Steve Bentley MD of Sofema Aviation Services www.sassofia.com looks at issues with EASA 145 Engagement
145.A.45 Maintenance data
(a) The organisation shall hold and use applicable current maintenance data in the performance of maintenance, including modifications and repairs. ‘Applicable’ means relevant to any aircraft, component or process specified in the organisation’s approval class rating schedule and in any associated capability list.
(b) For the purposes of this Part, applicable maintenance data shall be any of the following:
1. Any applicable requirement, procedure, operational directive or information issued by the authority responsible for the oversight of the aircraft or component;
2. Any applicable airworthiness directive issued by the authority responsible for the oversight of the aircraft or component;
3. Instructions for continuing airworthiness, issued by type certificate holders, supplementary type certificate holders, any other organisation required to publish such data by Annex I (Part-21) to Regulation (EU) No 748/2012 and in the case of aircraft or components from third countries the airworthiness data mandated by the authority responsible for the oversight of the aircraft or component;
4. Any applicable standard, such as but not limited to, maintenance standard practices recognized by the Agency as a good standard for maintenance.
Question – Do Aircraft Maintenance Engineers always report any issues related to the correctness and presentation of Maintenance Data?
Answer – Well evidence suggests that this is not the case. In fact please ask yourself how many times you have reported into your internal quality System in the last year!
(you are not alone – now multiply this across the industry)
Maintenance Cultural Behaviour
One possible reason relates to a culture of under reporting consider Maintenance driven Sub-Culture.
To ask where do you stand on the following comments do you agree / disagree?
a) Engineers are trained problem solvers and troubleshooters;
b) They are committed to their own safety standards; they often doubt the need for all the controls, rules and auditing;
c) They see adversity as a challenge;
d) They work in teams, but as Individuals not as Team Players or use the strength of the team;
e) Engineers enjoy risk taking, even though it is error prone;
f) They have great faith in the ability to get the job done!;
g) They don’t like to be seen as not knowing something about the aircraft!;
h) They are highly reliant on their ability to memorize tasks and even part numbers!
i) Related to work, they are poor communicators!;
j) They are resistant to being monitored, or supervised!;
k) They are prone to believing they know better than the company or manufacturer’s procedures!
EASA identify the following as Regulatory Requirements –
145.A.45 (c) The organisation shall establish procedures to ensure that if found, any inaccurate, incomplete or ambiguous procedure, practice, information or maintenance instruction contained in the maintenance data used by maintenance personnel is recorded and notified to the author of the maintenance data.
To Consider what this means !
Means that the obligation to report is mandatory – In other words if you fail to report you become part of the problem! (But not only because potentially you are also exposing your organisation!)
From time to time we face issues with information which may be found to be inaccurate, incomplete or even written in a way which makes it ambiguous.
The Bad Stuff!
Do you have a notebook (a little black book) with “favourite” or hard to find part no’s?
Maybe we keep information regarding dimensions or limits – or other hard to find information.
(I certainly did for many years!) – However to ask the question why? (Note the catch 22 – problems can only be fixed if they are identified and reported)
So let’s be clear after many years of paying attention to Causal and Contributory Factors we know as an industry that such a practice is a far from acceptable and can even be considered potentially dangerous practice.
So How Should it Work?
a) We must have the controlled and managed information (Data) to support the task we are performing. (And we must use it!);
b) If there are any shortfalls or issues then again we must resolve – but in a documented way so we have effective communication within the business;
c) The Organisation must provide us with a process to report / and address shortfalls in the documentation / information. For our part we must understand and use this process.
Sofema Aviation Services provides more than 300 EASA Compliant Regulatory and vocational short courses for details please see www.sassofia.com or email team@sassofia.com
Next Steps
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