Adapt or Perish

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There is a serious disconnect in aviation between technology advances and regulators’ ability to adapt to changes. Why am I writing about this?

The General Accounting Office has released a report, the title of which says it all: "FAA Needs to Update the Curriculum and Certification Requirements for Aviation Mechanics." (See www.gao.gov/cgi-bin/getrpt?GAO-03-317 and story on page 43.)

Most technicians earn a federal certificate, the Airframe & Powerplant Mechanic certificate, by attending a school regulated under Part 147 of the FAA regulations. The GAO report noted that "the curriculum has not changed in over 50 years." Indeed, archaic skills are still taught and this doesn’t properly prepare technicians to work on modern aircraft. It is still a requirement, for example, that a student technician learn something about dope and fabric, although many schools have been able to minimize the level of training on this subject to where they don’t perform it in the lab. Part 147 does offer some flexibility in that schools can emphasize some areas while minimizing others. But the constraints of Part 147 are real, and the rules do hinder necessary training.

The reason that Part 147 as currently written hinders training is that schools are businesses and they must attempt to earn a return on the investments of their owners. Most schools, therefore, train as necessary to cover the requirements of Part 147. Many schools offer additional training in special subjects, such as avionics, but most students are there to earn their A&Ps, after which they work in low-paying jobs until they learn what the industry really wants them to know.

Running an A&P school is expensive, so much so that few A&P schools could earn a decent return on investment by training students beyond what the FAA requires. That’s what happens to an industry regulated by government.

So technology marches forward, and the important initial training of future mechanics stays still.

There is a parallel in the development of new technologies in aircraft, such as some of the exciting advances in avionics. How did rules requiring installation of devices like ground proximity warning systems, terrain awareness systems, flight recorders, etc. come about? Did some FAA official wake up one day and decide it was time for new rules?

No. Rules get changed, unfortunately, as a result of learning from our mistakes: fatal accidents. Most new safety requirements are the result of fatalities. If you’re wondering why some rules seem to get enacted quickly and others languish, it is because of accidents. A rule designed to fix an accident cause will always fly through the bureaucracy faster than one that is just a good idea.

Two recent examples: the proposed new FAR Part 66 and the updated Part 145 repair station rule. The controversial Part 66 proposal, which would modernize certification of aircraft technicians, generated a huge response from people in the industry and it still languishes at the FAA, for lack of resources and interest and the need to focus on more pressing matters. The updated Part 145 rule is coming, but has been delayed again. Is this critical? I don’t think so. It was considered critical after the ValuJet accident, which brought maintenance quality to the public’s attention. I don’t believe anything in the new Part 145 would have made a difference in the ValuJet case. Perhaps that is why the new rule is taking so very long to come to fruition.

Conclusion #1: If there were more fatalities attributable to problems with Parts 65, 145, and 147, changes to these rules would have happened long ago.

Conclusion #2: The FAA lacks a process by which technological advances can be rapidly recognized in the aviation regulatory environment.

There is no question that technology rapidly outpaces regulation. The question is, can we come up with a way to adapt regulation to the pace of technological change? Can we figure out a way to update Part 147, for example, to cover training for today’s aviation technician? Could Part 145 be more flexible so that it could adapt to changes not only in non-U.S. repair station regulations but also the business needs of modern repair stations? And couldn’t the FAA allow Part 65 to recognize the new ways that technicians ought to be regulated to insure a good inflow of new blood into this industry and to adapt to the need for technicians to be recognized as skilled professionals?

Technology allows for vast improvements in safety, reliability, and efficiency. Shouldn’t the process of regulation be able to change with technology instead of waiting for fatal accidents to force new rules with questionable benefits?

Thank you, Jim McKenna: We are sad, but happy, to report that our managing editor, Jim McKenna, has accepted a promotion to Editor-in-Chief of Rotor & Wing magazine, our sister publication. Jim has been an able and hardworking member of our team, and we are going to miss his excellent writing and editing skills. From all of us at Aviation Maintenance, we wish you the best, Jim. Congratulations!