Mel'sPlace Consulting & ODA Services, LLC
Affecting Change from the Outside -
Oct 14, 2019
First Session - New Electronic Airworthiness Certification System
- Before the system is made mandatory by the FAA, they will need to provide training and more information updates than what’s been presented so far. No one has insight into when roll-out will actually happen.
- A generic process for the group to use may be helpful, but there’s no way on knowing or taking an action until the system is available. If the group is able to share information when the time comes, it would be worth discussing.
- It’s unclear if the system will cover replacement airworthiness certificates. Special flight permits will not be applicable.
Second Session – Unit Member Training
- Gulfstream shared their approach in developing small modules available on-line, and multi-device to support the training needs of all UMs. They’ve gone beyond training of just UMs and also provide modules for suppliers, for example how to complete an FAA Form 8130-9, so people have real-time access to training for helping complete required paperwork.
Third Session – New AVS ODA Office
- Once the new AVS ODA office is setup, it would be good to introduce this group and begin to establish a relationship with them. Information to share with them early includes:
- Non-standardization across offices and impact to industry.
- Emphasize need to continue toward agency being open to more delegation.
- Scorecard not being a valuable tool across the board. Discussion is valuable, but the administrative burden of collecting metrics has limited added value. Maybe this will no longer be necessary once the group is in place.
Fourth Session – Use of Special Projects
- Many ODAs are not allowed use of special projects and have been told by their OMT to include materials testing (or other special project like items) inside of other projects. Though this is working, many organizations would prefer having the option of doing testing under a special project.
Fifth Session – ODA Forum Benefits
- Benefits of continuing the ODA Forum includes:
- Sharing best business practices, but this needs to be broader with more sharing.
- Working together to identify non-standard areas and help reach resolution on the “standard.”
- Looking collectively at work coming out of other committees and providing joint feedback so we have more of a voice.
- A charter for the group will help define benefits from participation in the Forum. This will be drafted by a small group and then discussed at the next monthly call. Inclusion of a co-leader will also be discussed.
- When hosting a get-together, the host company should provide a briefing on the “thing” they do well. This could be anything they’d like to share, for example a deep dive into a regulation, a process that’s been effective, wins with the FAA, etc.
- The Forum should broaden discussions beyond the FAA and also look at issues with foreign validation.
- There should be a feedback mechanism with the forum. Sharing with the group if you take something from the discussions and try with the OMT, how things turned out.
- Group should interface with other committees to broaden collective voice. Paul Hill will provide information on how to begin this.
- No inclusion of the FAA is considered a benefit by some, but is concerning for others. Forum needs to be proactive in addressing issues the with FAA, so should be discussed more in the future.
For next face-to-face meeting, Seattle was identified as a potential location with Boeing hosting. The hope would be to setup a discussion with Jeff Duven, so FAA dialogue could be opened. This is not firm.
Sep 18, 2019
* Discussed people's experiences incorporating multiple companies under one ODA umbrella.
* Talked about requirements for re-issuing certificates when a company changes its name.
* Reviewed October meeting agenda and participant list.
* Shared experiences with what ODAs are seeing with regard to recent FAA audits and their approach to oversight.
Will skip monthly discussion in October due to face-to-face meeting. November discussion scheduled for the 13th.
Aug 20, 2019
14 participants in discussion, but not recorded so unable to share.
Jul 17, 2019
* People have been successful getting OMT engagement when using the action plan tool (1 page road map) that spells out what's needed, for example, when soliciting new authority.
* Some ODAs have had more success than others when disagreeing with their OMT. Though there are formal processes, such as the DOIP finding process, most found they more success and preference for an informal discussion. Some ACOs are more accommodating. One tool that was noted as helpful was the MCO's use of a spreadsheet to provide PSCP comments/disposition that serves as a way to work through differing opinions.
*Use-as-is as a non-conformance disposition - most ODAs are only using this disposition for test articles/test setups. Otherwise, one-off, serial number specific engineering notes/orders are being used to capture justification for continued use, incorporating into the MDL, and UM is approving with 8100-9.
* When adding an existing DER, per their FAA authorization, as a unit member, some ODAs are still being told no because the OMT "doesn't know him." There was a consensus that this type of response seems outside the intent of Order requirements.
* Boeing successfully completed their pilot project to attain 21.93 no acoustical change finding authorization. Though policy memo asks for definition of specific modeling processes for the ODA, they effectively used an MOU as a reference to address this policy item.
Jun 19, 2019
* ODA CIT met in Washington DC at the end of April. Meeting summary will be sent out by Paul Hill.
* FAA Scorecard briefing highlighted changes to period covered. Counts will be associated with calendar year (Jan-Dec) rather than fiscal year, and COS metrics will align with this period rather than covering a 2-year window.
* Gulfstream is currently using PDF fillable forms and a file sharing on-line service for a couple of FAA forms. No one else has developed on on-line form system.
* Most ACOs have stayed away from allowing special projects. A couple of ODAs are using special projects for things like material allowables - one has embedded their SP projects in PMA projects, the other has stand-alone SP projects for this testing.
* No word on when Order 8110.4, revision C will be provided for public comment, but its understood that the review period will be short (30 days) once it gets out of the FAA legal review.