
Roy Resto
VP Technical Operations
FAA-DAR
Direct: 414 875-2191
Cell: 414 467-3063
Fax: 414 875-0200
royboy@tracercorp.com |
(Thursday,
Nov 2nd, 2006)
Rethink
Those Airline Manuals
If you’re reading this,
then this blog somehow made it through the institutional
censors. Of course, everyone abhors the thoughts of “censors”,
so these guys refer to themselves by the more palatable
term “proof readers”. Professional proof readers call
themselves Editors, and if you make a living writing, you’d
better be careful to appeal to your target audience lest
you find yourself edited out the door. OK, enough fun
with this sarcasm.
Businessmen and academia
are perpetually analyzing the differences between legacy
carriers and low cost carriers, and the contribution of
those differences to profitability or the lack thereof.
Having worked in both airline and MRO operations, there is
one practice I’ve observed that perfectly illustrates an
example of the demarcation of legacy and low cost
airlines; many legacy airlines continue to cling to the
practice of requiring their MRO shops to use their
airline-specific component maintenance manuals, whereas
the low cost carriers tell their MRO shops to use the OEM’s
Component Maintenance Manuals (CMM’s).
Airlines that have their
own component maintenance manuals call these manuals by
various titles which include: Engineering Orders,
Engineering Specification Orders, Engineering Repair
Authorizations, Central Engineering Manual, and
Engineering Specifications. These manuals usually contain
information that is specific to that airline such as
repairs, inspections, modifications, or part numbers that
are variations of the OEM’s CMM. These manuals typically
evolve because of the airline’s effort at operational
and product improvements, and employee suggestion
programs.
Before we go any further
down the path I’ve suggested with this blog, I’d
better point out two things before someone starts wagging
their index finger at me. We all know there are FARs
requiring repair stations to perform their work in
accordance with the operator’s manual when the operator
specifies such manuals; understood and acknowledged,
and yes it will be so accomplished. The other is that
I have to speak in generalities, so I must acknowledge
that there are variations in carrier size, legacy or low
cost, as to the use of these manuals. Nonetheless, for the
purpose of this blog, I’m sticking to the
characterization of legacy and low cost carriers I made
earlier.
Consider this quick, yet
characteristic example:
- You’re a repair
station, and as such are expected to pay for the OEM
subscriptions for the manuals required by your
capabilities list. You, the repair station pays for
the subscriptions and internal distribution costs of
the publications. Routine, right?
- On the other hand assume
you’re an airline with those peculiar airline
manuals. You, the airline are responsible to pay
for the publication and distribution costs to your
internal shops or MRO suppliers.
If you have hundreds or
perhaps thousands of those manuals, just the
administration of those manuals is likely an intricate
process.
Is that it?
Lets amplify this a bit.
For those hundreds or
thousands of airline manuals, the airline will have to:
- Staff a publications
department
- Keep careful and
controlled lists of suppliers or internal shops
authorized to receive them
- Keep careful and
controlled lists of the revision status of the manuals
- The airline will have to
pay for the distribution costs, whether on CD, DVD,
PDF, hard copy, or internet access
- Since nearly every
airline manual uses portions and parts of the OEM
manual (if not entirely), then every time the OEM
sends out a revision to their manual, it most of time
will require a revision to the airline manual. So,
dedicated staff have to receive all these OEM manuals
(usually the publications department) and process them
for revision approval.
- Who approves of these
OEM derived revisions? Usually the respective
engineering staff. So yes, you will have additional
engineering staff
- If you want to add
something, anything, to the manual, this too will
require engineering staff resources to research and
initiate the revision. For example, if you wanted to
include a repair that the OEM manual does not contain.
- The Quality Auditors
over your MRO suppliers will have to assure your
manuals are being used.
- You will have to
consider that since you are imposing additional
requirements on your MRO provider, that the additional
handling costs
associated with your peculiar requirements will be
passed on to you
- If you surplus your
parts inventory for any reason (fleet downsizing,
fleet retirement, STC’s etc.), you must consider
that all the serviceability documents hanging on your
parts say they’ve been processed in accordance with
your manuals. In order for someone to buy these
otherwise serviceable parts, they will have to send
them to a repair station to be processed per the OEM
manual, and to possibly de-modify the part back to its
original configuration. This
means that either your parts are less marketable, or
that your parts will cost less, to cover the required
repair station visit; perhaps both
Is the bureaucracy and
additional costs of this arrangement coming into focus?
Predictably, if you desire
to eliminate this system, its biggest defenders will be
those whose turf is being threatened. They may even cite
the “S” word (safety), and that the airline has
enjoyed operational advantages because of this system. Oh
really? I don’t seem to recall that legacy airlines
using these systems have any advantage in safety
statistics, dispatch reliability, unit costs, or on-time
performance, over the Low Cost Carriers (LCC). Hmm...
Legacy airlines who are in
or threatened by bankruptcy, or LCC’s, must make hard
choices regarding operational changes that can potentially
contribute to greater efficiency. This blog suggests that
eliminating these burdensome and bureaucratic systems will
make their operations more efficient, reduce their repair
and overhaul costs, and make their surplus inventory more
marketable.
I have an airline buddy who
actively participated in his company’s suggestion
program. He informed me that the idea presented in this
blog was the frequent subject of many suggestors...to no
avail. When
employees from different quarters make the same
suggestion, the light should come on, somewhere, so why
weren’t these approved? The defenders were too
entrenched and numerous; music to ears of LCC’s.
♫ “And the band
played on...” ♫
(Lyric from the Temptation’s,
Ball of Confusion)
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