In a story published on September 1, AIN senior editor Kerry Lynch outlines a fascinating tale of a safety problem that doesn’t seem to be attracting much attention from the FAA, the aircraft manufacturer or the vendor of the product in question.
When I first read this article, I wondered why no one seemed to be interested in the problem, so I decided to search the FAA’s Service Difficulty Reporting (SDR) database to see whether there were any reports about this particular product. One of the ways the FAA gets information to determine whether an airworthiness directive is needed is from the SDR. I’ve never been able to find this out, but have often wondered whether manufacturers rely on their own data to come up with service bulletins or whether they look at the SDR database too.
I was surprised to see not one report on the problem that we wrote about, not a single mention. This made me wonder about the value of the SDR system and why the FAA is spending money on it.
Generally speaking, companies that operate under Parts 121, 125, 129, 135 and 145 are required to submit reports to the SDR database. All other reports are voluntary. You may not know this, but anyone can submit a report using the online Malfunction/Defect Report.
Here’s the problem: there is practically zero incentive for a Part 91 operator, a pilot or an overworked A&P mechanic to submit a report, even one about a potentially life-threatening problem. It doesn’t earn you any brownie points with the FAA, there is no pat on the back, although reporting a malfunction or defect could save someone’s life.
Not only is there no effort to encourage people to report problems to the SDR database, there is also no more dissemination of reports back into the field. Of course, anyone can search the online database. But the FAA used to publish a neat printed package of reports on a monthly basis, called Maintenance Alerts. We used to sit around the maintenance shop at lunchtime looking over the Alerts, laughing at stupid mistakes but also learning about what other mechanics had found and considered important enough to take time to fill out what was then a paper “M&D” form and mail it to the FAA. Eventually the FAA decided that printing and mailing the Alerts was too expensive, and the agency turned it into an online document, for a while published monthly as AC 43-16A, but that lasted only until 2012. The last copy of the Maintenance Alerts that I could find was dated November 2012.
Just a few months ago, on May 21 the FAA killed off AC 43-16A for good, as part of its effort to meet requirements to make regulatory interpretation more consistent.
Huh? What does a useful product like the Maintenance Alerts have to do with inconsistent interpretation of regulations? According to the FAA, “The [Aviation Rulemaking Committee’s] primary recommendation included canceling outdated or conflicting guidance. To address the recommendation [FAA Flight Standards] completed a revalidation review in January 2015. As a result of this review, [Flight Standards] is requesting the cancellation of the following Advisory Circulars and orders because they contain archaic information or have been incorporated into other guidance.”
I’m guessing that “incorporated into other guidance” in this case means that the information in AC 43-16A is available in the SDR database, which is certainly true. But the database is full of useless reports that airlines and other entities are required to report, such as “found crack in wing panel XX, fixed crack per manufacturer’s guidelines,” etc. The AC 43-16A reports certainly benefited from the deft editorial touch of someone at the FAA who was skilled at sussing out items that were not only interesting but also helped us mechanics learn about what to look for on the aircraft we serviced.
Oh well. Times change. Technology marches on. There still is an SDR database, but the subjects of the article apparently decided that even though they felt we should tell AIN readers about this problem, it wasn’t urgent enough that they would spend two minutes filling out a Malfunction/Defect Report.
Look, here’s the bottom line: if you think there is an urgent safety issue with a product, do the right thing: fill out a Malfunction/Defect Report. And if your buddies complain about a problem and the fact that no one is doing something about it, show them how to fill out the form. It’s there for a reason, and if the problem is compromising safety and enough reports are submitted, the FAA might just pay attention and do something.