Everyone is Responsible for Quality
There are no easy jobs in aviation maintenance — all take a tremendous amount of knowledge and fortitude. However, persons that have “quality” in their titles can have the toughest roles. Somehow, the title of director of quality or manager of quality assurance gives the impression that only those individuals are responsible for ensuring proper work is or has been done. Nothing could be further from the truth; every individual and company is responsible for ensuring compliance.
Compliance means that the government and customer requirements are fulfilled. In the case of maintenance, aviation safety regulations require each person performing work on civil aviation aircraft, engines, propellers, appliances and articles to be responsible for doing the assigned tasks properly. If you don’t believe me, read the rules. The performance requirements in Part 43 (section 43.13) of title 14 Code of Federal Regulations apply to “each person” performing maintenance, preventive maintenance, rebuilding or alterations; section 1.1 defines “person” as individual and other entities. The belief that only certificated persons can be tagged by the FAA for “violations” is patently false — anyone can and should be aware of and responsible for the quality of work performed in civil aviation. If the company holds a certificate under Part 145 (repair station) or Part 121 or 135 (air carrier), that entity will also be responsible for ensuring individuals have the proper knowledge, training and/or certificates to hold specific positions or responsibilities.
The aviation safety regulations use the terms “quality control” and “quality assurance” and under Parts 119, 121, 135 and 145 have some requirements for the individuals with certain titles. However, the holding of the title and/or certificate by an individual does not make only that person responsible for “quality.” The companies that hold certificates authorizing performance and approval for return to service of maintenance, preventive maintenance and alteration work must ensure every individual understands that quality is essential to every task — it cannot be ‘inspected in” or “assured” after the fact. Quality control and assurance is the responsibility of every single person involved in aviation safety tasks, not just the person with a convenient title!
Sarah MacLeod is executive director of the Aeronautical Repair Station Association (ARSA), an organization she helped found more than 25 years ago. She is a managing member at the law firm of Obadal, Filler, MacLeod & Klein P.L.C. and is engaged in the legal representation of foreign and domestic air carriers, aircraft maintenance and alteration facilities, distributors, pilots, and other individuals and companies in federal court and before federal administrative bodies. She also serves as assistant chair for Air Carrier and General Aviation Maintenance of the FAA’s Aviation Rulemaking Advisory Committee, a post she has held since 1996. A globally-recognized expert in aviation regulatory compliance, she is a sought-after speaker and has appeared at numerous aviation and MRO events. She is admitted to the bar in Virginia.