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					 in this monthly column, ric peri of the AeA’s Washington, d.c., office, informs members of the latest regulatory updates.

                                b y      r i c     p e r i
                                                             vice pres idenT of GovernmenT & indUsTry AffAirs for AeA

The personal qualities that are characterized by conforming to the ethical standards of a profession.

        irst used in 1856, the word profes-          AEA membership is predicated on meeting             My comment to the AEA member was
        sionalism currently is a buzz word           a “quality” standard. A few of the members       simple: Report the apparent falsification to
        thrown around to promote a bureau-           were, and still are, strong advocates that the   the FAA immediately. The frustration for me
crat’s personal agenda. But, unlike some of          benefit of AEA membership should come            was the supplier was a former AEA member.
the other words, this is not one to dismiss          with a requirement for quality and profes-       In my view, there is no room for intentional
lightly. Recently, there were a few issues           sionalism. Whether by design or require-         falsification of records and forms.
on professionalism that caused me to think           ment, it has been my experience that the            Merriam-Webster defines profession-
about our industry.                                  members who commit to the tools and ser-         alism as the “personal qualities that are
   First, on June 23, 2011, the National             vices that AEA membership offers exhibit         characterized by conforming to the ethical
Transportation Safety Board published its            the best the industry has to offer. We don’t     standards of a profession.” Then, it further
“top 10 critical changes needed to reduce            need to mandate a quality standard. The          defines ethics as “the discipline dealing with
transportation accidents and save lives.” Of         membership exhibits professionalism and          what is good and bad and with moral duty
the top 10 issues, six are related to aviation,      quality, as well as pride in AEA member-         and obligation.”
and four of the six are directly, or indirectly,     ship on its own.                                    The AEA staff has offered thousands of
related to our segment of the general avia-             What got me thinking about this grand         training hours at its regular regional meet-
tion industry.                                       concept of professionalism was a recent call     ings and conventions and on the pages of
   The issues on the new most wanted list are:       from a member regarding questionable pa-         Avionics News to assist the members in their
   • Promote pilot and air traffic                   perwork from a supplier. As the paperwork        constant drive for professionalism. The asso-
         controller professionalism.                 was described to me, the original shipment       ciation provides the opportunity for training
   • Address human fatigue.                          was received with Federal Aviation Admin-        and education on the professional standards
   • Improve general aviation safety.                istration Form 8130-3 that didn’t match the      of aviation, as well as the moral standards of
   • Require safety                                  invoice, shipping documents or equipment         good business practices.
         management systems.                         received.                                           Let me add a note on the role of associa-
   • Improve runway safety.                             When the supplier was contacted, a re-        tions here. There is a small segment of the
   • Require image and onboard                       placement form was provided, but again           industry, clearly a minority position, that be-
         data recorders.                             it did not match the shipment. Following         lieves the maintenance industry, as a whole,
   • Promote teen driving safety.                    this run-around by the supplier, the des-        is somehow less than “professional,” and
   • Improve motorcycle safety.                      ignated engineering representative whose         that they need to belong to one group or an-
   • Address alcohol-impaired driving.               signature appeared on the original form          other to “make them professional.” Well, to
   • Improve bus occupant safety.                    was contacted directly. He responded that        them I say, get out of the rarified air of your
   One of the early discussions I had after          he hadn’t done any work for the supplier         corporate office, or in this case, your corpo-
joining the AEA back in 2001, was that               for more than three years.                       rate hangar, and breathe some fresh air. As-

   12    avionics news   •   august   2011
sociations are tools to enhance knowledge       by the FAA to be a “fraudulent or intention-        facturer (it is not an AEA member com-
and education; tools that enhance profes-       ally false entry,” which, unfortunately, di-        pany), its lack of professionalism places it
sionalism and not create professionalism.       minishes the importance of this standard. On        at the bottom of the industry. In my experi-
   The NTSB has recommended as one of           the other hand, some FAA inspectors have            ence, 90 percent of the industry exhibits the
its top 10 initiatives that the FAA should      claimed falsification to support their “witch       highest levels of professionalism. This case
“promote pilot and air traffic controller       hunt” against common industry practices,            demonstrates the intent and purpose of the
professionalism.” Why did they not in-          such as “rebuilding” antique aircraft, which,       incoming inspection required by the repair
clude mechanics and technicians? I sus-         in my opinion, is simply wrong. But, in the         station’s quality control system.
pect it is because our standards are better     case of the suspect FAA Form 8130-3, this              When the FAA reviews the repair station
defined, with little room for deviation with-   paperwork indicates that signatures were            manuals and audits the repair station quality
out resulting in a regulatory violation. The    photocopied, serial numbers were wrong,             control system, one of the elements it should
NTSB did include SMS, which injects a           and the paperwork itself was a reproduction.        inspect are the procedures the repair station
concept of professionalism in the manage-       I have little patience for intentional falsifica-   uses to receive and document the airwor-
ment role of maintenance and operations,        tion. May the FAA and the courts have their         thiness of received articles. The receiving
but that is an issue for another day.           way with this manufacturer.                         inspection should include a review for the
   What are the professional standards we
meet in aviation maintenance? It is the Fed-
eral Aviation Regulations (Title 14 of the             Whether by design or requirement, it has been my experience
Code of Federal Regulations). The moral
standards are those that drive businesses to           that the members who commit to the tools and services that AEA
be fair and honest.                                    membership offers exhibit the best the industry has to offer.
   Each year, I get the privilege of visiting
with nearly half the AEA membership as
they demonstrate one element of profes-            So, how did the issue arise? It was caught       proper documentation, identification and
sionalism – the pursuit of their continued      by an unregulated incoming inspection;              traceability of articles. If the article received
education and knowledge at AEA events,          simply good business practices. The AEA-            or its paperwork is questionable, then the
shop visits and other industry events.          member distributor utilizes a quality sys-          repair station’s suspected unapproved parts
   But, getting back to the paperwork is-       tem, which includes an incoming inspec-             procedures should be followed. Remember,
sue. The Federal Aviation Regulations           tion. Their incoming inspection resembles           this is for “suspect” parts. Once the part and/
takes falsification seriously. In fact, 14      the regulatory incoming inspection required         or paperwork has been reviewed and inves-
CFR 43.12 makes it clear that “no person        by Part 145. So, when the equipment was             tigated by the quality staff, further action
may make or cause to be made any fraudu-        received from the manufacturer, the receiv-         may, or may not, be required.
lent or intentionally false entry in any re-    ing inspector questioned the paperwork.                So, we have the FAA constantly re-
cord or report that is required to be made,     Their procedure elevated the questionable           minding us to be professional and the
kept or used to show compliance with any        paperwork to management for review and              NTSB including professionalism as one
requirement under this part.”                   analysis, and they contacted the manufac-           of its top 10 items. This is a reminder that
   The regulations continue with “the com-      turer and attempted to get the paperwork            not everyone in our industry exhibits the
mission by any person of an act prohibited      corrected. When the manufacturer contin-            highest level of professionalism, and that
under this section is a basis for suspending    ued to send suspect paperwork, the AEA              our professional business practices can
or revoking the applicable airman, operator     was contacted. And, as reported earlier,            detect and resolve unexpected and unusu-
or production certificate, technical standard   after reviewing the steps the member has            al supplier defects. Perhaps this is a good
order authorization, FAA parts manufactur-      taken to correct the discrepancies, the lack        month to remind ourselves of the high
er approval, or product and process specifi-    of response from the manufacturer and the           ethical standards we have chosen to fol-
cation issued by the administrator and held     seriousness of the actions, the only option         low in our businesses. It is an opportunity
by that person.”                                was to report the apparent falsification to the     to review our procedures and remind our
   We have had a few instances where hon-       FAA for investigation and action.                   employees and co-workers of the stan-
est paperwork mistakes have been claimed           While I am disappointed with the manu-           dards we are committed to uphold. q

                                                                                                            avionics news   •   august   2011   13

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