to explain that a good turnover prioritizes the subject matter. RII work in progress is first. It is a maintenance safety concern. If the RII repair work goes across shift (day shift to swing shift, for example) or work is halted until the following day, their appearance in the turnover log is mandatory. A turnover entry when written must include a description of the unfinished work, the checklist steps or manual reference showing what work was accomplished, and the specific work step where work left off. It must identify who did the work and any in-process inspections that were accomplished. Next shift RII inspectors should be briefed as well to assure that they are aware of the interruption and how the work has been managed prior to shift change.
Next the turnover should identify or describe the aircraft safety state, i.e.; prohibitions to system activation, pinch or crush hazards present, and lock out/tag out activity. Management and mechanics should pass on safety information during crew shift briefings. These briefings must occur prior to moving to the aircraft or starting work.
Work cards or other maintenance paperwork contain important safety information that should be referenced in the turnover log. Work cards are often reposted to the planning booth between shifts where important information may be missed. That is why it should also be described in a turnover log. Other maintenance work in progress is recorded on continuation sheets or on aircraft logbooks depending on the circumstances.
Heavy maintenance checks on large aircraft can involve hundreds or thousands of work cards and their progress is often recorded either on work cards or attached nonroutine forms. If this sounds like a lot of work; it is. However, constant use and enforcement will make the use of the turnover process routine once it becomes part of the work culture.
If one were to review the maintenance-related accidents on record the lack of good RII management has played a role. Emphasis on required inspections and safety conditions must be trained into the work force and enforced by the supervision. Constant review by the quality unit, with verification on the aircraft, drive RII compliance as well as assure that communication processes provide the accuracy needed to make shift and work turnover a successful safety tool. AMT
Vern Berry began his aviation career as an A&P mechanic in 1979. His experience within the aviation industry includes key management roles in quality and safety for both MRO and air carrier operations. He and his wife currently reside in upper state New York where he writes and manages a consultant firm at www.blowntireaviation.com.