Washington Scene
By Stan Mackiewicz
April 1998
Stan Mackiewicz is the executive director of the Professional Aviation Maintenance Association.
Jane Garvey took over the reins of the FAA in August, 1997, just after the EAA show in Oshkosh. Since that time there have been no major air carrier accidents within the borders of the United States. In the unique language of large government departments, she is a stunning success. Measures of our Administrators often are pegged to the accident rates. Fair? Maybe!
The aftermath of her initial confirmation was a statement that her agency would focus on air carrier or commercial aviation; safety is first; promoting aviation as a method of transportation was not a necessary part of the FAA mission; and "maintenance" was synonymous with human factors.
So far the numbers point that she is going in the correct direction. Time will tell.
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The FAA Suspected Unapproved Parts Division is near finishing their program. If an "elephant" is a "mouse" designed by a committee, the SUP Program is somewhere between. It has already begun to clean up areas of the parts industry that needed attention. Unfortunately the program is loosing a key player. Ken Reilley, chief of SUPs, is leaving in several months to take a job in New York. He has been responsible for defining and documenting how the parts industry will work for years to come.
Soon there will be a flood of ACs and FAA Orders that explain the program. Training in the field has begun. Ken has won the grudging respect of industry leaders who worked with his office via the SUP Steering Committee. Ken listened to this industry group and factored many of their concerns into the program. The SUP program reports directly to the highest levels in the agency and shows what can be done when a dedicated group gets that support. Whenever he needed help, it was there. Ken probably does not see it that way, but those who have programs that do not have the visibility at a high level within the FAA suffer intolerable delays.
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There is a new gun fighter in the FAA Regions and FSDOs, and he/she belongs to us, the maintenance part of the flying equation. The position is called Airworthiness Safety Program Manager. The person is dedicated to airworthiness safety issues. Specifications call for the position to be filled by a person with an A&P certificate. This is significant. The safety programs have been mostly populated with people from the operations side of the FAA. Maintenance folk have not had the money nor expertise to develop meaningful programs. Instead we have seen safety program managers tell large groups of pilots what maintenance they can and cannot perform. Finally, some "right-thinking" in the agency. The program permits assignment of Airworthiness Safety Counselors similar to the volunteer Safety Counselors, often populated by flight instructors, who are often seen strutting around local airports. Not all regions nor FSDOs have read their mail yet nor know what the program is all about. These are your contacts for safety programs, and we urge you to call and find out who they are and what are they going to do for you. Budgets are currently being established for travel, literature, and other costs of running the safety program.
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The Aviation Rulemaking Advisory Committee (ARAC) has been officially extended for another two years. The ARAC process is intended to solicit industry help in making rules. There have been some notable successes everywhere but in the maintenance area. Part 66 and Major Minor are good examples of the problems with the system. On Part 66 many good dedicated people worked long hours to hammer out a proposed change to the regulations covering certification of mechanics. Fourteen months ago it left ARAC and began the tortuous journey through the bureaucracy to become an official "Notice for Proposed Rulemaking" and released to the public for comment. As this is written, it has cleared all the hurdles and sits in the Office of Deputy Associate Administrator for Regulation and Certification awaiting signature to send the document to the Federal Register. Since all the objections have been overcome or explained away, there is nothing holding it up except ink for the pen. It is frustrating to spend so much time only to have our government procrastinate without telling us why. Still, this process is preferable to government insiders making the rules in the blind.
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Another kink in the siphon line of meaningful work at the FAA is the Office of Chief Council. This august body of legal (technical?) experts is holding up AC43.13.1B. This document is the rewrite of "Acceptable Methods, Techniques, and Practices" for "Aircraft Inspection and Repair" and was first released in 1972 and updated in 1988.
This technical document is used universally for "minor" repairs and may be used as a basis for FAA data approval for "major" repairs. It can be used as approved data when (1) The user has determined that it is appropriate to the product being repaired; (2) directly applicable to the repair being made; and (3) not contrary to manufacturer's data.
It badly needed modernization, and a group of dedicated civil servants and industry people worked hard to get it done. I suppose the FAA has a good reason to hold up this kind of project, but so far they have not shared it with industry.
