Scribe marks, part 2

Air Safety Week, June 7, 2004

Recall recent Federal Aviation Administration (FAA) action enjoining aviation safety inspectors to heighten their surveillance of technician training concerning the imprudent use of sharp instruments during airplane stripping and painting (see ASW, April 12).

Now an aircraft painting project has been raised to the level of "substantial maintenance." According to a May 3 Flight Standards Handbook Bulletin for Airworthiness (HBAW 04-02), instances of improper paint removal and scribe marks inflicted on metal structure by sharp instruments warrant increased training of "persons responsible for stripping, preparing and painting an aircraft." In effect, the use of unskilled or marginally skilled labor for a skilled job is no longer tenable. Painters can have a significant impact on safety.

Painting will now be treated as a formal part of an operator's overall maintenance program. The painting process must now be FAA-approved. Once approved, the procedures are locked in, making changes more difficult. Painting now becomes a part of FAA inspection process. In other words, the HBAW brings a whole new level of regulatory oversight to painting.

Operators must modify their FAA-approved "OpSpecs" within 90 days to categorize painting as substantial maintenance. In practical terms, this means including vendors in the operating specifications and specifying the quality oversight function that will be followed. Reduced to its bare essential, the HBAW says: painting is now part of the approved program.

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