Technical Documentation Management, Aviation

Safety, and Regulatory Compliance:

Strategic Pressures, New Solutions for Flight Operations

TechPubs, Inc
September 2008
www.techpubsglobal.com
 Technical Documentation Management, Aviation Safety, and Regulatory
Compliance: Strategic Pressures, New Solutions for Flight Operations

Executive Summary
Airlines face a difficult business environment, made more challenging by mounting
regulatory pressures. Technical Document Management (TDM), an often-neglected
area, promises relief, notably in flight operations.
But to date, TDM solutions, adopted by only a few innovative carriers, haven’t
matured to the point of holding appeal to the industry as a whole. In their current
incarnation, such systems can be costly to implement, built without the flexibility
airline growth demands, and insufficient for the reporting requirements of
increasingly vigilant regulators.
That’s changing. This document describes a new breed of solutions that straddles
a middle ground between two common approaches to airline TDM. These new
solutions promise dramatic improvements in information quality, revision,
reusability, reporting, and other factors – for flight ops and across the airline
enterprise.

Aviation Safety & Regulatory Compliance: Pressure Builds

Recent developments in aviation safety regulation and compliance require a fresh
look at flight operations processes, and specifically, the substantial complement of
technical documentation that forms their foundation.
It’s no exaggeration to say that airlines run on data as much as on fuel. Managing
the myriad technical documents that describe and control daily flight operations is
a challenge familiar to all carriers. Lately, however, aggressive, more expansive
safety regulation and compliance developments have raised the ante in this area.
Across the industry, carriers are forced to reconsider their technical document
management (TDM) strategies. They’ve embraced the idea that TDM is more than
another detail of the aviation IT, since regulators are taking a closer look than ever
at flight operations processes – and all-too-frequently, finding problems with what
they see.

Recent developments
Recently, airline regulatory events have been in the headlines. It’s too simple,
however, to assume these actions have exclusively concerned maintenance
shortfalls. While maintenance has been at the core several incidents, flight
operations are struggling equally with more intense regulatory scrutiny.
Notably, the US Federal Aviation Administration’s (FAA) 2007 actions against
Southwest Airlines, resulting in a $10 million fine, concerned mandatory
inspections for structural damage - a familiar maintenance issue. But the situation
has prompted Southwest and other airlines to review their technical publications
needs across the board, through to and including flight operations.
More pertinently, when the FAA in 2008 alleged that American Airlines flew two
planes judged to be unsafe to operate under certain conditions and “not
airworthy,” there was more at issue than maintenance. Specifically, the action
related to parts on the minimum equipment list (MEL) that are variously required
depending on the specific flight routes involved – a not-unusual instance of
maintenance items that “spilled over” into flight operations.
In short, the FAA and other regulators – as well as the airlines themselves – are less
inclined to restrict their oversight to individual “silos” of airline activities, like

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Technical Documentation Management, Aviation Safety, and Regulatory
Compliance: Strategic Pressures, New Solutions for Flight Operations

maintenance. They’re beginning to perceive the technical documentation issue in

a broader perspective.

A Global Concern
The problem isn’t restricted to US carriers, of course. International oversight
bodies, notably in the EU, are paying greater attention to such concerns, with
impacts at the carrier level and beyond.
For example, a July 2008 EU Commission report noted that
…The Commission received on 16 May an update on the progress of
implementation of the corrective action plan by the competent authorities of
Indonesia. Relevant documentary evidence… demonstrates that the national
authorities do not have, at this stage, the ability to ensure the oversight of the
carriers they certify (including Garuda Indonesia, Ekpres Transportasi Antar Benua,
Airfast Indonesia and Mandala Airlines), in particular with respect to the area of
flight operation surveillance.
(Official Journal of the European Union, 25.7.2008; emphasis added)

The implications of these developments are dramatic. Not only are individual
carrier operations affected; an entire domestic commercial aviation industry in one
of the world’s most populous nations is jeopardized - chiefly because of an
inability to “surveil” pertinent flight ops processes. In short, Indonesian carriers are
banned from EU landings because their processes are poorly documented, not
verifiable, or both – a basic technical documentation concern. Similar
circumstances are common in commercial aviation throughout Africa, Asia, and
the Middle East.
The core of the regulatory challenge is a carrier’s ability not only to follow well-
documented, demonstrable flight ops procedures, but also to document
compliance with them to regulators. Specifically, the situation mandates a new way
of demonstrating that a) compliant processes are in place; b) they’re fully
documented, easily updated, and constantly available to appropriate personnel;
and c) they’re routinely followed in day-to-day operations.
The implication: lacking a flight operations publications strategy that recognizes
these emerging compliance issues presents a strategic challenge to airline
operations, far beyond what once was considered a mundane IT issue.

What cost safety and compliance?

In general, three main economic benefits flow from improved technical publication
management:

The enhanced flight operations efficiency that results from personnel better
equipped to perform their functions with the freshest, most reliable technical
information.

The avoidance of liability (and related costs) in the event of an accident owing
to poor document management, even if only peripheral to the event.

The mitigation of costs related to regulatory compliance – a potentially huge
impact if, at the extreme, regulators choose to shut down day-to-day flight
operations over poorly documented processes.
It’s this last consideration that has moved TDM from an operational concern to a
strategic issue – and from just another item in the IT queue to a focus at the
highest levels of airline operation.

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 Technical Documentation Management, Aviation Safety, and Regulatory
Compliance: Strategic Pressures, New Solutions for Flight Operations

Technical Documentation Management: Alternatives

All airlines have a technical documentation management strategy, in some form,
whether it’s explicitly “documented” or not.
On one extreme, many airlines persist in handling the bulk of flight operations
documents by hand, on paper. It’s a convenient, entirely “portable” solution for
flight ops personnel, but is of course difficult to maintain, unavailable to remote
personnel, and woefully inadequate for compliance monitoring.
On the other end of the spectrum, a handful of innovative carriers have
implemented sophisticated systems to provide flight ops personnel with
documentation that’s managed and distributed electronically, on the ground and
in the air. But to date, such systems have been built with a patchwork of
incompatible systems that impede efficient updating, broad distribution, and, most
critically in the current regulatory environment, immediate and accurate reporting
on compliance with safety mandates.

Fleet 1 EFB
Airworthiness Laptop
NAA CAA Directives (Ads) Fleet 2

Engineering Orders (EO /EA)

Flight Ops (FOM)
Job Cards Fleet 3
FAA Min Eq List (MEL)
ECRA
Fueling Man. (FM)
MSA
Training (SCORM)
FTP
ATA 100
ATA 2100
Engineering Operations
ATA 2200
S1000D Oversight
Failure Rates

Gen Maint Man. (GMM)

Tech Ass Req. (TR)
Maintenance Quailty Control Field Notices
SneakerNet
Cust Orig Change (COC)
Compliance
AMM
EMM
SRM Records Library Planning Collaboration
CMM

AIRBUS
CD-ROM
(IPC)
(WDM) Email MRO Provider
Engine (IPC)
Aircraft OEM Service Bulletins (SBs) MRO Provider
Maintenance Squedules MRO Provider
BOEING Overnight RON
A,B,C,D Checks
1
The typical airline document management landscape is littered with incompatible
"silos" of information, lacking facility for easy updates, data reuse, and reporting

Let’s take a high level look at the problem. At its heart, aviation technical
documentation is a set of rigid requirements, processes, and equipment details
with cross- (and extra-) organizational uses. The data management challenge is
multi-faceted: information arrives in a dizzying array of formats, from multiple
suppliers; destined for an audience that literally spans the globe; and that
necessitates highly flexible methods of accessing, viewing, reviewing, commenting
on, and in many cases, editing the content, while maintaining a foolproof “paper
trail” throughout.

The Case for a Document “Warehouse”

It’s no great leap to understand the general need for a central data repository to a)
“ingest” the full range of incoming content, regardless of format; b) transform it
into standard, easily manipulated forms; c) distribute it to a huge population of
downstream consumers, within and external to the carrier; d) constantly track and

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Technical Documentation Management, Aviation Safety, and Regulatory
Compliance: Strategic Pressures, New Solutions for Flight Operations

record changes made over time; and e) support a flexible set of reports and other
uses of the data, notably but not exclusively for regulators.
Though necessary, however, a documentation-centric airline-wide database is not
in itself sufficient. There are many such commercially available systems, already in
use within the industry, with mixed results.
A closer look suggests two elements are required complete an airline-appropriate
TDM solution built on this foundation:
a) A comprehensive set of aviation-aware, function-specific applications for
delivering useful reports and data manipulation tools to downstream
personnel, and
b) The industry-specific expertise to customize the entire solution for each
carrier’s unique requirements.
In light of these high level requirements, let’s compare two common approaches to
the TDM problem, and discuss how a middle road promises a better future.

Why Best Efforts Fail: “Band Aid” vs. “One Off” Solutions
In an effort to produce a useful TDM solution according to the framework above,
forward-thinking airlines typically turn in one of two directions: stage a do-it-
yourself effort to wire existing systems together to solve the obvious problems of
the moment (the “band-aid” approach), or a more ambitious outsourced custom
development effort, built on an off-the-shelf content management foundation
augmented with custom application development (the “one off” approach).
Both have their limits, and present critical risks to carriers.
The band-aid approach is often the result of short-term focus on an immediate
problem – a particular compliance reporting challenge, for example. There’s
obvious appeal: internal IT personnel are intimately familiar with existing systems
and require no “ramp” time to understand the problem (assuming the IT queue is
clear, a dubious assumption).
The flaws are equally obvious, however. Unless the bigger picture is considered in
addressing the problem, incorporating the concerns of all constituents involved –
including flight operations personnel, maintenance staff, external vendors,
regulators, and many more – this “one off” is likely to be satisfactory for a brief
period, if that long.
A more strategic approach is often merited, especially since the nature of the
challenges in this area has migrated to a strategic level in many commercial
aviation organizations. In this mode, carriers typically turn to a team of outsourced
software specialists guided by internal IT to analyze the problem with an eye to the
broader organizational issues, and propose a costly, long term project to build –
largely from scratch – a fully customized solution.
It’s no surprise that while these projects promise a precise fit for the carrier’s
specific needs (as currently defined), they often produce cost overruns, delays, and
the inflexibility that results from “hard coded” applications for narrow problems.
That’s a function of two factors: the airline industry’s relative inexperience with
TDM, and their outsourced developers’ bias toward labor-intensive, high cost
projects that promise complex engagements with long maintenance “tails.”

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 Technical Documentation Management, Aviation Safety, and Regulatory
Compliance: Strategic Pressures, New Solutions for Flight Operations

It’s a challenge every carrier must consider – how to cost-effectively address

immediate document management needs without over-investing in a technical
“dead end” that can’t support the unpredictable requirements of the future.

Designing the Perfect TDM Solution

A middle course, between “band aid” solutions on existing systems and top-to-
bottom custom software development, is required in this dynamic, increasingly
vital area.
The ideal TDM solution would combine a state-of-the-art technology foundation for
authoring, transforming, managing, distributing, and updating technical
information; an easily-customized set of interchangeable, aviation-aware
application “modules” to handle common flight ops processes and reporting
requirements; and the expertise to define, customize, implement, and support the
system, freeing airline IT to focus on other tasks.

EFB
Laptop
Airworthiness
Directives (Ads)

Engineering Orders (EO /EA)

Job Cards
ECRA
Flight Ops (FOM)
MSA
Min Eq List (MEL)
ATA 100
Fueling Man. (FM)
ATA 2100
Training (SCORM)
ATA 2200
S1000D Oversight
Failure Rates

Gen Maint Man. (GMM)

Tech Ass Req. (TR)
Cust Orig Change (COC) Field Notices

Compliance
AMM
EMM Collaboration
SRM
CMM

(IPC)
(WDM) Maintenance Squedules
Engine (IPC) Overnight RON
Service Bulletins (SBs) A,B,C,D Checks
1

Appropriate aviation TDM systems offer a suite of function-specific applications built

on a sophisticated content management "core," easing information creation,
management, distribution, updating, and reporting
While the “perfect” solution is simple to conceptualize, it’s harder to find in the
marketplace. Tried and true enterprise content management (ECM) technologies
are widely available, but aren’t easily adapted to aviation-specific requirements.
The expertise to create “smart” flight operations applications exists, but isn’t
typically tied to appropriate ECM solutions, even if they are adaptable to airline
needs. Even less common is expert consulting services to accurate define and
customize a full solution for the flight operations compliance requirements of
global carriers.
A new breed of solutions, led by emerging firms like TechPubs, is changing this
landscape. Teamed with Parametric Technology Corporation, a global leader in
ECM in many industries, TechPubs has introduced the first flight operations TDM
solution that offers proven technical excellence; modular, easily-configured flight
ops applications, and the consulting expertise needed to make a perfect “fit” for
every carrier – without the heavy overhead of building from scratch.

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 Technical Documentation Management, Aviation Safety, and Regulatory
Compliance: Strategic Pressures, New Solutions for Flight Operations

The Future
All industry participants’ interests – from the flying public, to carriers, to regulators
– are best served if flight operations personnel have access to the freshest, most
accurate data wherever and whenever it’s needed. The challenge is to make that
practical, affordable, and technically extensible in an era of skyrocketing costs,
shrinking margins, and regulatory pressure.
But promising new solutions built with best-of-breed components and delivered by
industry experts are increasingly available today. With these solutions in place, the
global airline industry stands to enjoy greater efficiency, safety, and compliance
with regulatory bodies charged with monitoring their activities.

About TechPubs, Inc.

TechPubs, a PTC Global Airline Industry Platinum Partner, has joined with PTC to
develop FlightPubs and FlightComply - a customized application suite that
simplifies the authoring, publication, management, distribution, reuse, and
updating of operational document, while supporting regulatory compliance and
reporting needs.
TechPubs is an exceptional team of industry veterans comprised of aerospace
professionals, electronic manual designers, flight standard directors, regulatory
compliance experts and airline operations experts. With our combined expertise,
we have resolved the challenge of our industry’s unique publishing needs with the
development of FlightPubs and FlightComply.
More information is available from www.techpubsglobal.com, or at info@tech-
pubs.com.

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