International Acceptance of Repairs: The Way Forward

1
International Acceptance of Repairs The Way
Forward

• Dave Hempe
• Federal Aviation Administration

2
International Acceptance of RepairsThe Way
Forward

• Welcome
• Ground Rules
• Session broken into two parts
• First Hour - Six 10 to 15 minute speakers
• Second Hour - Question/Answers/Brainstorming
• Goal - Identify possible next steps between
  authorities and industry
• Out of box thinking

3
International Acceptance of RepairsThe Way
Forward

• Speakers
• Engineering Repair Approval Process How to
  Proceed? Presenter David Hempe (FAA)
• International Acceptance of Repair Data Proposal.
  Presenter Boeing - Web Heath
• Repair/Alteration Data Developed by JAA
  Maintenance Organizations. Presenter AEA -
  Werner Leuhmann
• Current and Future TCCA/FAA Memorandum of
  Agreement on Repairs. Presenter TCCA - Martin
  Eley Brian Whitehead
• Installation Requirements/Paperwork Trail,
  Difficulties and Possibilities for the Future
  Presenter FAA - Leo Weston
• NAA/JAA System for Repair Design, Production and
  Embodiment A Summary Review. Presenter JAA
  Koos van der Spek Gert Litterscheidt

4
International Acceptance of RepairsThe Way
Forward

• Attributes of Type Validation Principles
• Maximum credit given to certifying authority
• Risk management techniques
• System approach to safety
• Works well at product level
• Didnt happen overnight

5
International Acceptance of RepairsThe Way
Forward

• How to move from the airplane to the component
  level
• Develop same mentality around principles and
  oversight
• Find mutual equivalency -System approach
• Apply streamline acceptance of process

6
International Acceptance of RepairsThe Way
Forward

• Principles and Oversight
• How are delegation privileges used at a component
  level
• Repair classification
• minor deviations to major repairs
• Installation procedures
• System oversight
• sampling
• paperwork trail

7
International Acceptance of RepairsThe Way
Forward
WHICH SYSTEM IS RIGHT?
Mutually Recognized
Literal Compliance
Mutually Equivalent
Need to look at everything no risk model
Too Liberal (abdication)
Right balance
8
Major and Minor Determinations - Repairs,
Alterations, and Continue in Service
Is the Change an Alteration listed in the mfgrs
specs?
FAA
NO
Does the Change Affect the Weight?
YES
MAJOR
NO
YES
YES
Balance?
If improperly done, would appreciably affect
airworthiness?
NO
YES
Structural Strength?
Repair?
NO
NO
Performance?
NO
YES
Continue in Service?
NO
Power Plant Operation?
NO
NO
Flight Characteristics?
ALTERATION
NO
Other Airworthiness Qualities?
MINOR
NO
Primary Structural Element?
NO
Accepted Practices or Elementary Operations?
NO
YES
9
NPA 21-8 ISSUE 2
OPERATOR
A
Go to Apply solution
Product first type certificated outside JAA (New
or caught-up)
Damage
JAA
B
Go to NAA for approval
Initial Assessment
existing solution available and approved?
APPLY SOLUTION
yes
Other DOA
NAA
(JAA Countries)
If the repair design originates in a state
outside the JAA, see Subpart N-M
NAA of State of Registration
no
Classification
New Design
no
Is Applicant DOA?
Send data to
Minor?
no
Other DOA
Classification (If not previously classified by
NAA)
Classification
Internal NAA approval process
B
Minor?
no
no
Minor?
Approval of design
yes
yes
A
A
Approval of Design
A
Approval of Design
10
International Acceptance of RepairsThe Way
Forward

• Paper Trail - When you dont have it!!

11
Questionable Repair Practices

• Multiple Repair Patches

12
Questionable Repair Practices

• Improper Stop Drilling

13
Misdrilled Holes
14
International Acceptance of RepairsThe Way
Forward

• CONCLUSION
• IF WE CAN FIND A
• SYSTEM APROACH
• AND ACCEPTABLE RISK
• MANAGEMENT PROCESS
• FOR THE WHOLE AIRPLANE
• THEN COMPONENT/REPAIR LEVEL
• SHOULDNT BE THAT
• DIFFICULT???