2. CASP location in the company's chain of command is poor. A CASP unit should be an important management tool; a stand alone element of the organization. It should have a direct pipeline to upper management. In some start-up airlines, we find that the directors of maintenance or directors of quality control are usually assigned responsibility for running CASP.
Although legal, this is not really a good idea. In reality, you are asking the director of maintenance or quality control to make an objective analysis of his or her own organizational performance. The odds of getting an objective analysis are the same odds of expecting an objective response when asking a barber if you need a hair cut. No one in his right mind is going to say to his boss that his or her organization has pimples or bad breath. So problems remain hidden, and too often, multiply in the dark.
3. The CASP unit is not allowed to grow with the airline. When airlines expand or merge, the CASP program usually remains the same size. As the airline brings aboard new equipment, line stations, and personnel the CASP unit is overloaded, undermanned, and doomed to fail in its mission. Over a relatively short time, the analysis and surveillance functions wither, and with less and less self evaluations that provide the airline with a whiff of reality, the airline slowly becomes a victim of the "Goldilocks syndrome" or "everything is just right" - until the nightmare arrives.
4. Another problem area is the continuing analysis and surveillance program is no longer continuous. On some air carriers, CASP functions as a hit-and-miss operation. While it is true that the airline's data collection runs continuously, the overall analysis and surveillance that is performed is sporadic.
The way the FAA can tell if an operator has put CASP on hold is simple. We just look at the number and kinds of changes to the airline maintenance portion of their manual over the last few months. If the manual changes are cosmetic in nature and operational procedures pretty much remain the same, but the number of maintenance delays or other indicators are on the rise, then it is obvious to us that the CASP program has become dysfunctional. We then check our calendar and schedule a visit.
5. As previously mentioned, many airlines are very good at obtaining CASP data, sometimes too good. Any airline maintenance department can get more data than it can possibly handle. Too much data creates a drag on the system by entering too much of the wrong information into the CASP database at the expense of losing valuable surveillance and analysis time. The data collected should be a means to an end, not the end unto itself. This excess of data will create a similar problem and a similar FAA response as identified in the previous paragraph.
What can the FAA do if they find a CASP wanting?
The FAA certificate holding office, after finding and documenting that either the airline's CASP audit or performance surveillance sections, or both, is no longer effective, the office will send a letter to the airlines. The letter will identify the CASP problem areas, recommend or require specific changes to the CASP, and usually assign a date when the corrective action must be completed. The FAA usually follows up with an on-site inspection after the carrier has made the necessary changes.
What can the airline do if it doesn't want to change its CASP?
Section 121.373 and Section 135.431 both allow the certificate holder to petition the FAA certificate holding office to reconsider the notice to change the CASP. However, the airline must submit the petition to reconsider within 30 days of receiving the FAA's letter. Except in the case of an emergency requiring immediate action in the interest of safety, the filing of the petition stays the FAA certificate holding office's notice pending a decision by the administrator. In other words, the decision is bumped up to either the FAA office's region or to headquarters.
A final thought
While I spent most of the space available for this article stressing the need to make the CASP a very important part of each airline's maintenance organization, I saved the most important element of the CASP for last.
No matter how well thought out the CASP program is and no matter how well it is positioned within the organization's chain of command, the most important element of the CASP program is the people who make it work.
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