Airline Pilot Central Forums - FDX QA Observations

Quote:

Originally Posted by 3pointlanding (Post 1681528)

First AC120-92 was cancelled and replaced by 120-92A.

http://www.blogcdn.com/massively.joy...0/facepalm.jpg

Well, I've been a little busy the past few days with Recurrent Ground school and a couple of AQP Simulator events, but I don't feel too bad about taking so long to respond to your posts because I said I wouldn't until you produce a link to "one single reference in a regulatory document that requires FedEx to implement the program they're calling QA," and you still have not. However, in the interest of entertainment, here I go.

First, this post:

Quote:

Originally Posted by 3pointlanding (Post 1681720)

By the way, I sort of object to your snide comment of my "climate controlled cubical". For 35 plus years my cubical came with a seat on the right and a seat behine me and I worked all three seats. I don't know how many hours you have but I bet I beat it.

I want to offer you my sincere congratulations on completing a career of flying, and my sincere condolences that you obviously cannot enjoy the reward of retirement. It must be daunting to have to rely on the benevolence of Uncle Fred and an office job to pay the bills and keep things going. It's a shame, and I'm sorry you have to endure it.

Just out of curiosity, do they keep the thermostats set at 78° in your cubicle? They tell us (pilots) that they won't hook up air conditioning to the jet unless the OUTSIDE temperature is predicted to rise above 78°. Do you have any idea what the cockpit temperature gets to be at that temperature? Anyway, I digress.

Back to the first post ...

Quote:

Originally Posted by 3pointlanding (Post 1681528)

First AC120-92 was cancelled and replaced by 120-92A.

Why, of course, why didn't I think of that?!? Oh, wait, I DID! In fact, I said the very same thing, only I gave the title and a link. (That's the text that shows up on your screen as blue. When you place your cursor over the blue text and click, your browser will take you to an on-line copy of the document.) Then I quoted from it. At length. As I recall, ... no, wait, I don't have to rely on memory, I can just copy and paste it here ...

Quote:

Originally Posted by TonyC (Post 1668696)

You really are a slow learner, aren't you?

AC-120-92 (Cancelled) - Introduction to Safety Management Systems for Air Operators Cancelled August 12, 2010.

Before it was cancelled, it said, "This AC is not mandatory and does not constitute a regulation. Development and implementation of an SMS is voluntary."

Safety Management Systems for Aviation Service Providers replaced it on August 12, 2010.

Guess what it says. "This AC is not mandatory and does not constitute a regulation. Development and implementation of an SMS is voluntary."

Still, if an aviation service provider elects to voluntarily implement an SMS, the FAA lists Performance Objectives and General Design Expectations for a host of Components (Safety Policies and Objectives, Safety Risk Management, Safety Assurance, and Safety Promotion), Elements (such as Safety Policy, Hazard Identification and Analysis, Safety Performance Monitoring and Measurement, and Communication and Awareness), and Processes (such as System Description and Task Analysis, Analysis of Data, and Training). Paragraph 5.2 of Appendix 1 explains that FAA FRAMEWORK EXPECTATIONS are functional expectations, that is, they describe the what of each process, not the how. "For example, the what of a deicing process is to prevent any aircraft from taking off with ice adhering to any critical control surface. The how of the de-icing process would include deicing equipment procedures, flight crew deicing procedures, hold over table activities, etc., and may be different between individual organizations.

You know what's missing from this Advisory Circular? QA. Well, that's not entirely true, the letters are in FOQA, which is mentioned along with ASAP in a list of "Related Reading Material" that may help users of this AC to develop their SMS programs. Funny, no mention of a Quality Assurance program.

But there is a nice passage about Just Culture. Permit me to quote:

"A safety effort cannot succeed by mandate only or strict implementation of policy. Where individual attitudes are concerned, organizational cultures set by top management establishes the tone that enhances the performance and efficiency of the entire SMS. Cultures consist of psychological (how people think and feel), behavioral (how people and groups act and perform) and organizational (the programs, procedures, and organization of the enterprise) elements. An organization’s culture consists of the values, beliefs, mission, goals, and sense of responsibility held by the organization’s members. The culture fills in the blank spaces in the organization’s policies, procedures, and processes and provides a sense of purpose to safety efforts. Dr. James Reason, and other organizational system safety theorists, stresses the need for a reporting culture as an important aspect of safety culture. The organization must do what it can to cultivate the willingness of its members to contribute to the organization’s safety efforts. Dr. Reason further stresses the need for a just culture, where employees have the confidence that, while they will be held accountable for their actions, the organization will treat them fairly."

(italics in original, bold mine)

Ah, yes, I remember now. It says, "This AC is not mandatory and does not constitute a regulation. Development and implementation of an SMS is voluntary."

Maybe if we quote it a few more times it will change and become mandatory and constitute a regulation, ya think?

Quote:

Originally Posted by 3pointlanding (Post 1681528)

If you want a reference for joining the IOSA registry call Mr Bronzek.

Nope. Joining the IOSA registry is of no interest to me. The reference I asked for, again, is ... "one single reference in a regulatory document that requires FedEx to implement the program they're calling QA."

Quote:

Originally Posted by 3pointlanding (Post 1681528)

To name a couple of countries requiring the airline be on the registry? I will only give the ones we fly to, Chile, Brazil, Dubai, Mexico, Chine to be added sometime this year and a few others I cannot remember but I will provide them tomorrow.

Interesting, but irrelevant. Apparently you forgot what you forgot because you forgot to complete the list "tomorrow." With or without the complete list, you still have failed to provide "one single reference in a regulatory document that requires FedEx to implement the program they're calling QA."

Quote:

Originally Posted by 3pointlanding (Post 1681528)

Now for the last three IOSA audit one member was required to observe a flight and a simulator session. This has nothing to do with your "job on the line. It is an observation, no more, no less. If you up the ISARPs and go to FLT 3.3 and 3.5 you will see just what an observation is for.

I don't care to see "just what an observation is for." What I would like to see is "one single reference in a regulatory document that requires FedEx to implement the program they're calling QA."

Quote:

Originally Posted by 3pointlanding (Post 1681528)

)IOSA and the DoD had auditors during their audits. No big deal.) If you want I can send the ISARP to you.

Thanks, but I don't want the ISARP. What I would like is "one single reference in a regulatory document that requires FedEx to implement the program they're calling QA."

Quote:

Originally Posted by 3pointlanding (Post 1681528)

Believe me you aren't doing my homework but I like the baseball metaphor. Not a home run but a solid triple.

Delusional much?

Quote:

Originally Posted by 3pointlanding (Post 1681528)

As to the SAS you so eloquently quoted. SAS and for that matter SMS is published and the company is in the midst of setting up the SMS. It takes a long time with a timeline toward that three years you alluded to. Each stage has its own time for completion with reports going to the Feds. As to SAS, the SAS has been published and only the JTIs are not released. The CMO is heading to OK City for training in about a month. In the meantime if you go to fslims.gov check the SAI And EPI's you will see it will not concern you. If I were you I would be more worried about the ASI who is there to "help you".

The programs agreed to by FedEx, ALPA, and the FAA satisfy the requirements of the FAA's SMS program and IATA's IOSA program. The program which FedEx has instituted on its own, without the cooperation or buy-in from the pilots and with no method for protecting pilots or sharing information gathered, IS NOT REQUIRED FOR EITHER.

If I am wrong, please show me "one single reference in a regulatory document that requires FedEx to implement the program they're calling QA."

Here's the deal. The FAA's Safety Management System includes 4 programs, ASAP, FOQA, LOSA, and FRMP, all of which require the participation of The Company, The Association, and the FAA. We voluntarily participate in all 4. If The Company wants to put observers in the cockpit, they can conduct a LOSA according the LOA we all agreed to and signed.

The beauty of this SMS program with all three parties volunteering to participate and all three parties enjoying the benefits of sharing the information, learning from mistakes, and endeavoring together to make our airline more safe is that it also satisfies the requirements of IATA's IOSA standard. We don't have to reinvent any wheels, or copy any Australian airline.

The QA program as explained in our 6-month recurrent ground school is conducted by Fleet Check Airmen, and our FOM states that I must grant them flight deck access. According to the Fleet Check Airman who gave the briefing I attended, they will not bust a pilot even if they observe something that is unsafe or in violation of the FARs. Instead, they will refer those pilots to Standards and Training for further "attention."

This brings up two issues. First, how does the FAA feel about a Check Airman NOT intervening in order to prevent an unsafe condition? How does the FAA feel about a Check Airman turning a blind eye to a violation?

Second, if the Fleet Check Airman can refer me for additional "attention" from a "real" Check Airman (meaning someone who is actually qualified to fly and evaluate on my airplane), then the ride presents jeopardy to me. Just like a line check or a ride by an Aviation Safety Inspector from the FAA, my ticket is on the line.

Since that briefing in recurrent ground school, The Company solicited First Officers to become management wannabes and conduct QA observations. (I would refer to them by their proper title, but I don't know what it is.) The FOM does not require me to grant them flight deck access, so I will not.

AGAIN, if The Company wants to put observers in the cockpits, all they have to do is conduct a LOSA according to the agreed-upon procedures of our LOSA LOA.

And AGAIN, and for the last time, if you can produce that "one single reference in a regulatory document that requires FedEx to implement the program they're calling QA," I'll consider changing my mind about it.

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