Beware the nasty NASIP

Beware the nasty NASIP Are You Ready? By Stephen P. Prentice April 1998 Steve Prentice is an attorney whose practice involves FAA-NTSB issues. He has an Airframe and Powerplant license and is an ATP rated pilot. He worked with Western...


Beware the nasty NASIP

Are You Ready?

By Stephen P. Prentice

April 1998

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.

CONGRESSIONAL MANDATE
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.

WHAT'S IMPORTANT
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.

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