Inconsistent interpretations of regulations makes following standard procedures difficult.
Documentation issues and failure to follow procedures are among the most frequent error-prone hazards in the aviation system.
In ground services, we strive for standardization and safety optimization in all procedures. But regulatory inconsistency contributes to documentation issues and failure to follow procedures.
There seems to be regional and even “inspector-specific” interpretation and enforcement of regulatory requirements.
For instance, regulatory oversight of technical publications in Kansas might not have the same documentation requirements as in Kentucky. Meanwhile, requirements in North Carolina may differ from North Dakota.
A panel of aviation industry and government officials recently met to identify challenges and prioritize solutions for issues surrounding technical documentation and following procedures. (See “Procedures 101,” in the April 2012 issue of Ground Support Worldwide by Dr. Bill Johnson for more.)
After the two-day summit, the participants identified five challenges and discussed what could be done to solve them:
- FAA consistency regarding technical documentation.
- Content accuracy for users.
- Industry culture and professionalism.
- Business case for documentation improvement.
- Industry standards.
I’ll cover all of these challenges in future issues of Ground Support Worldwide, but let’s start with the first on regulatory consistency – or, rather, inconsistency.
Panel members insisted that we all need to play by the same rules. They identified two key improvements for realizing solutions:
Aircraft, engine and ground support manufacturers have studied documentation quality and tried to use industry standards to create technical instructions. But many engineers who write technical directions, FAA inspectors who write evaluation guidelines and FAA inspectors who evaluate documents in the field are not consistent in their practices.
What these groups need is a valid, reliable and straightforward way to produce and evaluate technical documentation.
A great deal of human factors literature is available, some of it funded by FAA, regarding the design of paper and electronic documentation. If you develop or evaluate technical documentation, check out these resources on https://hfskyway.faa.gov.
Inconsistent communication of expectations regarding technical information is a key contributor.
Participants said the solution requires new regulations and guidance materials. These materials must be developed collaboratively with industry groups. Tools and training should be developed and applied in a manner that empowers both government and industry personnel to create and validate technical instructions.
There must be more reliance on industry to assist in internal validation and acceptance of information systems.
The FAA has committed to improving relationships with stakeholders and communicating with employees exactly what is expected in its interactions with stakeholders and the public as part of the Aviation Safety (AVS) Consistency and Standardization Initiative (CSI).
The goals of the AVS CSI are to:
- promote early resolution of disagreements;
- promote consistency and fairness in applying FAA regulations and policies;
- encourage stakeholder feedback, including complaints;
- and enhance stakeholder satisfaction.
TO DO LIST
Documentation issues and failure to follow procedures are among the most frequent hazards in the aviation system.
Unfortunately, this problem is ingrained in aviation culture.
Solutions will require significant action by all stakeholders, including manufacturers, operators, government and individual employees. What can you do?
Commit to using existing guidance material to review and revise technical documentation – especially those known to be problematic.
- Strive for standardization among all documents.
- Use voluntary reporting systems to collect documentation challenges and their root causes.
- Manufacturers should strive to validate their written procedures.
- Assign responsible parties to work the issue as a collaborative process.
- Analyze voluntary reporting data to identify common traits of poor documentation.
- Renew Advisory Circulars and other relevant guidance material for industry and inspectors.
- Fund research and development to reintroduce proper documentation practices.
- Create training courses for documentation development and evaluation.
- Create training courses for aviation safety inspectors involved in technical documentation development and oversight.
- If documentation is unavailable or incorrect, notify your supervisor that it isn’t possible to complete the task or complete an Aviation Safety Action Program report. Workers by regulation must follow written instructions.
- Report all suboptimal work cards or manufacturer’s instruction to your management and to FAA.
- Use the Aviation Safety Action Program (ASAP), the Aviation Safety Reporting System (ASRS), Line Operation Safety Audit (LOSA), and other voluntary reporting systems to highlight all documentation challenges.
Methods to address hazards associated with poor documentation and work procedures are clear. Join together, take responsibility for problems, identify the root causes, develop viable solutions and implement them.
Dr. Katrina Avers is a Research Scientist at the Federal Aviation Administration in the Civil Aerospace Medical Institute Human Factors Research Lab. Dr. Avers takes a practical, science-based approach and has worked to develop applied solutions that can be used across the industry.