MAC’s 10th Anniversary!

“One of the secrets of life is that all that is really worth the doing is what we do for others.” – Lewis Carroll

July 1^st marked McFarren Aviation Consulting’s tenth anniversary! I’m honored to have the opportunity to serve my clients and our industry.

Some businesses have anniversary parties to show their gratitude to their clients and colleagues but since you are spread all over the world, it is MAC’s tradition to give donations to charitable organizations to share the year’s successes. This year I chose the Veterans Airlift Command (VAC) and Food & Friends.

VAC is a charitable organization that provides free air transportation to wounded warriors, veterans, and their families for medical and other compassionate purposes. Washington, DC’s Food & Friends provides men, women, and children living with HIV/AIDS, cancer, and other life-challenging illnesses with specialized meals and groceries in conjunction with nutritional counseling.

I strongly encourage you to consider supporting these great organizations.

This blog has been quiet lately but it’s not because I’ve run out of things to say. (Never!) Check out the recently updated Articles tab on mcfarrenaviation.com for thoughts on everything from the FAA’s Safety Assurance System to doing business in the Part 135 environment.

 

Advertisement

Happy Holidays from McFarren Aviation Consulting!

In lieu of holiday cards for clients and colleagues, MAC has made a donation to Washington, DC’s Food & Friends program, which provides men, women, and children living with HIV/AIDS, cancer, and other life-challenging illnesses with specialized meals and groceries in conjunction with nutritional counseling. MAC’s office assistant Heidi (a lovable Border Collie/Husky mix) once again requested a donation be made to the Dumb Friends League, a humane animal rescue in the Denver area that each year places thousands of dogs, cats, and horses in loving homes.

Whether you celebrate Christmas, Hanukkah, Kwanzaa, New Year’s Eve/Day, or another holiday I wish you a safe and fun holiday season with friends and family!

Happy holidays from McFarren Aviation Consulting! I look forward to working with you again in 2019.

SAS Revisions: A Cautionary Tale

At the recent NBAA Business Aviation Convention & Exhibition, John Duncan, head of the FAA’s Flight Standards division, emphatically told attendees of an education session that Data Collection Tools (DCTs) – the checklists that make up the oversight backbone of the FAA’s Safety Assurance System (SAS) – are inspector assignments and not “operator homework”.

I believe Mr. Duncan means for that to be the case – inspectors completing the DCTs for their assigned operators – but my experience in the field is more of the operator homework variety. But it can be beneficial for operators to complete their own DCTs, rather than having the inspector do it. You get to tell the inspector the answer, rather than having the inspector poke around in your stuff to find the answer. Plus, going through the checklists yourself gives you an opportunity to improve or revise your manuals as necessary to meet the requirements of the DCTs.

(Quick note: DCTs are not regulatory in nature. Technically, you don’t HAVE to do them at all or change any manuals to meet the “requirements”, but the FAA will tell you each item in the DCTs is based on a regulatory requirement, therefore you must “comply”. I can debate a good number of the DCTs applied to Part 135 operators as being outside of Part 135 regulations but in most cases, it’s easier to go along to get along. Yes, that hurts my soul a bit.)

In working with the DCTs over the past couple of years, I’ve noted an important and slightly disturbing trend – the DCTs change. They change often, in fact. This means the FAA has a way of quickly and easily changing the requirements for operators without any sort of rulemaking process.

Rulemaking – real rulemaking, not rulemaking by publishing a new Advisory Circular or revising a DCT – must follow the Administrative Procedures Act (APA) and, in cases of “significant regulatory action”, Executive Order 12866 (EO 12866). The APA and EO 12866 require the federal agency considering a new rule or change to an existing rule to do things like:

• Conduct an economic analysis of the rule,
• Ensure it doesn’t conflict with other agencies’ regulations,
• Submit a draft for public comment, and
• Actually CONSIDER public comment and publish a disposition of those comments (i.e., address each comment or recommendation and state why it was or was not ultimately incorporated in the final rule).

Obviously, the formal process takes a fair bit of time – usually years. A DCT, however, can be changed very quickly. What this means for you, Part 135 operators, is a manual written or revised today to meet the requirements of the DCTs may be out of date tomorrow. And there’s no quick way – at least that I’ve discovered – to be advised of DCT changes. They’re posted on the Flight Standards Information Management System (www.FAA.fsims.gov) but you have to search FSIMS for your peer group or look for your peer group in the list of recently revised documents. It’s not a task you want to add to your daily list of things to do.

That said, do you want to chase ever-changing, not-required-but-kind-of-required standards anyway? Probably not.

So this serves as a cautionary tale – don’t assume that once you meet the DCTs, you’ll continue to be “in compliance” with them forever. Don’t be surprised if your inspector gives you a DCT in 6 months that you’ve already completed but this one looks different and has new requirements.

Have You Been SAS’d? How to Deal with the FAA’s Safety Assurance System

The FAA’s latest oversight initiative, the Safety Assurance System (SAS), is a risk-based system used for certificate issuance, surveillance, and management for Part 121, 135, and 145 applicants and certificate holders.

How does SAS impact your organization? What do you need to know to “comply” with SAS?

SAS involves six Safety Attributes. They are, as described by the FAA:
• Responsibility: A clearly identifiable, qualified, and knowledgeable individual who is accountable for management of activities and their ultimate accomplishment.
• Authority: A clearly identifiable, qualified, and knowledgeable individual who can direct, control, or change procedures and make key decisions.
• Procedures: Documented methods to carry out activities that translate the “what” into the “how”.
• Controls: Parts of the system, including hardware, software, special procedures, checklists, and supervisory practices designed to keep processes on track to achieve attended results.
• Process Measurement: The certificate holder’s process to measure and assess its processes to identify and/or correct problems or potential problems.
• Interfaces: The certificate holder identifies, documents, and has a method to evaluate the impact of changes on related processes.

SAS considers certificate holders of similar capabilities and authorizations as “Peer Groups”. For example, Part 135 operators will be Peer Group 135B, 135C, etc., depending on whether your certificate is a 9 or less or 10 or more.

Each Peer Group is given a Master List of Functions (MLF), which identifies the critical tasks, as determined by the FAA, for that type of organization.

The MLF for your Peer Group is basically your cheat sheet to successful SAS’ing. Take a look at the tasks identified on the MLF and consider the six Safety Attributes for each of those activities.

Some inspectors drop off a giant stack of DCTs for an operator and request the operator complete them. Give yourself plenty of time for this task. Other inspectors give the operator a few DCTs at a time.

There are a couple of ways to approach the DCTs. One is to do a complete re-write of your manuals, identifying the MLF tasks and addressing each of the six Safety Attributes. I only recommend this route if you are already planning a major overhaul of your manuals. Otherwise, you can probably identify many of the Safety Attributes for MLF tasks in your existing manuals – even if worded slightly differently – and provide references for those sections. If you have a mature, functioning SMS, the SMS likely covers some of the process measurement, control, and interface items.

SAS is not a passing fad within in the FAA. It is here to stay. The agency recently launched the SAS Portal, through which they intend for operators to post manuals for their inspectors, inspectors to conduct DCTs for operators, and both parties to complete other general SAS-related tasks.

If you haven’t been handed a bunch of DCTs yet, it’s only a matter of time. When the inspector drops an encyclopedia-sized batch of documents on your desk, don’t panic but be prepared for some work. You’ve just been SAS’d.

 

Happy Holidays from McFarren Aviation Consulting!

In lieu of holiday cards for clients and colleagues, MAC has made a donation to Washington, DC’s Food & Friends program, which provides men, women, and children living with HIV/AIDS, cancer, and other life-challenging illnesses with specialized meals and groceries in conjunction with nutritional counseling. MAC’s office assistant Heidi (a lovable Border Collie/Husky mix) once again requested a donation be made to the Dumb Friends League, a humane animal rescue in the Denver area that each year places thousands of dogs, cats, and horses in loving homes.

Whether you celebrate Christmas, Hanukkah, Kwanzaa, New Year’s Eve/Day, or another holiday I wish you a safe and fun holiday season with friends and family!

Happy holidays from McFarren Aviation Consulting! I look forward to working with you again in 2016.