All business is regulated to some extent but those of us in the aircraft maintenance repair station business are held to a little higher standard than similar companies in other industries. We are subject to periodic inspections and audits from the FAA to ensure that we are operating within the boundaries specified by the regulations that govern the work we do and to ensure that the aircraft that we approve for return to service are delivered airworthy.
One thing is for sure, business is business and to stay in business, no matter how tight the regulations, a business must be profitable. We believe that it's the technician on the hangar floor, working to resolve the latest discrepancy on the aircraft that brings profitability to today's repair station. And this month we want to look at a few of the things that can get in the way of a technician who is working hard to stay profitable.
Is the process efficient?
In years past, the corporate aviation maintenance repair station business played a slightly different role in our industry. We supported a very active new aircraft sales group and enjoyed fairly significant new parts margins when we sold parts as a part of the maintenance we performed. Today, however, we see a different picture. The manufacturers are handling the sale of most new business aircraft and the margin for parts sold during maintenance is dwindling. Today the aircraft maintenance repair station business must be much more efficient at completing the work so that they can realize a higher profit on labor than parts.
So, whose job is it to get the work done, with the highest quality and in the shortest time? You guessed it, yours. But what about all those regulations? Who is going to comply with all that paperwork stuff? You guessed it, you. Get it done fast and in compliance? Seems like those two don't go together. Well, they do. No one ever said that getting the work done quickly meant sacrificing quality. As a matter of fact, organizing the work so that it gets accomplished in a predefined order, with the right tools and the right team usually means faster and with higher quality. Where we usually run into the conflict is with the FAA. In order to incorporate new procedures, we are required to get the FAA involved, and for most of us, that's like going to the dentist. The FAA will often throw up a brick wall to new procedures. Not because the procedure is out of compliance, but because they may not have seen it done that way in the past and so they may resist your new procedure. To be able to accept the procedure, your inspector will need to do the research and discover how your new procedure is in compliance. He/she already knows that the old procedure is in compliance and would rather you just keep doing it (whatever it is) the old way. Like it or not, the FAA's job is to make sure you are working in compliance with the regulations, not make it easy for you.
The FAA isn't concerned with your profitability
The fact is, it's not the FAA's job to make you profitable. It's the FAA's job to make sure you're complying with the regulation and that you run a safe operation. To that end, the principal safety inspector assigned to your repair station will come by at least once each year to "inspect" your operation. They want to know if you're still following the procedures that were accepted when you applied for and received the repair station certificate.
The development of new procedures that increase your team's efficiency is dynamic and should never end if your business continues to grow. The sad thing is many repair station managers don't even try to increase efficiency. Or they develop and implement new procedures without getting input from the FAA and get a nasty-gram from the FSDO following the yearly inspection.
Getting new procedures accepted by the FAA can be a time-consuming process for someone, likely the chief inspector or director of quality. However, the time is very well spent when the new procedures can improve your efficiency and thus your business's profitability. And the time it takes to get approval or acceptance can be reduced greatly with a little planning up front.
Getting the FAA to say "Yes"
The single most important tool in dealing with the FAA is your knowledge. In order to have fruitful dialog with the FAA you must know the rules that govern the topic of discussion. If you don't, then all you are really doing is asking one FAA inspector their opinion about the topic. Now they may know the rule and may be able to tell you how they want you to comply with the rule, but if you research the rule and understand how your new procedure complies with the regulatory requirements, you can present it to the FAA. In some cases they won't listen, for some inspectors it is more important to be "in charge" than to be helpful, but in most cases, when you present your case and have researched the basis of your proposed process or procedure, the FAA will respect and appreciate your position.
So we encourage you to step outside the box, get a clean sheet of paper. Ask your team, "If we could do this task (whatever it may be) any way we liked, how would we do it?" "What things are getting in the way of getting the job done?" Try to eliminate unproductive steps and streamline the work process. Write down the new procedure and then put on your regulations hat and start making adjustments if you need to. What you may find is that you need to add a couple of steps here and there to inspect or check work, but that the basic process is probably well within the boundaries of the regulations.
By the way, your inspector may not know as much about the rules as you do
Not every FAA inspector has memorized the rules and understands how they all tie together. And many of them are working in many different areas, Part 121, 135, 145, etc. and could never keep up with all of the regulations.
When you go to the FAA, know your position on whatever the topic may be and how your position is supported by the regulations. The FAA inspector may very well have a particular point that he/she wants to make clear, but it does not have to affect your position. Many of us are afraid of the FAA, and really don't need to be. If you are afraid of the FAA it may be because you think he/she knows more about the regulations than you do. But if you take the time to research each issue before approaching the FAA and find out how your new procedures meet the requirements of the rule, you will go into the conversation way ahead of the FAA. You will be able to present your plans for new procedures, what you plan to do, how you plan to do it, when you plan to have it done, and the regulatory basis for your plans.
Please note, you are not there to ask for permission. I have found that when I ask the FAA for permission, (can I do this?, can I do that?) nine times out of 10 the first answer is "No". The fact is that they might say "No" even when you present your well-thought-out procedure, but if you start by showing you have thought it through and can demonstrate how the new procedure keeps you in compliance, the FAA will appreciate your efforts and will be much easier to deal with.
If the FAA says "No" just ask them "why not?". Ask them to show you in the rule why you cannot do what you want to do.
Making procedural improvements can make your team more valuable to the company, particularly when you get the team's involvement in creating the change. Look for opportunities to remove work from your procedures. Present them to the FAA and get their buy-in for making your company more profitable. In the end everybody wins, the FAA, the customer, you, and the company. AMT