Federal Aviation Administration Presented to: US/Europe Aviation Safety Conference Presented by: Fran Favara, Manager Engine & Propeller Directorate Rick

Federal AviationAdministration

Presented to: US/Europe Aviation Safety Conference

Presented by: Fran Favara, Manager Engine & Propeller Directorate

Rick Domingo, Deputy Manager,

Flight Standards Northwest Mountain Region

Date: June 5, 2008

AVS Repair, Alteration and Fabrication Team (RAFT) Results

22Federal AviationAdministrationUS/Europe Aviation Safety Conference June 5, 2008

AVS Repair Alteration and Fabrication Team Results

How did this start?

Owners/operators need and want less costly parts and components that are safe, compliant and that are accepted as such in today’s competitive global environment.



The Key Issues

Concerns raised by TC/PC holders and component OEMs about repairs, alterations, fabrications, and replacement part designs:

• Not adequately engineered and evaluated for compliance

• Being performed on more safety critical parts and complex systems increasing the threat to safety,

• Are being misrepresented as TC/PC holder parts, and

• Create an un-even commercial playing field because FAA does not hold all applicants to the same standards

Unfounded Safety Recommendations and SUPs reports from FAA inspectors and private individuals.



Secondary Drivers

• Commercial competition between TC/PC holders and the independent after market parts suppliers and maintenance providers

• TC/PC holders diversifying into leasing and maintenance

• Owners/operators are contracting maintenance which will continue to increase globally

• Liability concern of TC/PC holders and owner/operators about aftermarket parts and repairs which affects:– Insurance implications

– Resale value aircraft and parts

– Exportability of aircraft and parts



How is FAA responding?

• Chartered an AVS team* to review all regulations and policy related to repair, alteration, and fabrication during maintenance

• Identify any gaps and recommend possible solutions:

– Training

– Policy changes

– Rule changes

* Flight Standards and Aircraft Certification



What Will the Team’s Report Contain?

• Research Documentation

• Drivers and Issues

• Conclusions and Recommendations

• Proposed Plan to close gaps identified by the study to ensure:

– A joint AVS & Industry strategy

– Consistency of definitions, interpretations and application of requirements

– Identify which rules or policy need revision



Industry input

When did we start?

February 07

1ST Qtr. 08

Study complete

End 07

Develop policy…

FAA’s Repair, Alteration and Fabrication Study Team Schedule:

Current Status: • Draft report presented to FAA management late 2007• Presented results to Industry in late 2007 and early 2008• Report to FAA Management and a Proposed Action Plan

completed April 2008



Who is responsible for the airworthiness of the product?

• Standard Certificate of Airworthiness (C of A) is issued under 14 CFR 21.183

• Aircraft must conform to type design (TC)

• Must be in condition for safe operation

• Standard C of A remains in effect as long as the aircraft is maintained and altered in accordance with Parts 43 and 91 (21.181)

• This means that the operator is responsible for the validity of C of A and for the continued compliance with the appropriate airworthiness standards



Where can owner/operators get parts and components?

• Purchase parts, approved per CFR Part 21, Subpart K, from:

– TC/PC Holder

– STC/PMA Holder

– PMA Holder (replacement parts)

– TSOA Holder

• Repair or alter existing parts and components under CFR Part 43.13 using approved or accepted data



Fabrication of parts using FAA approved or accepted data during the conduct of maintenance is permitted by today’s rules:– 14 CFR 43.13(b): “…will do work in such a manner

and use materials of such a quality,…” such that condition after maintenance/alteration will be equal to the product’s original or properly altered condition

– 14 CFR 21.305(d): Any other manner approved by the Administrator • Fabricate their own (owner/produced parts)

• Fabricate during maintenance (repair or alteration)

– Guidance for fabrication is provided in AC 43-18

Fabrication of Parts and Sub-parts



Extensive repairs are allowed by current rules and policy:– FAA’s concern is with safety and compliance

• Not with percent of part repaired (sliver repairs)

• Not with economics of a repair

– Maintenance providers should not do extensive repairs with the intent of circumventing PMA requirements or 14 CFR 21.303

Repairs



• When developing design data for major repairs, major alterations and PMAs the FAA engineers and designees should evaluate whether or not they are a Major or Minor Type Design Change under CFRs 21.113 and 21.93

• Guidance for this is not as explicit as it should be

• Currently Designees are not permitted to make that determination (8110.37)

Effect on the Product’s Type Design



Repair or Alteration ProcessProposed Repair

or Alteration

Amend TC or Obtain STC per Order

8110.4

Approved Data not required –use acceptable

data

Major / Minor Part 43

PerformRepair or Alteration per Approved Data

MINOR

MINOR

Return to Service per

Part 43

Effect on Product Design

21.113

Obtain Approved Data

(DER, 337 block 3, etc.)

MAJOR

MAJOR



Part Marking

• Production Part Marking is covered adequately in CFRs 21 and 45.

• Re-marking parts that have a major alteration performed will be addressed in the next change to CFRs 21 and 45.

• Part Marking for fabrication during maintenance is contained in AC 43-18.

• Part Marking of extensive major repairs and alterations is not covered and is under review by FAA.

• Part Marking of owner produced parts is not covered and is under review by FAA.



• Review DER authorization categories and limitations and make appropriate changes to better delegate DERs in these areas

• We will also look at our DER training, DER seminars, etc. to ensure that our DERs are continually updated with our policies

• Develop better guidance to help with major/minor design change decisions and issue policy that will ensure standard application

Actions that FAA is considering:



• Clarify policy on “critical parts” consistent with the definition developed under the pending U.S.-EU bilateral agreement as those parts identified by the TC holder during the safety assessments required for type certification and validation

• Clarify how critical parts lists and management plans are documented, transmitted, and used.

• Look at existing guidance such as AC 120-77 and revise to make applicable to repair stations

• Develop new guidance for repairs with templates and other information that will ensure consideration of appropriate airworthiness standards




• Leverage Industry owner/operators and maintenance providers to gather best practices of how they determine Major/Minor repair and alteration classification under CFR 43.

• Implement through the AVS SMS initiative.




• Clarify guidance to emphasize that all repairs, alterations, and fabrications have an Instructions for Continued Airworthiness (ICA) assessments consistent with FAA Order 8110.54 ICA, and

• Clarify how ICA are to be documented and transmitted including those for repair, alteration and PMA.

(Note: AC 43-18 recommends an ICA assessment for fabrication of parts)




Conclusion

• FAA, TC/PC holders and their Suppliers, and Aftermarket Providers need to:

– Objectively investigate service events where repaired, altered and PMA parts may be involved to ensure safety

– Accurately represent all the facts– Share data on repair and alteration service

history and best practices– Reporting Service Difficulties appropriately



• Continue to implement Continued Operational Safety (COS) programs within the PMA community and repair stations.

• Leverage the AVS Safety Management Program to develop and disseminate guidance on COS management as part of certificate and approval holders’ SMS requirements.

Conclusion



Thank You !

Questions?

Documents

Federal Aviation Administration Presented to: US/Europe Aviation Safety Conference Presented by: Fran Favara, Manager Engine & Propeller Directorate Rick