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.

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Aircraft Disassembly/Recycling’s AFRA BMP and the New IATA BIPAD

I detect that I have set a new personal record (woohoo!) for the amount of acronyms in a blog article title at four. If you’re reading this, you probably already have a good handle on what they mean, but more on that later.

Before we get started I wanted to make a suggestion to those of you who are responsible for maintaining those pesky Approved Supplier Lists required by nearly all quality standards. Many of you give automatic approval to firms who are accredited, for example, to the ASA-100, and are shown on the FAA’s listing of AC 00-56 accredited distributors. For firms who are accredited disassemblers and recyclers, the listing of such firms is maintained by the Aircraft Fleet and Recycling Association (AFRA) on the Directory Tab of their https://afraassociation.org/ website. For AFRA accredited listed firms, you too can also give them automatic approval for those services. Royboy’s counsel: As with the ASA-100, don’t confuse membership with accreditation. Although membership is always encouraged, membership alone does not guarantee a bona fide quality system.

A PRIMER:

Many years ago, with the forecasted accelerating growth of aircraft retirements, the industry recognized a need to retire and recycle aircraft in an orderly and uniform manor. AFRA, the Aircraft Fleet and Recycling Association (AFRA) stepped up and worked with many industry leaders to develop the Best Management Practices (BMP) for Disassembling and Recycling Aircraft. The BMP was and remains the basis for establishing a quality system to perform this work. It is also the basis for accreditation. Firms who demonstrably implement and uphold the BMP are audited, and upon passing are placed on AFRA’s list as previously mentioned. The BMP has been continuously updated by AFRA committees.

ASA and AFRA

All of you who attend the ASA conference will notice that the ASA and AFRA hold their conferences jointly. This is not coincidental. The members of each organization actually conduct a good deal of business with each other, and it is not unusual to find firms holding dual memberships and/or accreditations in each association.

IATA:

First, a little bit about IATA. From their website at www.iata.org:

“The International Air Transport Association (IATA) is the trade association for the world’s airlines, representing some 290 airlines or 82% of total air traffic. We support many areas of aviation activity and help formulate industry policy on critical aviation issues.”

That is really an understatement. For all of us that fly, IATA has been a globally accepted influencer and facilitator for airline business. For example, they have established standards and guidance for Baggage handling and ID, addressing tariffs, Airline coding, scheduling, ticketing and reservations, security, loading, fuels, costing, dangerous goods, finance, accounting, and leasing among many others. IATA’s stated mission is to represent, lead, and serve the airline industry. IATA has been presenting regularly at the ASA/AFRA conference and they always provide valuable global industry insight.

IATA’s BIPAD:

At 101 pages, IATA’s BIPAD document, Best Industry Practices for Aircraft Decommissioning, is rich in guidance aimed at aircraft owners or operators regarding business processes and operational experience from best practices in the industry. On the other hand, AFRA’s BMP is primarily aimed at firms actually performing aircraft disassembly and recycling. From my analysis, I concluded that the two documents are complementary, and in fact the BIPAD cites the AFRA BMP frequently. I like the BIPAD because for anyone contemplating an active entry into the disassembly and recycling market, the BIPAD provides additional data and guidance which could establish the basis for a business plan. There are some interesting and indeed welcomed sections of the BIPAD that I like. For example:

  • For those of us bothered by the continuing vagaries of Non-Incident Statements (NIS), the industry, bolstered by IATA, is moving to implementing an Incident/Accident Clearance Statement or ICS…bravo. The BIPAD further inculcates the idea of the ICS by inclusion in the document. For more information, see my previous article on this topic at https://www.aviationsuppliers.org/NON-INCIDENT/ACCIDENT-STATEMENT-NIS-and-INCIDENT/ACCIDENT-CLEARANCE-STATEMENTS-ICS
  • Appendix B contains “Examples of dangerous and hazardous materials to be removed and treated from aircraft”. This is welcome since currently there does not appear to be any other such listing, and the industry needs awareness and certainly training on the issue.
  • Insightful case studies regarding potential value and the market for removed parts.
  • Useful economic overviews.
  • Chapter 2 titled “Decision to Decommission” is richly insightful and informative for operators regarding the decision process, possible outcomes, and issues to be aware of. It includes such nuggets as Accounting Principles, Aircraft Value Concepts, and Regulatory and Legal Aspects.
  • Chapter 3 contains specific suggestions regarding topics which employees involved in this activity should be trained on.

ICAO’s influence.

Like IATA, the International Civil Aviation Organisation has, and continues to exert a great influence on existing and emerging global aviation regulations and procedures. The BIPAD acknowledges this with the following:

“The International Civil Aviation Organization (ICAO) supports activities related to aircraft end-of-life and recycling. At its 39th Assembly in 2016, States were requested to: “consider policies to encourage the introduction of more fuel-efficient aircraft in the market, and work together through ICAO to exchange information and develop guidance for best practices on aircraft end-of-life such as through aircraft recycling9.

ICAO has signed a Memorandum of Understanding (MoU) with the Aircraft Fleet Recycling Association (AFRA) to enhance cooperation and development of best practices for the management of aircraft end-of-life processing 10.

In its Environmental Report 2016, ICAO has further reiterated the need for aircraft life cycle assessments which includes a report of best practices implemented by AFRA and Bombardier in managing an aircraft’s end-of-life 11.”

It should be clear that ICAO, IATA, and AFRA are harmonized in their support of orderly and standardized aircraft retirement practices as embodied in the BMP and BIPAD.

By the way, for those you wishing that someday there would be a single set of globally accepted regulations, it will likely come from IATA and/or ICAO. Imagine, a Repair Station/AMO who only needs a single 145 approval rather than ten to do business internationally. Just sayin…

Over ‘n out

Roy “Royboy” Resto

President/FAA-DAR

AimSolutionsConsulting.com

  • Posted By Roy Resto | 2/1/2019 11:49:16 AM
     

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