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 recycling” 9.
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