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The Knowledge Dilema

By Antonio Salem Gómez - S&A Aeronautical Consulting Group
Founder & CEO


By Antonio Salem Gómez | Founder & CEO - Tue, 03/07/2023 - 11:00

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The Mexican aeronautical authority (AFAC) is making a great effort to recover the Category 1 (Cat. 1) status on the International Aviation Safety Assessment (IASA) program, audited by the US Federal Aviation Administration (FAA). Some of the findings are related to changes in regulations and others to required investment, specifically in personnel.

There is no question that eventually Mexico will “pass” and recover Cat. 1, but let’s look at one issue that is difficult to comply with: the knowledge of personnel.

For this purpose, I refer to  knowledge as those capabilities and skills needed to make high-level decisions, correctly apply criteria and having a background of information that allows you to go further than just follow a checklist.

Besides Cat. 1 recovery, the knowledge required of AFAC personnel who  make rules, audit and oversee operations in our country is far beyond that obtained through  some training courses or the fact of having “some” professional experience.

To correctly carry out AFAC’s responsibilities requires a full understanding of rules and also of the reasons why they were issued. There are scenarios where someone appears to be  complying with the rules but, in fact, they are creating the risk of an accident.

Also, this knowledge implies that ability to figure out real situations and not just what is shown in an audit environment. An experienced auditor can identify half truths or lies.

There is no doubt that AFAC has a number of personnel who have this knowledge, but there is also a large group of them who do  not. The question is, how will AFAC acquire this knowledge?

Believing  that a few training courses and a percentage increase in salary will solve the need is a mistake. Of course, these are required too, but they will not automatically transfer enough knowledge to rookies.

Bringing in experienced personnel from companies would require AFAC to pay salaries that are at least similar, if not better, than in the private sector We all know that this will not happen. To wait for the development of new personnel is too risky, and they almost certainly  will migrate to companies as soon as they gain some knowledge.

How can we solve this dilemma?

We can look to the US and European Union aeronautical authorities as  good examples. They have few people in relation to their fleet size, but those people are well prepared, very skilled, with a great deal of  experience in the organization’s operation and with high salaries.

How do they manage large fleets? With the help of a group of people with the same characteristics but who do not work within the authority itself. They are individuals or companies that are “designated.”.

In the US, for example, there are Designated Airworthiness Representatives (DARs) that perform inspections, issue Airworthiness Certificates and conduct other activities on behalf of the FAA.

There are also Designated Engineering Representatives (DERs) that process Supplemental Type Certificates (STC), modifications and others, also on behalf of the FAA.

The FAA may appoint as many DARs and DERs as needed and where required. It is not easy to get such a designation. The aforementioned knowledge must be fully demonstrated as well as an honest professional trajectory.

DAR or DER services are not cheap but they earn every penny. Certainly,  operators can go directly to the FAA for these documents, but due to the limited resources, it would take , long time.

Designation from the FAA also does not mean a blank check. There is close oversight of designees to prevent mistakes or corruption. Constant training and updating on  new, clarified or changed rules also avoid misunderstandings. To keep a designation is not easy.

It may not be the perfect solution, but it has worked well for the US and Europe for many years. Can it be applied in Mexico?, I think so, although the law would require changes to implement similar figures.

Mexico needs a new method of overseeing  aviation. Increase personnel numbers with rookies will neither fulfill current requirements nor future needs. Improving employee conditions and training will reduce the leak, but not solve the problem of knowledge.

In Mexico, there are a number of retired pilots, engineers, technicians and other aviation professionals eager to help AFAC to improve because they too have suffered as a result of this lack of knowledge.

With the use of figures like DAR or DER, AFAC can focus on developing its personnel without the pressure of running the operation. Also, AFAC can employ a selected group of reliable experts to take care of the day-to-day tasks without a cost.

From the operator's point of view, there are also benefits. Perhaps the greatest is in the response time for their documents. They will avoid delays due to misunderstandings around the rules and, even if there is a cost, it would be deductible. Bribes are not.

DAR and DER are not merely intermediaries between operators and the FAA. Among their services, they advise how to comply with rules and explain the requirements. In many cases, they can also show you how to improve your operation, which is a bonus.

This proposal requires a change in the current paradigm, in which  we have to recognize that it is possible for the aeronautical authority to delegate without losing control. The key is to learn from best practices.

Photo by:   Antonio Salem Gómez

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