This quote is also from my addendum (supplement) to my first report.
Please investigate the lack of "OK to Install" and "OK to Close" inspections at PSD and the lack of anti-tamper seals on closures done, between the time closure is done at PSD and when the area is opened back up at the Prime Divisions--if they are opened back up.
Because of our lack of a Closure Inspection QOI and our lack of an ethical QA Planning department, a lot of critical work that is done at PSD is closed off to inspection before an inspector inspects it, and/or there is no evidence that the work was inspected if you looked at the plan.
One example, of a possible many, is in the strut shop. Normally, except for the case of the item 43 shakedown inspection referenced above, line inspectors do the shakedown inspection of the struts before the access panels that close off the interior of the strut are installed. These panels are temporarily installed in Wichita or at the vendor, as the case may be, and then removed from the strut by mechanics prior to the receival inspection of the struts. They do their work, we sometimes inspect it [pending on whether the inspector thinks they are an inspector, as our job description (see Exhibit AA) and FAA-approved QA Manual states, or simply a mechanic trainer, as our QA Supervisors say], and then do the shakedown inspection when the work is complete. It used to be that the shakedown inspection was done on its own job, and the access panels were installed on their own crate job, but now, I believe, all of the shakedown inspections are simply in-process inspections on the crate jobs, fitting in with our QA Management’s diminution of our line inspector’s jobs into nothingness, and we do not have our own separate QA shakedown jobs anymore in struts.
This also dovetails with our QA Management’s goal of getting us to roller stamp the shakedown inspection, as they don’t see it has any value, as their thinking is exactly the same as the Manufacturing Supervisor’s, who bitch when an inspector takes more than a few minutes on a shakedown inspection. Having a separate QA shakedown job implies that the job is so important and extensive that it requires its own, separate, O&IR. Having the shakedown be just another in-process inspection on a shop O&IR implies it is no more important or time consuming than an electrical bonding inspection most of us line inspectors roller stamp.
I guess I’m somewhat off subject on this. Anyway, after the shakedown inspection, shop just installs the access panels, no matter if they are installed on the same job as the shakedown inspection was done, or not. There is no "OK to Install" inspection for the panels that would invoke the controls, by line inspectors, of the closing of the panels per our Closure Inspection (written procedure), which I believe is (a procedure) that only I am aware of in the PSD QA ranks.
So, once the shakedown is done, shop could install the panels immediately thereafter, maintaining the integrity of the inspection, or install them the next day, the next week, whatever they want to do. We will never inspect inside the strut again, no matter how long the period between the time when we did the shakedown and when the panels were installed, as there is no required "OK to Close" inspection on the jobs.
There is one exception. 747 struts have an "OK to Install" inspection on the fairing installation job after the Customer Shakedown of the struts (reference job I.D. and line number). But, to my knowledge, the 757, 767, and 777 struts are afflicted with the aforesaid problem.
I believe I was told at one time that all of the access doors on the struts were opened at the Prime Divisions for functional testing inspections, so that is why we are so cavalier about the "OK to Close" on these panels.
But, even if that rumor is true, there should be a note on the plan that states that the panels will be opened on a certain job in Everett or Renton, and that is not the final installation of those panels prior to delivery. And if only some of the panels are removed later, then there should be, at a minimum, an "OK to Close" inspection on the panels that will not be removed.
But there is also another problem with this whole situation. What about controls for securing these inspected strut interior area’s inspection status from tampering between the time of the "final inspection" of them--the shakedown inspection--and the time the panels are removed, if they are removed, at the Prime Divisions? Right. There are no controls, although the integrity of the inspection status of parts is of paramount concern, I believe, in your FARs, and in our, unknown to virtually all inspectors at PSD (because our management wants us to be ignorant of it, among other things), (written procedure) on Closure Inspection.
There should be an "OK to Close" inspection for these panels, even if they are to be removed later, so that the necessary controls will be put in place to preclude tampering with the inspection status of the part, and/or entry of FOD and/or animals into the to-be-closed-some-unknown-time-in-the-future strut interior areas, by application of "Do Not Break" inspection seals on the access doors, as the (written procedure) requires, to assure the Prime Divisions that the closed areas weren’t tampered with between our shakedown inspection, and the time they are opened at the Prime Divisions, if they are opened.
Some strut locations have double doors, with both an interior, primed door, and an exterior, top coated door/fairing. The interior door could have a paper label, or inspection putty (as the wing tank access doors get), and the outer doors would just get a temporary paper label that would be removed in preflight, or when that door was opened during scheduled work in the factory.
This could actually save the Company money, by only complying with requirements (this would be an alien concept to our management, whose philosophy only states that money can be saved by not complying with requirements).
If a panel does not need to be opened at the Prime Divisions, there would be no need to open it just to see if that area was not tampered with in the factory before flight, or to see if CDC had conveniently "borrowed" a part from an accepted installation as they are rumored to do on occasion, without the bothersome paperwork, if the seals were still intact on the panel, indicating it had not been opened since inspection. These seals could be removed at any convenient time during preflight activities.
Anyway, please investigate this whole situation, and tell us how we should be doing these closures and coordinate the jobs to ensure that both PSD and Prime Divisions know what each other does to these panels, so the proper controls can be put in place to preserve the integrity of inspection status, as we have no clue.
The Last Inspector