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...


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.

TRAINING RECORDS
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 Many times they are non-existent, inadequate, or, as is usually the case, out of date.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.

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