WHITE PAPER: EMPOWERMX
possible to address every one of those: but it is necessary to look at the paperless operation and know what the scope is and what the high level plan is. Consider it as the corners of a canvas when getting ready to paint a picture, first identifying the corners of the canvas — that’s the high level plan that needs to initially be taken to the regulator. • It’s very important to bring in the affected regulators early and often and let them know the general intentions. There doesn’t have to be an entire plan figured out when that first approach is made to the regulators; it’s the involvement that counts. I’ve found a successful approach is to go to the regulator and say… ‘We just want to let you know that paperless operations are happening all around the world and we’re going to head in that direction and want to let you know that we’re considering a program or project that will address electronic signature: we’ll keep you involved to make sure you’re comfortable that the things we’re doing meet your requirements and we’re giving you an early advanced notice’ That has been a critical part of people’s success, bringing in the regulator early in the process. • Identify those elements that will need to be accepted and approved by the regulators. We’ve identified a few above (Baseline Regulator Requirements), including six that will be of key importance. Some of my customers have taken those six items and built their plan around them asking, ‘how are we meeting the objectives of each of those requirements in that regulation?’ • Develop a detailed approach for implementation of the program and electronic signature meeting all of the regulator’s requirements. This is where it’s time to develop the detailed approach but readers might say that they’ve not done that before so where would they get the details, they don’t have the expertise or know what to do. The answer is to find someone who does know what to do and has been successful at accomplishing
these things, and use their experience with the regulators to be able to create a detailed plan that will also be successful. • Secure agreement from the operator / customer. Some readers will be from airlines, some will be from MROs, some from consulting organizations, many different types of operations. There are a few key things, in my experience, that have caused significant risks and delays in a program. AIRCRAFT IT MRO • MARCH-APRIL 2019 • 39
• The availability of data has been one that’s
been a risk in a program from the beginning.
• Changing requirements from the operator or from the customer.
• A regulator that didn’t know what the
company was doing and, at the last minute, decided they wanted to make changes. In a recent large implementation at an MRO in the USA, two days before the program was going