Airworthiness Decisions – Who Benefits?
Following our decision to apply for an EASA Part M Sub-part G approval, we will be creating a diary of our progress towards approval; targeting towards the end of Q1 2010. Additionally, this week, we are starting a series of articles highlighting, in a little more detail the benefits signing-up with an independent. This initial article is applicable to both private and commercial operators.
The options, with regard to Sub-part G, open to an owner/operator are fairly straightforward or so it would seem; it is a service provider aligned to the OEM or aligned to an MRO. However, there is a third way, an organisation not aligned with either the OEM or an approved MRO.
So why would an owner/operator enter into an arrangement with a stand-alone organisation?
I have seen a number of reasons why both private and corporate operators should think twice about their airworthiness providers, in particular:
- When an AD, with alternative means of compliance included modification or repetitive inspection, is issued, what is the recommendation? Are you told to terminate the AD with a change? Has a proper cost benefit analysis (CBA) been carried out for your operation, or are you just contributing man-hours to the MRO/Service Centre shop-floor?
- Where will the scheduled maintenance be carried out, where the aircraft is operated or where the MRO/Service Centre is based? What logic can be applied to flying a heavy business jet on a 500 mile round trip for minor maintenance that can be accomplished by a man and van or a local maintenance provider? Is it that a half-day maintenance slot has been sold in the MRO?
I would not say that all aligned serviced providers are explicitly guilty of the above actions.
As an independent service provider, all our decisions will be based on the airworthiness requirements of the aircraft and the operational environment that aircraft operates in. For all aircraft supported, ADs and SBs will have a comprehensive CBA completed; the analysis will decide the applicable course of action. Approved Maintenance Programmes will reflect the needs of the operator, not the requirements of the MRO/Service Centre.
Repetitive defects, the bane of all operators, and trying to meet a flying schedule, will they be coded properly and flagged as a repetitive defect? Or will the ATA chapter change? Defects can be costly, to both parties, the operator in terms of lost revenue or missing a departure slot or to the MRO if the contract has built-in performance guarantees. Accurate coding and intelligent analysis are vital to prevent operational delays to a minimum.
A stand-alone airworthiness management service provider may be slightly more complex to manage contractually, though not beyond the capability of today’s commercially aware operator, but will be so much more in-tune with the operator’s needs.
Keep watching, the next major hurdle will be the issue if the provisional approval number from the CAA and the allocation of a regional office.
There is a good argument for Operators contracting their maintenance including their planning and engineering including analysis of airworthiness requirements (be it ADs or repetitive defects) to one service provider an MRO in this case. The pitfall here, is the fact that the MRO may make decisions that are favorable to its business needs which may not be in the best business interest of the operator. The airworthiness status of the aircraft not being jeopardized in any case.
Contracting the services with an independent organisation will give the operator the ability to make decisions more attuned to its business needs, without of course jeopardizing airworthiness. Such an arrangement will have a higher work load in terms of the operator implementing their airworthiness decisions in a timely and efficient manner but will provide a better result in terms of savings and availability of the aircraft.
Oussama
Thanks for your supportive comments!
I agree, the “one-stop-shop” will not compromise the airworthiness status of the aircraft, it is just that the operators bottom line will be affected! Interface procedures and the use of technology will ease the management burden on the operator.
Regards
Malcolm