FDX QA Observations
06-29-2014 | 08:33 AM
#61
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Joined: May 2013
Posts: 139
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Just curious...what would you have the company do to fix this? As an international kind of guy I always marvel at how upset we all get with the customs/ag/immigration practices of the countries we fly to. Does anybody think any of these places really care what FedEx, UPS or any other airline thinks, especially after what we imposed post 911? Really?
07-10-2014 | 05:35 PM
#62
Gets Weekends Off
Joined: Jan 2011
Posts: 307
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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:
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.
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.
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
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." 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.
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.
.
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.(italics in original, bold mine)
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.
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.
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.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
So.
Looks like a fast ball down the middle, caught you looking. Strike 3. You're out.
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.
.
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".
Last edited by 3pointlanding; 07-10-2014 at 06:17 PM. Reason: Correction
07-11-2014 | 05:55 AM
#63
Gets Weekends Off
Joined: Jan 2011
Posts: 307
Likes: 0
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.
Beware is ASIs with greetings of good tidings.
And forgive the spelling errors, it was done on an IPad MIni while flying from Pensacola to Memphis in a 182 (even puddle jumpers have autopilots) not the best forum to be using an IPad Mini no less.
Beware is ASIs with greetings of good tidings.
And forgive the spelling errors, it was done on an IPad MIni while flying from Pensacola to Memphis in a 182 (even puddle jumpers have autopilots) not the best forum to be using an IPad Mini no less.
07-11-2014 | 06:07 AM
#64
Gets Weekends Off
Joined: Jan 2011
Posts: 307
Likes: 0
I forgot AC120-92A, here is the excerpt for you pleasure:
This advisory circular (AC) provides a Framework for Safety Management System (SMS) development by aviation service providers. It contains a uniform set of expectations that align with the structure and format of the International Civil Aviation Organization (ICAO) Framework; and Aviation Safety (AVS) policy in Federal Aviation Administration (FAA) Order VS 8000.367, AVS Safety Management System Requirements, Appendix B.
•AC 120-92A (PDF, 305 KB)
Take note of the second sentence, line 4. Maybe I did hit a home run off a hanging curve ball.
This advisory circular (AC) provides a Framework for Safety Management System (SMS) development by aviation service providers. It contains a uniform set of expectations that align with the structure and format of the International Civil Aviation Organization (ICAO) Framework; and Aviation Safety (AVS) policy in Federal Aviation Administration (FAA) Order VS 8000.367, AVS Safety Management System Requirements, Appendix B.
•AC 120-92A (PDF, 305 KB)
Take note of the second sentence, line 4. Maybe I did hit a home run off a hanging curve ball.
07-11-2014 | 06:18 AM
#65
Gets Weekends Off
Joined: Aug 2006
Posts: 3,931
Likes: 0
3ptlnding,
The management job is a good thing and you undoubtedly deserve it. Sorry you're insulted by someone pointing it, and you're inadequate argument, out. Sounds like you don't have an open door policy.
You don't think anyone reading this board is buying your trolling "information", do you?
The management job is a good thing and you undoubtedly deserve it. Sorry you're insulted by someone pointing it, and you're inadequate argument, out. Sounds like you don't have an open door policy.
You don't think anyone reading this board is buying your trolling "information", do you?
Last edited by Gunter; 07-11-2014 at 06:49 AM.
07-11-2014 | 06:26 AM
#66
Gets Weekends Off
Joined: May 2006
Posts: 157
Likes: 0
From: Captain
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.
Beware is ASIs with greetings of good tidings.
And forgive the spelling errors, it was done on an IPad MIni while flying from Pensacola to Memphis in a 182 (even puddle jumpers have autopilots) not the best forum to be using an IPad Mini no less.
Beware is ASIs with greetings of good tidings.
And forgive the spelling errors, it was done on an IPad MIni while flying from Pensacola to Memphis in a 182 (even puddle jumpers have autopilots) not the best forum to be using an IPad Mini no less.
07-11-2014 | 06:51 AM
#67
Gets Weekends Off
Joined: Feb 2007
Posts: 397
Likes: 0
I forgot AC120-92A, here is the excerpt for you pleasure:
This advisory circular (AC) provides a Framework for Safety Management System (SMS) development by aviation service providers. It contains a uniform set of expectations that align with the structure and format of the International Civil Aviation Organization (ICAO) Framework; and Aviation Safety (AVS) policy in Federal Aviation Administration (FAA) Order VS 8000.367, AVS Safety Management System Requirements, Appendix B.
•AC 120-92A (PDF, 305 KB)
Take note of the second sentence, line 4. Maybe I did hit a home run off a hanging curve ball.
This advisory circular (AC) provides a Framework for Safety Management System (SMS) development by aviation service providers. It contains a uniform set of expectations that align with the structure and format of the International Civil Aviation Organization (ICAO) Framework; and Aviation Safety (AVS) policy in Federal Aviation Administration (FAA) Order VS 8000.367, AVS Safety Management System Requirements, Appendix B.
•AC 120-92A (PDF, 305 KB)
Take note of the second sentence, line 4. Maybe I did hit a home run off a hanging curve ball.
For your cubicle reading. That home run went outside the foul line… Next pitch? swing and a ….
ex·pec·ta·tion
ˌekspekˈtāSHən/
noun
plural noun: expectations
a strong belief that something will happen or be the case in the future.
"reality had not lived up to expectations"
synonyms: supposition, assumption, presumption, conjecture, surmise, calculation, prediction, hope More
anticipation, expectancy, eagerness, excitement, suspense
a belief that someone will or should achieve something.
Are Advisory Circular's regulatory? Nope
Advisory circular (AC) refers to a type of publication offered by the Federal Aviation Administration (FAA) to provide guidance for compliance with airworthiness regulations. They define acceptable means, but not the only means, of accomplishing or showing compliance with airworthiness regulations.Generally informative in nature, Advisory Circulars are neither binding nor regulatory; yet some have the effect of de facto standards or regulations.
Advisory circulars typically refer to industry standards from SAE and RTCA. Some Advisory circulars are only a few pages long and do little more than reference a recommended standard;
Advisory Circulars ‐ The FAA issues Advisory Circulars (ACs) to inform the aviation public in a systematic way of nonregulatory material. Unless incorporated into a regulation by reference, the contents of an advisory circular are not binding on the public. Advisory Circulars are issued in a numbered subject system corresponding to the subject areas of the Code of Federal Regulations (CFRs) (Title 14, Chapter 1, FAA).
07-11-2014 | 07:32 AM
#70
Gets Weekends Off
Joined: Jan 2011
Posts: 307
Likes: 0
Gunter
It is what it is. The powers to be have hitched the wagon to IOSA, Mr. Bronzek was the IOC President. The bottom line QA has nothing to do with crew performance just operating processes. At the beginning of this thread I got the impression some felt threatend by QA when in acutality it is just another process hoisted on us and a component of SMS. My original thought was to assuage the fear It looks like I failed. But so be it. I do have one question though. If during the next Enhanced IOSA audit the auditor is assigned to your flight or your sim session, would you refuse to allow him access to the cockpit?
It is what it is. The powers to be have hitched the wagon to IOSA, Mr. Bronzek was the IOC President. The bottom line QA has nothing to do with crew performance just operating processes. At the beginning of this thread I got the impression some felt threatend by QA when in acutality it is just another process hoisted on us and a component of SMS. My original thought was to assuage the fear It looks like I failed. But so be it. I do have one question though. If during the next Enhanced IOSA audit the auditor is assigned to your flight or your sim session, would you refuse to allow him access to the cockpit?
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