Part 135 GMM – Page 2


Continued from GMM page 1:

Operator Responsibilities

Hundreds of hours of development have gone into making this GMM as turn-key and user friendly (and FAA-friendly) as possible. However, effective implementation of any GMM will depend on the level of active commitment from the management team of the operator. The operator’s management team will need to thoroughly review the entire document.

It is also recommended for the operator’s management team to perform tabletop testing of the procedures, specifically maintenance planning and scheduling, equipment and tool management, parts handling, personnel training, RII procedures, contract maintenance administration, CASS procedures and record keeping. Tabletop testing of all company forms is strongly encouraged.

Any software planned to be used by the maintenance department should be tested in parallel with the GMM procedures and forms test.

Testing these procedures should not take more than two or three days, and will give the operator confidence when presenting the document to the FAA.

Aircraft Specific Maintenance and Inspection Documents and Procedures. The operator is responsible to obtain for itself all required manuals such as AMM, SRM, IPC, and so forth. Additionally, most FSDOs require the operator to prepare what is often called a ‘CAMP document’. This is a list of the required inspections, life limited parts, and other items that determine the maintenance and inspection schedule for each specific tail number on the 10 or more program. Each FSDO handles this a little differently. Working with your PMI and PAI will be the best way to handle this.

Best Practice. For operators who want to have the best understanding of their GMM and develop a fuller picture of the regulatory and guidance requirements, it is highly recommended that the management team read through the SAS questions thoroughly and then look at the cross-reference in the GMM to see how the requirement was met. This process, though slightly painstaking, will put the operator’s management team in the best possible position for a fast approval and to be able to deal with any issues raised by the FAA.

Learning More

Reading Lists. We have developed reading lists from the FAA guidance and SAS checklists. Contact us and we can provide this list along with an initial consultation. These lists will help you learn about the 10 or more requirements and the level of knowledge and procedures that will be required. These are free with the initial phone call (the call is also free).

SAS Checklists. We have a summarized version of the FAA SAS checklists (DCTs) that will give you an overview of the design requirements for a GMM. These are also available free of charge with an initial consultation.

GMM Format

The GMM is formatted in MS Word, and uses standard paragraph heading styles and 1 inch page margins. This document is very easy to edit for operators that prefer to do their own revisions. We are always willing to assist with future revisions, but most operators have no problem working with the document and creating the revisions on their own.

FAQ

Is this GMM already FAA-approved?

First, a technical point, GMMs are accepted rather than approved. The difference is relatively minor from the operator’s perspective, see below. To address the point of the question, there isn’t anything like a manual that has already been given a standing approval or acceptance by the FAA. Each FAA office has its own idea of what a manual should contain. A manual that passes review at one FSDO with no issues could end up having a long list of required corrections at another. Each time a manual is submitted, it is as though it is a brand new document with no previous history. See the next question for more info.

How long will it take to get this GMM accepted?

This depends on two things: How long it takes your FAA team begins to start and complete the review, and what level of change they want to see. Substantial effort has been put into this GMM to make it as comprehensive as possible, and so far it has been passing review with a reasonable amount of corrections. In most cases, the time delay is due to the fact that many PMIs have never approved a 10 or more authorization before. Some have dealt with OpSpec D072, but only with operators already holding that OpSpec. In this case, the PMI and PAI will often be very thorough in their review and often have many ‘corrections’ that are often not errors but simply require clarification.

When the FAA returns the GMM with the list of required corrections, what happens next?

One major key to success is a very fast turn-around. Most of the time we can collaborate on any required changes and return the revised GMM within a week, sometimes less. In a few instances, the FAA wants a more highly developed procedure for some item. As long as the operator makes their management personnel available, we can usually turn the document around in less than two weeks.

A fast turnaround time is crucial for two reasons. First, it shows the FAA that the operator is serious about moving the process along. Second, it prevents the FAA inspectors from losing track of the project in the interim. Inspectors are busy people, and like anyone, you don’t want to give them a month to lose track of where the project was and what the nature of their required corrections were.

Do you guarantee FAA acceptance?

We do not make a specific guarantee of acceptance. That said, we have never left an operator hanging without a completed authorization or approval. Every effort will be made to get the ball over the goal line. Having stated that, it is possible to run into some FAA offices or inspectors who make the approval process extremely difficult. So far, we have not run into one that made it impossible. There have been one or two instances where the FAA made additional demands on the content of the manual outside of the scope of the FAA requirements. In these cases there may be some small additional hourly charges. This will always be discussed with the client before any charges are made. The Terms of Service document (available upon request) sets the official terms and explains contractor and client obligations.

What about revisions? What does this cost?

While we have no problem doing revisions for you if you want us to, our real goal is to deliver a document that is very easy for you to revise yourself. Document formatting is very simple, and it does not take a Word Ninja to make simple corrections. If you really want help, we perform that on an hourly basis.

Intellectual Property

No watermarks or copyright information is places on the GMM. Once we complete the project together the manual is provided to you in an unlocked Word document. Finished PDF copies are provided as a convenience as well. No password protection or document security is used.

The only thing asked of you is that you follow the provisions in the Terms of Service agreement and avoid disclosing the document to persons who do not have a direct need for access. Rather than attempt to restrict your access or use of the document, we prefer to trust the operators we do business with. Many of our clients have given us business referrals to other operators, which is always appreciated.

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