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Technical Documentation Management, Aviation Safety, and Regulatory Compliance: Strategic Pressures, New Solutions for Flight Operations

TechPubs, Inc September 2008 www.techpubsglobal.com


Technical Documentation Management, Aviation Safety, and Compliance: Strategic Pressures, New Solutions for Flight Operations

Regulatory

Executive Summary Airlines face a difficult business environment, made more challenging by mounting regulatory pressures. Technical Document Management (TDM), an often-neglected area, promises relief, notably in flight operations. But to date, TDM solutions, adopted by only a few innovative carriers, haven’t matured to the point of holding appeal to the industry as a whole. In their current incarnation, such systems can be costly to implement, built without the flexibility airline growth demands, and insufficient for the reporting requirements of increasingly vigilant regulators. That’s changing. This document describes a new breed of solutions that straddles a middle ground between two common approaches to airline TDM. These new solutions promise dramatic improvements in information quality, revision, reusability, reporting, and other factors – for flight ops and across the airline enterprise.

Aviation Safety & Regulatory Compliance: Pressure Builds Recent developments in aviation safety regulation and compliance require a fresh look at flight operations processes, and specifically, the substantial complement of technical documentation that forms their foundation. It’s no exaggeration to say that airlines run on data as much as on fuel. Managing the myriad technical documents that describe and control daily flight operations is a challenge familiar to all carriers. Lately, however, aggressive, more expansive safety regulation and compliance developments have raised the ante in this area. Across the industry, carriers are forced to reconsider their technical document management (TDM) strategies. They’ve embraced the idea that TDM is more than another detail of the aviation IT, since regulators are taking a closer look than ever at flight operations processes – and all-too-frequently, finding problems with what they see.

Recent developments Recently, airline regulatory events have been in the headlines. It’s too simple, however, to assume these actions have exclusively concerned maintenance shortfalls. While maintenance has been at the core several incidents, flight operations are struggling equally with more intense regulatory scrutiny. Notably, the US Federal Aviation Administration’s (FAA) 2007 actions against Southwest Airlines, resulting in a $10 million fine, concerned mandatory inspections for structural damage - a familiar maintenance issue. But the situation has prompted Southwest and other airlines to review their technical publications needs across the board, through to and including flight operations. More pertinently, when the FAA in 2008 alleged that American Airlines flew two planes judged to be unsafe to operate under certain conditions and “not airworthy,” there was more at issue than maintenance. Specifically, the action related to parts on the minimum equipment list (MEL) that are variously required depending on the specific flight routes involved – a not-unusual instance of maintenance items that “spilled over” into flight operations. In short, the FAA and other regulators – as well as the airlines themselves – are less inclined to restrict their oversight to individual “silos” of airline activities, like

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Technical Documentation Management, Aviation Safety, and Compliance: Strategic Pressures, New Solutions for Flight Operations

Regulatory

maintenance. They’re beginning to perceive the technical documentation issue in a broader perspective.

A Global Concern The problem isn’t restricted to US carriers, of course. International oversight bodies, notably in the EU, are paying greater attention to such concerns, with impacts at the carrier level and beyond. For example, a July 2008 EU Commission report noted that …The Commission received on 16 May an update on the progress of implementation of the corrective action plan by the competent authorities of Indonesia. Relevant documentary evidence… demonstrates that the national authorities do not have, at this stage, the ability to ensure the oversight of the carriers they certify (including Garuda Indonesia, Ekpres Transportasi Antar Benua, Airfast Indonesia and Mandala Airlines), in particular with respect to the area of flight operation surveillance. (Official Journal of the European Union, 25.7.2008; emphasis added)

The implications of these developments are dramatic. Not only are individual carrier operations affected; an entire domestic commercial aviation industry in one of the world’s most populous nations is jeopardized - chiefly because of an inability to “surveil” pertinent flight ops processes. In short, Indonesian carriers are banned from EU landings because their processes are poorly documented, not verifiable, or both – a basic technical documentation concern. Similar circumstances are common in commercial aviation throughout Africa, Asia, and the Middle East. The core of the regulatory challenge is a carrier’s ability not only to follow welldocumented, demonstrable flight ops procedures, but also to document compliance with them to regulators. Specifically, the situation mandates a new way of demonstrating that a) compliant processes are in place; b) they’re fully documented, easily updated, and constantly available to appropriate personnel; and c) they’re routinely followed in day-to-day operations. The implication: lacking a flight operations publications strategy that recognizes these emerging compliance issues presents a strategic challenge to airline operations, far beyond what once was considered a mundane IT issue.

What cost safety and compliance? In general, three main economic benefits flow from improved technical publication management: 

The enhanced flight operations efficiency that results from personnel better equipped to perform their functions with the freshest, most reliable technical information.



The avoidance of liability (and related costs) in the event of an accident owing to poor document management, even if only peripheral to the event.



The mitigation of costs related to regulatory compliance – a potentially huge impact if, at the extreme, regulators choose to shut down day-to-day flight operations over poorly documented processes.

It’s this last consideration that has moved TDM from an operational concern to a strategic issue – and from just another item in the IT queue to a focus at the highest levels of airline operation.

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Technical Documentation Management, Aviation Safety, and Compliance: Strategic Pressures, New Solutions for Flight Operations

Regulatory

Technical Documentation Management: Alternatives All airlines have a technical documentation management strategy, in some form, whether it’s explicitly “documented” or not. On one extreme, many airlines persist in handling the bulk of flight operations documents by hand, on paper. It’s a convenient, entirely “portable” solution for flight ops personnel, but is of course difficult to maintain, unavailable to remote personnel, and woefully inadequate for compliance monitoring. On the other end of the spectrum, a handful of innovative carriers have implemented sophisticated systems to provide flight ops personnel with documentation that’s managed and distributed electronically, on the ground and in the air. But to date, such systems have been built with a patchwork of incompatible systems that impede efficient updating, broad distribution, and, most critically in the current regulatory environment, immediate and accurate reporting on compliance with safety mandates.

Fleet 2

Engineering Orders (EO /EA) Job Cards ECRA MSA

FAA

EFB Laptop

Fleet 1

Airworthiness Directives (Ads)

CAA

NAA

Flight Ops (FOM) Min Eq List (MEL) Fueling Man. (FM) Training (SCORM)

Fleet 3

FTP ATA 100 ATA 2100 ATA 2200 S1000D Gen Maint Man. (GMM) Tech Ass Req. (TR) Cust Orig Change (COC)

Operations Oversight Failure Rates

Maintenance

Quailty Control

SneakerNet

Field Notices Compliance

AMM EMM SRM CMM

AIRBUS

Engineering

CD-ROM

Aircraft OEM BOEING

Collaboration

Planning

Records Library

(IPC) (WDM) Engine (IPC) Service Bulletins (SBs)

MRO Provider

Email

MRO Provider Maintenance Squedules Overnight RON A,B,C,D Checks

MRO Provider

1

The typical airline document management landscape is littered with incompatible "silos" of information, lacking facility for easy updates, data reuse, and reporting

Let’s take a high level look at the problem. At its heart, aviation technical documentation is a set of rigid requirements, processes, and equipment details with cross- (and extra-) organizational uses. The data management challenge is multi-faceted: information arrives in a dizzying array of formats, from multiple suppliers; destined for an audience that literally spans the globe; and that necessitates highly flexible methods of accessing, viewing, reviewing, commenting on, and in many cases, editing the content, while maintaining a foolproof “paper trail” throughout.

The Case for a Document “Warehouse” It’s no great leap to understand the general need for a central data repository to a) “ingest” the full range of incoming content, regardless of format; b) transform it into standard, easily manipulated forms; c) distribute it to a huge population of downstream consumers, within and external to the carrier; d) constantly track and

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Technical Documentation Management, Aviation Safety, and Compliance: Strategic Pressures, New Solutions for Flight Operations

Regulatory

record changes made over time; and e) support a flexible set of reports and other uses of the data, notably but not exclusively for regulators. Though necessary, however, a documentation-centric airline-wide database is not in itself sufficient. There are many such commercially available systems, already in use within the industry, with mixed results. A closer look suggests two elements are required complete an airline-appropriate TDM solution built on this foundation: a) A comprehensive set of aviation-aware, function-specific applications for delivering useful reports and data manipulation tools to downstream personnel, and b) The industry-specific expertise to customize the entire solution for each carrier’s unique requirements. In light of these high level requirements, let’s compare two common approaches to the TDM problem, and discuss how a middle road promises a better future.

Why Best Efforts Fail: “Band Aid” vs. “One Off” Solutions In an effort to produce a useful TDM solution according to the framework above, forward-thinking airlines typically turn in one of two directions: stage a do-ityourself effort to wire existing systems together to solve the obvious problems of the moment (the “band-aid” approach), or a more ambitious outsourced custom development effort, built on an off-the-shelf content management foundation augmented with custom application development (the “one off” approach). Both have their limits, and present critical risks to carriers. The band-aid approach is often the result of short-term focus on an immediate problem – a particular compliance reporting challenge, for example. There’s obvious appeal: internal IT personnel are intimately familiar with existing systems and require no “ramp” time to understand the problem (assuming the IT queue is clear, a dubious assumption). The flaws are equally obvious, however. Unless the bigger picture is considered in addressing the problem, incorporating the concerns of all constituents involved – including flight operations personnel, maintenance staff, external vendors, regulators, and many more – this “one off” is likely to be satisfactory for a brief period, if that long. A more strategic approach is often merited, especially since the nature of the challenges in this area has migrated to a strategic level in many commercial aviation organizations. In this mode, carriers typically turn to a team of outsourced software specialists guided by internal IT to analyze the problem with an eye to the broader organizational issues, and propose a costly, long term project to build – largely from scratch – a fully customized solution. It’s no surprise that while these projects promise a precise fit for the carrier’s specific needs (as currently defined), they often produce cost overruns, delays, and the inflexibility that results from “hard coded” applications for narrow problems. That’s a function of two factors: the airline industry’s relative inexperience with TDM, and their outsourced developers’ bias toward labor-intensive, high cost projects that promise complex engagements with long maintenance “tails.”

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Technical Documentation Management, Aviation Safety, and Compliance: Strategic Pressures, New Solutions for Flight Operations

Regulatory

It’s a challenge every carrier must consider – how to cost-effectively address immediate document management needs without over-investing in a technical “dead end” that can’t support the unpredictable requirements of the future.

Designing the Perfect TDM Solution A middle course, between “band aid” solutions on existing systems and top-tobottom custom software development, is required in this dynamic, increasingly vital area. The ideal TDM solution would combine a state-of-the-art technology foundation for authoring, transforming, managing, distributing, and updating technical information; an easily-customized set of interchangeable, aviation-aware application “modules” to handle common flight ops processes and reporting requirements; and the expertise to define, customize, implement, and support the system, freeing airline IT to focus on other tasks. EFB Laptop Airworthiness Directives (Ads) Engineering Orders (EO /EA) Job Cards ECRA MSA ATA 100 ATA 2100 ATA 2200 S1000D

Flight Ops (FOM) Min Eq List (MEL) Fueling Man. (FM) Training (SCORM) Oversight Failure Rates

Gen Maint Man. (GMM) Tech Ass Req. (TR) Cust Orig Change (COC)

Field Notices Compliance

AMM EMM SRM CMM

Collaboration

(IPC) (WDM) Engine (IPC) Service Bulletins (SBs)

Maintenance Squedules Overnight RON A,B,C,D Checks

1

Appropriate aviation TDM systems offer a suite of function-specific applications built on a sophisticated content management "core," easing information creation, management, distribution, updating, and reporting

While the “perfect” solution is simple to conceptualize, it’s harder to find in the marketplace. Tried and true enterprise content management (ECM) technologies are widely available, but aren’t easily adapted to aviation-specific requirements. The expertise to create “smart” flight operations applications exists, but isn’t typically tied to appropriate ECM solutions, even if they are adaptable to airline needs. Even less common is expert consulting services to accurate define and customize a full solution for the flight operations compliance requirements of global carriers. A new breed of solutions, led by emerging firms like TechPubs, is changing this landscape. Teamed with Parametric Technology Corporation, a global leader in ECM in many industries, TechPubs has introduced the first flight operations TDM solution that offers proven technical excellence; modular, easily-configured flight ops applications, and the consulting expertise needed to make a perfect “fit” for every carrier – without the heavy overhead of building from scratch.

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Technical Documentation Management, Aviation Safety, and Compliance: Strategic Pressures, New Solutions for Flight Operations

Regulatory

The Future All industry participants’ interests – from the flying public, to carriers, to regulators – are best served if flight operations personnel have access to the freshest, most accurate data wherever and whenever it’s needed. The challenge is to make that practical, affordable, and technically extensible in an era of skyrocketing costs, shrinking margins, and regulatory pressure. But promising new solutions built with best-of-breed components and delivered by industry experts are increasingly available today. With these solutions in place, the global airline industry stands to enjoy greater efficiency, safety, and compliance with regulatory bodies charged with monitoring their activities.

About TechPubs, Inc. TechPubs, a PTC Global Airline Industry Platinum Partner, has joined with PTC to develop FlightPubs and FlightComply - a customized application suite that simplifies the authoring, publication, management, distribution, reuse, and updating of operational document, while supporting regulatory compliance and reporting needs. TechPubs is an exceptional team of industry veterans comprised of aerospace professionals, electronic manual designers, flight standard directors, regulatory compliance experts and airline operations experts. With our combined expertise, we have resolved the challenge of our industry’s unique publishing needs with the development of FlightPubs and FlightComply. More information is available from www.techpubsglobal.com, or at info@techpubs.com.

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Technical Documentation Management, Aviation Safety, and Regulatory Compliance