Beware the nasty NASIP
Are You Ready?
By Stephen P. Prentice
If technicians want to feel secure in their jobs, they have to pay special attention to the management of maintenance within their company. When a technician observes things getting out of line and in violation of the FAR, he or she should discretely go through channels and advise top management. The threat of violations resulting from a NASIP style inspection should make all technicians pay special attention to their maintenance procedures and various paperwork requirements. Your jobs may depend on it.
You don't have to be a rocket scientist to understand what the Feds are up to with the current round of NASIP inspections of air carriers and repair facilities. For those who should know, NASIP stands for National Aviation Safety Inspection Program. The inspection will focus on safety, for the most part, and adherence to regulation in general. The idea is to look into every nook and cranny of the operation, under mandate from Congress, to insure compliance with the FAR. The theory is to satisfy a Congressional mandate that came about as a result of the infamous ValuJet — now Air Tran — accident.
If an air carrier operating under the rules of Part 135 or 121 or a repair station under 145 is toeing the mark, there should be no fear of the Fed. The inspectors follow a set procedure and simply go through the various regulatory aspects of FAR 135, 121 or 145. If an air carrier or repair facility runs a tight ship and has all its ducks in order, there is nothing to fear. But if your paperwork and inspection requirements are lacking, you better watch out. It does not take much in the way of violations to shut down a shop or carrier. And there goes your job. Safety is the paramount consideration. Threaten the public in any way with your operation, and you will be shut down, maybe permanently.
In the case of 121 operators, the main emphasis will be on such things as flight and duty time records, vendor and substantial contractor audit, and maintenance training records. The Continuing Analysis and Surveillance Program mandated by FAR 121.63, or CAS, as it is called, was a major issue in the ValuJet re-examination after its merger with Air Tran. CAS can simply be defined as a continuing check on the operational reliability of the aircraft and their systems. Such things as using contractors to paint aircraft that were not listed on the approved op. spec. were highlighted by the inspectors. Do you use contractors and/or vendors who are not listed on your operations specifications? If you do, you had better get them approved and listed pronto.
CONTINUOUS ANALYSIS AND SURVEILLANCE
In the case of ValuJet, inspectors stated while Valujet's CAS program was in place, it was not up to the subjective standards of the inspectors. They went on to say there were no "systemic safety concerns." Well, one can only wonder that if there are no safety concerns, what's the beef? If there are no safety concerns that will threaten the public, why all the hue and cry? Are these really safety violations that will impair the public or an attempt to look under every rock? These kinds of findings seem strange to many observers and do not, in the opinion of many, reflect common sense safety inspection techniques.
The CAS program is, of course, important however, simply because it is mandated and described by the FAR. The program must be set up, followed, and reviewed on at least a monthly basis. It's not difficult to accomplish, but it does take staff and time to complete. All the various discrepancies on aircraft have to be looked at and analyzed with the goal of attempting to reduce their number. Furthermore, the operations aspects of the aircraft must be reviewed and analyzed with the goal of correcting all of the deficiencies and, more importantly, laying a groundwork to avoid them in the future — hence the need for at least a monthly review. What goes into the nuts and bolts of the review is pretty much left up to the operator. There must be documentation to support your CAS program and appropriate records and data to confirm compliance with the FAR. However, it must be remembered that the FAA inspectors have guidelines that they will use to gauge the effectiveness of your program. If they don't think it is adequate, they will tell you so based on their guidelines. Technicians should participate in this examination simply because they have the hands-on exposure and are in the best position to analyze maintenance deficiencies.
In addition, technicians should review their individual training history records. Many times they are non-existent, inadequate, or, as is usually the case, out of date. If your individual record at an air carrier or repair station is deficient, point it out to management and get them to make it current. You can be sure that your maintenance PMI and any NASIP inspector will look very carefully at such records to determine whether they are up to date.
The maintenance department will also be expected to pay close attention to their individual maintenance resource management programs, if any exist. Do you have one? Will you have one in the future, and will your technicians be participating? These are all questions that can impact any inspection of your maintenance facilities. Although there is no mandate under the FAR for such programs at this time, your participation will go a long way toward showing your companies good-faith efforts to improve safety and efficiency.
FAA INTERNAL DISPUTE
Recent reports have noted that in the ValuJet re-examination an unprecedented and substantial dispute arose between the Washington NASIP inspection team and the local FSDO inspection personnel. It became of such concern that an additional inspection team was called in to help settle the dispute. This team is a special team sent in specifically to iron out disputes. Their job is to tackle the more difficult job of reviewing the work of the NASIP teams and settling any disputes that may exist with the local inspectors. It could not have been a pleasant task, but it needed to be done to keep peace in the FAA family. Hopefully, Washington listened to the local hands-on inspectors who are on the firing line daily and take most of the brunt of inspection requirements. Although they are much maligned in the press, they are really the unsung heros who have to deal with the problems on a daily basis, even with Washington looking over their shoulders.
Technicians should work with their local inspectors and cooperate with them in attempting to enhance the safety of the operation. In the long run, this may also contribute to the longevity of the technicians' jobs.