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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

 

TWENTY YEARS OF FAA AC 00-56

A banal cliché overheard during political campaigns is ‘working together’. I figuratively roll my eyes at the lack of creativity in that diluted, overused utterance. Fortunately, despite cynics, there really are examples in governance where that term bore fruit.


Every government organization has its head; the Administrator, or Director for example. An oft heard refrain among those leaders is that the goals of the organization can’t be met without the active participation of industry; in other words, working together (there’s that term) to achieve mutual goals. So…are there examples of such collaboration? Without question, a paragon model has been the FAA’s Advisory Circular 00-56. But let’s not get ahead of the story.


To understand the profound impact the AC had on the industry, it’s important to understand the environment that existed at the time of its creation.


Bogus Parts: those were the trigger words on everyone’s lips in the early 90’s. News programs and articles were saturating the marketplace warning of the perils of bogus parts. In fact there was such a tumult that Politicians held public hearing on the issues, and many independent ‘experts’, airline representatives, trade Associations,  and FAA employees, among others gave testimony which at times painted a dire picture, and in some instances a somewhat sensationalistic, scary portrayal of the issues. At the conclusion of the hearings the Senate gave the FAA a list of problems that had to be fixed. In response the FAA established a special office whose charter was to fix the problems contributing to Unapproved Parts (or now commonly called SUPs – Suspected Unapproved Parts). Most of you recall Ken Reilly who headed that office for a long time and who, for his efforts was a recipient of the prestigious ASA “Eddy” award. But, back to the AC…


One of the problems cited by the Senate for the FAA to fix regarded the state of distributors. Unlike manufacturers, operators, and repair stations, distributors were not regulated, had no oversight, and were not required to implement and follow aviation style quality systems. It was felt that if bogus parts were to find their way into the industry, the weak link would be the distributors who supplied parts to both manufacturers and operators. There were some in the industry (and at first I counted myself among them) which took the position that distributors should be regulated and certificated by the FAA. At the time I recall a number being bandied-about was 2000 regarding the estimate of the number of distributors (including stockists and brokers) globally. Certificate that! As you can imagine, the FAA was not going to be funded to regulate even a fraction of that number. So, the standoff stood; what to do about the wild-west among distributors? Enter the draft of the AC 00-56, ‘Voluntary Distributor Accreditation Program.’ To be sure, there was government-industry collaboration in writing, editing, and fielding it. A few names that come to mind in that campaign are Dennis Piotrowski, Ed Glueckler, and Al Michaels (also an “Eddy” recipient) among others.


Out came the initial AC. The Air Transport Association (now Airlines for America, A4A) distributed it to their constituent airline members, and here was my first exposure to it. I was working for a major airline and was handed the job of determining what the airline’s position was going to be regarding its substance. In a rather large meeting held with the heads of Purchasing, Material Control, and QA, I introduced the AC and solicited feedback. There were, and still are two lines in the AC that stood out to this management group: “We (the FAA) consider obtaining parts through accredited distributors is a sound safety practice.” And “If a certificated customer uses an accredited distributor, and voluntarily reports any known potential violations of 14 CFR rules, we would recognize the fact that the certificate holder obtained the part from an accredited distributor as a mitigating circumstance in any subsequent administrative or enforcement action.”


The terms, “…sound safety practice”, and “…mitigating circumstance…” rang pretty well for this safety conscience airline. It took about 15 minutes of discussion and a senior Director gave the order to send out a letter to all its after-market distributors which stated they had a year to become accredited or risk being dropped from the airline’s approved supplier list, and oh yes, I was to administer this, and out went the famous letter to its suppliers. So-much for being a ‘voluntary’ program. Other airlines and manufacturers saw the benefits of the program and similarly used the program as a basis to approve their distributors. Thus steadily, the AC became a success and gained global acceptance.


And a trivia question: Who were the first 6 firms to be accredited? See bottom, beneath the web site listing.


Interesting: When the AC was being drafted there was the thorny issue of who would administer the listing of firms meeting the requirements of accreditation; the “Database Listing”. This is not just a simple matter of posting a listing on a web site. There are administrative procedures that must be followed, records kept, follow-ups, and yes the web site upkeep. Read paragraph 10 of the AC and you’ll get the picture. At first it was thought that the FAA would perform this task, but alas, this too was not likely to get funded. The ASA volunteered. In the AC, the FAA delegates the keeping of the Database to the ASA.  It’s an unheralded fact that the ASA has been flawlessly performing this mission pro bono since the AC’s inception; bravo ASA!


The FAA has twice updated the AC and participated in ride-along audits. The AC and the accreditation program is a living document. Every day there’s countless activity in many parts of the world triggered by the AC; Manuals being updated, external and internal audits being performed, training imparted, records updated, findings and non-conformities being addressed, Approved Suppliers Lists being updated, documents generated, orderly scrapping of parts, inspections performed, and rosters updated, just to name a few, and all in conformity with… AC 00-56.


September 2016; 20 years of a very effective cooperative effort between government and industry.


BTW: I know some of you may have additional details, names or stories to round- out this great accomplishment. If so, share them in the comments section of this blog entry.


Over ‘n out


Roy ‘Royboy’ Resto


www.AimSolutionsConsulting.com


Trivia answer: AVTEAM, Avio-Diepen, and AvioSupport were all accredited the same day followed by International Aircraft Associates, Baron International Aviation, and Norcross Air, Inc.
Posted By Roy Resto | 8/4/2016 9:37:16 AM
 

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