Airline Pilot Central Forums - FDX QA Observations

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

Quote:

Originally Posted by 3pointlanding (Post 1668595)

If you are interested,
Refer to AC 120.92,

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)

So, Strike 1 and 2 on your attempt to prove The Company's QA program is required by the FAA.

Quote:

Originally Posted by 3pointlanding (Post 1668595)

... the soon to be published FAR part 5 (it is available) ...

Seriously? We're regulated by a "soon to be published" regulation?

You're a real hoot.

Strike 3. Well, OK, let's make this more fun. Let's call this one a foul ball.

Here's the text of the proposed rule: Proposed 14 CFR Part 5 Regulatory Text

It says that a Part 119 Certificate Holder must have an SMS program that meets the requirements of this section by 3 YEARS after the date of implementation of the proposed rule. That SMS program may contain programs, policies, or procedures the certificate holder already had in place, including components of an existing SMS, and it must include at least the following four components:

(1) Safety Policy

(2) Safety management

(3) Safety assurance

(4) Safety promotion

Guess what's not required. Uh, huh. "QA" ain't in there. "Quality Assurance" is not mentioned.

Quote:

Originally Posted by 3pointlanding (Post 1668595)

... order 8900.1 volume 10 (SAS), ...

FAA Order 8900.1 Volume 10 SAFETY ASSURANCE SYSTEM PLOICY AND PROCEDURES - CHAPTER 1 GENERAL - Section 1 Safety Assurance System

Paragraph 10-1-1-5 BACKGROUND

A. Statutory Authority. ... SAS is not a separate safety standard and does not impose additional requirements on certificate holders.

Section 2 Safety Assurance System: Introduction to SAS Business Process and Tools

Paragraph 10-1-2-5 BACKGROUND

D. Safety Management Systems (SMS). ... SMSs consist of four main components: Safety Policy, Safety Risk Management (SRM), Safety Assurance (SA), and Safety Promotion.

Sound familiar? Yepp, same stuff we found in the Advisory Circulars and the Proposed 14 CFR Part 5. And, strangely enough, again we cannot find QA or Quality Assurance programs mentioned, much less mandated by the FAA.

Another foul ball hit to the same place, well wide of the baseline, and dribbling to a pathetic stop before making it even half-way to the first base coach.

Quote:

Originally Posted by 3pointlanding (Post 1668595)

IOSA Standards Manual Flt. 1.10 Quality Assurance Program and ORG 3.4.1 Guidance which the company must adhere to remain on the IOSA registry). That should give you an idea the program. It is not a big deal

Third time. The I in IOSA stands for IATA - International Air Transport Association. It is a TRADE ASSOCIATION! It's not the FAA, which has regulatory authority in the U.S. It's not ICAO, a convention of rules and regulations recognized around the world. It can MAKE NO RULES! It cannot possibly require FedEx to do anything!

IATA can develop standards and recommended practices, but it cannot mandate adherence. Even so, while it uses quality assurance (lower-case, generic) quite extensively, it does not mandate a particular way to achieve the objective.

From the IOSA Standards Manual, 1 September 2013, 7th Edition, we read:

FLT 1.10.1

The Operator shall have a quality assurance program that provides for the auditing and evaluation of the flight operations management system and operational functions at planned intervals to ensure the organization is:

i) Complying with applicable regulations and standards of the Operator;

ii) Satisfying stated operational needs;

iii) Identifying areas requiring improvement;

iv) Identifying hazards to operations.

For further clarification, the same paragraph refers us to the IATA Reference Manual for Audit Programs (IRM), August 2013, 4th Edition for a definition of "quality assurance."

The formal and systematic process of auditing and evaluation of management system and operational functions to ensure:

Compliance with regulatory and internal requirements;
Satisfaction of stated operational needs;
Identification of undesirable conditions and areas requiring improvement;
Identification of hazards.

Equivalent Terms: Internal Evaluation, Safety Assurance

And here's the kicker: the 4 programs we already have in place at FedEx by LOA and MOU, that is ASAP, FOQA, LOSA, and FRMS, meet the objectives of IATA's IOSA Standards and Recommended Practices.

So.

Looks like a fast ball down the middle, caught you looking. Strike 3. You're out.

Quote:

Originally Posted by 3pointlanding (Post 1668595)

It is not a big deal

It's a huge deal when my job is in jeopardy.

Listen, I'm tired of doing all your work. No more links from me. Find one single reference in a regulatory document that requires FedEx to implement the program they're calling QA, and we can talk some more. Until then, enjoy your climate controlled cubicle.

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