Probably not two activities that you think would be linked in any way; but there is a link – commercialism!
There are similarities:
- Both are subject to globally agreed regulations, EASA, FAA and the IRB
- Both are seeing the accepted regulations circumvented by commercial pressures
Let me set the scenarios.
I referee and coach youth rugby, colts, in particular. I have been watching this year’s world cup with enjoyment, tinged with disappointment that Scotland came home before the quarter finals for the first time, and a growing sense of frustration that the Laws of the Game (LofG) have been hi-jacked at this elite level by the needs of television, or commercialism. I am faced on a Sunday morning with boys, coaches and parents who complain because I apply the LotG, as they are written down and not in the way they are shown on television. The commercialism of television coverage wants the ball to continually be in play and rewards the team in possession; television does not want the tactical nuances of the game, because they are not appealing to a mass market.
I know that next week, next month and next year I will have the same discussions with players, coaches and parents over interpretations about the contact area; I will receive letters and directions through our referees society instructing us to apply the LotG and yet live rugby on the television will not reflect the game I have to deal with on a Sunday morning.
So where is commercialisation distorting airworthiness regulations, how are regulations overseeing safe commercial flying operations being circumvented? We all know that aircraft are assembled with a range of components, those requiring scheduled maintenance interventions and those that do not require any maintenance actions, except when they fail. They are then routed through an appropriate back-shop and released back into service. They will be issued with an applicable release certificate; an EASA Form 1, F8130 or equivalent. The release paperwork will be completed in accordance with an approved company procedure derived from the international standards. The release paperwork will contain the legally required information for that component as defined by the Vendor.
I have seen a lessor saying that for on-condition components, that is not enough; the lessor wants to know the date of manufacture, hours and cycles consumed. The fact that it is an on-condition item, it is not necessary for the overhaul facility to detail the utilisation or hours consumed; if it is on a second or subsequent shop visit the data may not be available. The airline is then required to spend time and effort either trying to identify the utilisation or replacing the component with one that has got all the utilisation data available.
The lessor’s rational is that the average age of all the components fitted should be less than the age of the aircraft. If that was the case, with a new aircraft on the first lease transfer, all components changed during its service with the airline should have come from the fleet leader, and there should be a disproportionally high number of on-condition components changed. With the logistics systems being what they are this would not happen a proportion of components will be new items. When discussing this with the lessor, their default position is, read and understand the lease you have signed! This can be difficult when an airline is purchasing spares from a range of suppliers under a range of conditions, from scheduled maintenance through to AOG!
What does it mean for the future? The regulators, the IRB, EASA and the FAA must either:
- Stand-up and say there is no need to amend the current regulations and ensure that there is not this erosion of regulations, or;
- Amend the regulations to reflect the new reality; to do this they must tell those of us affected by the changes why they are changing.
In either case it will result in higher costs for the airline(s); there will be perfectly acceptable, from a regulatory standpoint, components that can not be able to be fitted, there will be a requirement for changed processes and an increased number of new items. Airlines not being charities, costs will have to be passed on, to you and I. For me, on a Sunday morning I will continue to be questioned by boys, coaches and parents who do not understand the difference between entertainment and sport!
As always I look forward to your thoughts!
