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Return to Committees > Forums and Blogs > Industry Issues Blog

CAVU Café: Royboy’s Prose & Cons

*Note: The views expressed in CAVU Café: Royboy’s Prose & Cons blog are those solely of the writer and are not necessarily shared by the Aviation Suppliers Association or the Association’s staff, members, or Board of Directors.

 

   About Roy Resto

 

NON INCIDENT/ACCIDENT STATEMENT (NIS) and INCIDENT/ACCIDENT CLEARANCE STATEMENTS (ICS)

What potentially, do all of the following have in common, which may occur in flight or while taxiing? A Pax dies of natural causes, lightning strikes, hale damage, bird strikes, FOD damage, hard landings, tail strikes, or bent metal caused by impacts with ground equipment or other aircraft. Answer: Depending on varying broad definitions, these, and many other scenarios all have the potential to be categorized as accidents or incidents. In fact it has been my experience that given a mature aircraft, it would be difficult to find any serial number that has not experienced some sort of accident or incident. Perhaps it’s that realization which causes purchasers of aircraft, engines, and components to continue to ask for Non Incident/accident Statement (NIS) or Incident/accident Clearance Statements (ICS).

Before I get into NIS/ICS’s I’m wont to address the neglected issue of the rather portly pachyderm reposing in the parlor. We need to clearly establish that NIS/ICS’s are not regulatorily required! So why the continuing requirement as if it added some sort of value to the transaction? Assuming the transaction requires the asset be in airworthy condition, you will get the applicable documentation attesting to such airworthiness. Any past history of accidents or incidents does not detract an iota from the stated status of airworthiness! And ‘so-what’ if that part flew on a military platform? Are all the now civilian airworthiness documents in order? I continue to shake my head at practices that add cost but not value, and this is one of them.

ME:     “So Joe, why your need for an NIS?”

JOE:    “Royboy, because it’s a requirement.”

ME:     “Really? Why, what reg’ is that?”

JOE:    “Hmm, I’ll have to get back to you on that”

ME:     “So… why?”

JOE:    “Because it’s on my checklist.”

ME:     “Why?”

JOE:    “Because it’s in my manual to do so.”

ME:     “Why?”

JOE:    “Because we have always done it that way.”

 

And there you have it: the root cause within 5 ‘whys’.

Alas, I suspect many of you will agree with the aforementioned, but posit that the practice is too entrenched, and that the right people don’t get it…which will bring me back to NIS and ICS’s.

At the last ASA conference, during the QA Committee meeting, Tom Kolesar gave an introduction to a project that the Aviation Working Group has accomplished. According to their web site, AWG is a

“not-for-profit legal entity comprised of major aviation manufacturers, leasing companies and financial institutions that contribute to the development of policies, laws, and regulations that facilitate advanced international aviation financing and leasing”.

It seems they have put forth a neat, standardized set of ICS’s. Some feedback I’m getting from various sources seems to indicate the ‘form’ is gaining popularity. Friends, I’m all for standardization.

By the way, AWG has coined the term ICS to replace NIS.

Aiding in the AWG’s rollout of the ICS, it seems that IATA, the International Air Transport Association, has embraced the ICS, typically in a Document titled “Guidance Material and Best Practices for Aircraft Leases.”

According to the AWG’s Guidelines document for the ICS,

“The purpose of this incident/accident clearance statement is to remove the focus from whether or not an aircraft/engine/part has been subjected to an accident or incident and instead declare that the aircraft/engine/part has been deemed acceptable for continued use.”

Bravo.

There are two formats; one for Aircraft and one for Engines. The one for Engines can be formatted for components. Interestingly, the Guidelines suggest that if desired, the language can be added to the traditional ATA Spec 106.

Neat.

Although you can google the documents, I’m going to post below the fundamental elements of the ICS for your perusal:

To Whom It May Concern:

Engine serial number [insert ESN], details of which are specified below, has been operated by [insert company name] during the period from [insert delivery date] to [insert redelivery date].

Configuration details as of date of this statement;

Description  Type/Part No.          Serial No.      TSN    CSN

I hereby certify that, to the best of my knowledge, during the period stated above:

1. Neither the engine, nor any part installed have been

a. damaged during, or identified as the root cause of, a reportable incident or accident as defined by Annex 13 to the  Chicago Convention, or

b. subjected to severe stress or heat (such as in a major engine failure, accident, or fire) or has been submersed in salt water, 

unless its airworthiness status was re-established by an approved maintenance organisation in accordance with the instructions of the type certificate holder and/or OEM of the part, and supported by an authorized airworthiness release certificate.

2. No part has been installed on the engine which was obtained from a military source or was previously fitted to a state aircraft as deemed by Article 3 of the Chicago Convention.

Again, this can be modified for use on components.

Lastly, I’d like to address another neglected issue; that is, the use of the words “…to the best of my knowledge.” I have heard some make disparaging remarks about the choice of these words as if it diluted the sincerity or validity of the attestation: it does not. I prefer to think that the person is being honest, and that between the lines the meaning is: …at the moment I signed this, presented with all the information available at the time, I attest that…

It’s my opinion that in order to bring a modicum of stability and clarity to the issue of Non Incident Statements, we should encourage the use of the AWG’s ICS.

Over ‘n out

Roy “Royboy” Resto

www.AimSolutionsConsulting.com

Posted By Roy Resto | 10/15/2015 4:02:11 PM
 

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