You’ve been ‘listed’. That could be good or that can be bad! If you’re on a no-fly list, that’s bad, but if you’re on any of the following lists, consider yourself privileged.

Whether you call it a Roster, Registry, or Listing of Authorizations, they all essentially mean the same thing: It’s a tabulation of names and the listing of tasks they are authorized to perform. Let’s amplify this, and by the way, regardless of what you call it, in this article I’ll use the generic term, Roster.

In aviation, whether you are a manufacturer, operator (airline, Air Force, etc.), AMO/Repair Station, or accredited distributor, all have their versions of Rosters. Here’s a small sampling of some of the many types of programs requiring Rosters:

Manufacturers:

• MRB- Manufacturing Review Board: During the manufacturing process, a non-conformance was discovered. The persons authorized on the MRB listing (a type of Roster) may jointly conclude that the issue does not affect safety, and then issue instructions to rework and/or place it onto its next higher assembly. On the other hand, they may conclude it needs to be scrapped.
• ODA- Organization Designation Authorization: In short, ODAs can perform certifications as delegated by the FAA. ODAs must have a listing (Roster) of the persons authorized to perform specific duties in the certification process¹.
• Conformity Inspections: Whether you are an EASA, FAA, TCCA, ANAC or any other approved manufacturer, someone will have to signoff that the product/article conforms to its design; I guarantee you they are on a Roster of some sort, authorizing them to do so.

Airlines:

• MRB- Maintenance Review Board. During Maintenance, a non-conformity is documented. The persons authorized on the MRB listing (a type of Roster) may jointly conclude that the issue does not affect safety, and then issue instructions to rework and/or accept it as is. On the other hand, they may conclude it needs to be scrapped or replaced.
• RII- Required Inspection Item: The performance of some items of maintenance are considered so critical, possibly affecting safety, that the accomplishment has to be signed for by both the technician and a ‘second set of eyes’, the RII Inspector. Typical maintenance actions requiring RII include engine changes, landing gear changes, flight control repairs including rigging, and pitot-static systems maintenance.
• Category III C Avionics Maintenance: A category III C approach to landing is a precision approach and landing with no decision height and no runway visual range limitation. Persons performing maintenance on the avionics systems affecting this capability must be authorized to state or reinstate the aircraft to this level of capability.
• Borescope Inspections: All borescope inspectors must be authorized to perform this task.
• Return to Service: Signing off that the part/aircraft is now airworthy: Return to Service authority after any maintenance generally falls into two categories; the whole aircraft or components such as maintenance on rotables/LRUs.
• Cannibalization/Robbed Parts: Only certain persons may have the authority to authorize the taking of parts from one aircraft to install it on another aircraft².

AMO/Repair Stations:

• Return to Service: Signing off that the part/aircraft is now airworthy: Return to Service authority after any maintenance generally falls into two categories; the whole aircraft or components such as maintenance on rotables/LRUs.
• In process inspections: Authority to sign off routine tasks where the signature line or block says “Inspector”.
• Larger AMO/Repair Stations such as those that work on entire aircraft likely have some of the same Rosters as those mentioned in the airline section.
  

ASA-100 Accredited Distributors:

• Receiving Inspections: Persons Authorized to perform visual inspections of the parts and documentation during receiving.
• Shipping Inspections: Persons Authorized to perform visual inspections of the parts and documentation during shipping.
• Hazmat: Persons authorized to handle Hazardous or Dangerous Goods material.
• Signing Material Certifications or their equivalents. Persons authorized to sign the distributor’s C of C, Material Certifications, or equivalent.
• ESD: Persons who are trained and authorized to handle and inspect ESD parts.

Qualifications to be added to a Roster:

Regardless of what type of entity your firm is, your system of manuals will contain a procedure which details the requirements which must be met in order for a person to be added to the Roster. For example, the ASA-100 Standard in paragraph 4.B. calls this “Authorization criteria.” Depending on the criticality of the task, the criteria by which one becomes qualified for the Roster may consist of, or a combination of, training, recurring training, experience, education, or credentials including licenses, permits, or education.

The importance of being on a Roster:

During my career I have had the privilege of being on many Rosters including RII, Return to Service for aircraft and components, MRBs, Conformities, and many more. If you have ever been on a Roster, detail it on your CV/Resume. Being on any Roster is a career milestone and should never be taken lightly no matter how mundane the task may feel. In this regard I’d especially like to reach out to our friends in the Accredited Distribution community. It is known that distributors don’t perform any actions regarding airworthiness or maintenance, and that their own certs are not airworthiness documents. I’ve often thought that this realization may contribute to some persons on the Roster trivializing their role. Nothing could be further from the truth. I’m constantly impressed with the quality of the non-conformities or discrepancies found by distributor inspectors regarding their visual inspections and review of documents.

For some distributors, Royboy offers this counsel:

• Do you have sales persons on your Roster? Be careful, it has been found that such persons, who are under pressure to meet sales goals, may become conflicted when performing inspections.
• Do you have management office people on your Roster? I’m finding that in some cases these employees have not performed inspections in a long time. The look of surprise on their faces when I call on them to perform the functions they are listed for on the Roster is priceless. In some cases I’m told “…but Roy, he’s the President!”, to which I retort “…but he’s on the Roster…”. This is followed by a pregnant silence, followed by a revision to the Roster, recurrent training, and/or an NCR for not being able to follow the procedures.
• Don’t take the process lightly. The concept of a Roster for distributors follows a well- established aviation industry practice. The process of placing employees on your roster should be the result of circumspect selection.

Of course, for small companies it must be recognized and accommodated that employees have to ‘wear multiple hats’. Understood and acknowledged, but be careful.

Keeping the Roster Current:

In this time of staff adjustments there are occurrences where the Roster is not being kept current. For some Rosters which are regulatorily required, the rosters must be updated within 5 days of the staff changes, for example FAR 145.161 (b). Regardless, it’s a reflection of your professionalism and attention to detail to keep these current.

Roster variations:

Some Rosters not only have the names and authorizations for the listed employees, but also contain additional information such as:

• The Employee’s signature and initials.
• The Employee’s Stamp impression.

Support for employees on the Roster:

For employees on any Roster, they must be given the authority and independence to perform their duties without fear of retribution or loss of their employment. Management’s support for such employees says a lot about the safety and quality culture of the firm.

Over ‘n out

Roy ‘Royboy’ Resto

AimSolutionsConsulting.com

¹ For more information see this previous article titled “MAX, ODAs, BABIES, AND BATHWATER”:

https://www.aviationsuppliers.org/max-odas-babies-and-bathwater

² For more information see this previous article titled “Cannibalizing, Robbing, and Swapping Aircraft Parts”.

https://www.aviationsuppliers.org/Cannibalizing-Robbing-and-Swapping-Aircraft-Parts