AVS Repair, Alteration and Fabrication Team RAFT Results

1
AVS Repair, Alteration and Fabrication Team
(RAFT) Results
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• 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 todays competitive
  global environment.

3

• 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.

4

• 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

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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

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What Will the Teams 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

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• FAAs 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

Industry input
When did we start?
Study complete
Develop policy
February 07
1ST Qtr. 08
End 07
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• 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

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• 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

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Fabrication of Parts and Sub-parts

• Fabrication of parts using FAA approved or
  accepted data during the conduct of maintenance
  is permitted by todays 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 products 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

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Repairs

• Extensive repairs are allowed by current rules
  and policy
• FAAs 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

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Effect on the Products Type Design

• 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)

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Repair or Alteration Process
Proposed Repair or Alteration
MINOR
MAJOR
Major / Minor

Part 43
Effect on
MINOR
MAJOR
Product Design
21.113
Approved Data
not required

Obtain
use acceptable
Approved Data
data
(
DER
,
337
block
3
,
etc
.)
Amend TC or
Obtain STC
per Order
8110
.
4
Perform Repair or Alteration per Approved Data
Return to
Service per
Part
43
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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.

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Actions that FAA is considering

• 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

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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

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Actions that FAA is considering

• 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.

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Actions that FAA is considering

• 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)

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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

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Conclusion

• 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.

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Thank You !

• Questions?