afs-300 air carrier maintenance division...
TRANSCRIPT
Federal Aviation Administration
By: Tim Shaver, Manager Aircraft Maintenance Division, AFS-300 Date: March 2016
AFS-300
Air Carrier Maintenance Division
General
2 Federal Aviation Administration
The Division
Rulemaking
Contract Maintenance
MRO Initiative
Global
Teams
3 Federal Aviation Administration
Aircraft Maintenance Division, AFS-300, Organizational Structure
Tony Janco Senior Field
Technical Liaison and Integration
AFS-304
ACO, MIDO, AEG
Patricia Williams (Acting)
Assistant Manager AFS-301a
Daniel Bryan Program Mgmt. &
Info AFS-310
Rolandos Lazaris (Acting)
Assistant Deputy Manager
AFS-301b
Dale Hawkins Special Programs
AFS-320
John Dugan Air Carrier
Maintenance AFS-330
George Padalec (Acting)
Repair Station AFS-340
Kevin Morgan General Aviation
AFS-350
Charlie Fellows (Acting) Avionics AFS-360
Jim Hein FAAST Team
Davetta Ogunlola Admin Support AFS-301a/b
Tim Shaver Division Manager
AFS-300
Vacant Special Assistant
Dr. Bill Johnson CSTA
Vacant
AFS-300 Assistant
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Aircraft Maintenance Division We develop and standardize the regulations, national directives, policy and procedures for:
General Aviation Maintenance Air Carrier Maintenance Avionics Maintenance Designees Airmen FAAST Airworthiness Air Agencies (AMTS and Repair Stations)
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Branch Functions
AFS-310
Program Management and Information
Strategic and tactical planning; fiscal and human resource management; program management and analysis; information
management; and general administrative management of the division; Respond to
Freedom of Information Act requests; Monitor cost accounting system/LDR; Manage division
publications; Focal for knowledge sharing network (KSN); Focal quality Management;
Focal AFS-500 curriculum.
AFS-320
Special Programs Focal for incoming FAA and National
Transportation Safety Board (NTSB) safety recommendations; technical liaison to the Aircraft Certification Service (AIR); Suspected Unapproved Parts (SUP) Program, the Aircraft Evaluation Group
(AEG) Managers; Supports Unmanned Aerial Systems (UAS) initiatives.
AFS-330
Air Carrier Develop regulations and standardize national
guidance on maintenance for Title 14 of the Code of Federal Regulations (14 CFR) parts 91 subpart K (91K),
119, 121, 125, 129, 135, and 136; focal for the Operations Specifications Working Groups (OSWG), human factors, ICAO, Maintenance Review Board Policy Board; Technical assistance Extended Ops, Continuous airworthiness, Joint Implementation
Measurement and Data Analysis; Service Difficulty Reporting.
AFS-340
Repair Station Develop regulations and standardize national
guidance and rulemaking for FAA-certificated repair stations; Implement and oversee BASA/MIP
agreements with foreign Aviation Authorities; Coordinate with AFS-50; Develop, evaluate, and
implement policy for Cargo Focus Team; Evaluate, recommend or deny exemptions to 14 CFR part 145.
AFS-350
General Aviation Develop regulations and standardize national
guidance and rulemaking for airmen certification, AMTS, and GA maintenance under for 14 CFR parts 43, 65 subparts D, E, and F, 91, 103, 105, 133, 137, and 147; focal point for GA functions concerning maintenance regulatory aspects of 14 CFR parts 21, 23, 25, 27, and 29 regarding
data approvals for repairs and alterations; Support AFS-600 and AFS-700 regarding AFS-300 areas of responsibility ; Develop, evaluate, and implement policy for maintenance, alteration,
and airworthiness of aircraft used by pilot schools, external-load, special purpose, agriculture, and light-sport aircraft (LSA)
operators.
AFS-360
Avionics Develop policy and guidance for large/small aircraft and operating certificate holders under parts 43, 91, 121, 125, 129, 133, 135, 136, and 137 for avionics, radio, instruments, and electrical systems; Support and coordinate all avionics, radio, instrument, and electrical systems policy ; focal point for avionics,
radio, instruments, and electrical systems concerning maintenance regulatory aspects of parts 21, 23, 25, 27, and 29 regarding data approvals for
repairs and alterations; manage focus teams to support the field and the industry on various
avionics technical and operational issues (e.g., Automatic Dependent Surveillance-Broadcast (ADS-
B) Focus team).
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Rulemaking Activity Part 147, Aviation Maintenance Technician School
Revise the regulatory requirements concerning Curriculum, Operating Rules and Appendices A, B, C, and D in part 147.
• NPRM published on 10/02/15 for public comment. However, it was extended until February 1, 2016.
• As of Jan. 7th, 2016, revisions to four 8900.1 orders on AMTS have been distributed to the Regional Offices for comments.
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Major Repairs and Alterations Data • AC 43-210 “Standardized Procedures for Requesting
Field Approval of Data, Major Alterations, and Repairs. Document” – Align the AC with FAA Order 8300.16 (an AIR/AFS joint order). – Changes include:
• Title change – Removed “Field Approval” from title • Adds DAR Function code 52 authority to perform field approval • Change of DAS terminology to ODA • Update procedures for Flight Manual Supplemental approval • Most significant: AIR requested cancelation of “AC 21-47 -
Submittal of Data to an ACO, a DER or an ODA for a Major Repair or a Major Alteration” and added to the introduction of AC 43.210
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Major Repairs and Alterations Data • AC 120-77 “Maintenance and Alteration Data”
– Establish working group to revise and address current issues.
– Focus Areas: • Better define “appreciably affects” applicable to each
airworthiness characteristic • Address new and novel considerations (Software, Aircraft
data networks, composite) • Better address 43 Appendix A “…when not listed in the
aircraft specifications issued by the FAA…”
• Activity just starting. Kick-off TBD.
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Evolution of Contract Maintenance
Early Regulatory
maintenance manual
Requirement
DOT/IG Issued Report (Certificated
Part 145 repair stations)
NPRM Published
SabreTech Value Jet
Crash
3/04/2015
DOT/IG Issued Report
(Non-certificated
repair facilities)
Congressional Hearing
DOT/IG Issued Report (Outsourcing maintenance)
1965
1996
2007 2008
11/2012 2003 2005
2009
2012
FAA Published
Best Practice
AC
FAA Modernization Reform Act
2010
FAA Reviewed
manual procedures
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Contract Maintenance New Section 121.368/135.426
Maintenance Provider – any person who performs maintenance, preventive maintenance, …….
Covered work - means any of the following: – Essential maintenance, if not performed properly or if
improper parts or materials are used, could result in a failure, malfunction, or defect endangering the safe operation of an aircraft;
– Regularly scheduled maintenance; or – A required inspection item on an aircraft.
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Contract Maintenance “Each certificate holder who contracts for maintenance, preventive maintenance, or alterations must provide to its FAA Certificate Holding District Office, in a format acceptable to the FAA, a list that includes the name and physical (street) address, or addresses, where the work is carried out for each maintenance provider that performs work for the certificate holder, and a description of the type of maintenance, preventive maintenance, or alteration that is to be performed at each location. The list must be updated with any changes, including additions or deletions, and the updated list provided to the FAA in a format acceptable to the FAA by the last day of each calendar month.”
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Contract Maintenance
Directly in charge – means having responsibility for covered work performed by a maintenance provider. A representative of the certificate holder directly in charge of covered work does not need to physically observe and direct each maintenance provider constantly, they must be available for consultation on matters requiring instruction or decision.
13 Federal Aviation Administration
Safety Assurance System
Screen shots of the maintenance category entry for contractors – could be “imported”
This acceptable format could be in “excel”
121.368 (h) “…format acceptable to the FAA….”
14 Federal Aviation Administration
Field Offices transitioned to the SAS tool for
14 CFR part 121, 135 and 145.
Safety Assurance System
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Maintenance, Repair and
Overhaul (MRO)
Audit and Data
Sharing Initiative
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Addressing the Issue Develop a process that will reduce the number of unnecessary
audits. (Includes the multitude of regulator audits as well as those audits performed by certificated entities on each other)
Focused risk-based inspections supported by data, in lieu of random selection.
Address Safety Management Systems as related to these audits.
Briefings were held for field inspectors and management to evolve the thinking behind consolidation of CMP surveillance and data sharing of identified risk.
Revisions were made to FAA Order 8900.1 V6C2S40, V6C9S18, and V6C9S22 along with the SAS tools used to request repair station assistance.
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Past: Annual “Regional Team Focused Inspections” (R items) were mandated in FAA Order 1800.56N (August 14, 2013) “National Flight Standards Work Program Guidelines” for air carrier contract maintenance providers.
Present: The mandatory requirement for these inspections was removed in revision “O” of this Order (December 3, 2014). (P is current revision level.)
Future: “Regional Team Focused Inspections” will be conducted based on risk indicators. Contract Maintenance Providers (CMP) will be audited based on risk with supporting data shared through systems such as SAS and SPAS.
Where we are going - Philosophy
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Part 121 ATOS = Part 145 SAS ATOS EPI 1.3.7 (Part 121) SAS EP 4.2.7 (Part 145) 1.15 Did the maintenance provider appropriately perform maintenance?
1. Best describe how the procedures were followed to perform work for air carriers and commercial Operators per their maintenance program.
1.24 Did personnel performing required inspections; • Hold an appropriate airman certificate, or • Meet 14 CFR 145.155 and 145.157 if the work is
performed by a repair station located outside the United States?
1.6 Were on-wing required inspection items (essential maintenance) performed only by a listed essential maintenance provider?
2. Best describe how the air carrier maintenance RII procedures were followed to ensure that: #1 A person was designated (by title) to maintain a current list of RII inspectors; #2 Air carrier information was available to inspection personnel when the work was performed; and #3 Maintenance and inspection personnel were separated in the organizational chart.
1.15 Did the maintenance provider appropriately perform maintenance? 1.21 Were maintenance provider personnel trained and competent to perform the assigned work? 1.12 Did the maintenance provider use current manual(s) or parts thereof?
3. Best describe how the procedures were followed to: #1 Perform line maintenance for 14 CFR Part 121, 135, or 129 Operators per their manual and approved maintenance program; #2 Perform maintenance with the necessary equipment, trained personnel, and technical data.
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Part 121 ATOS = Part 145 SAS Continued
ATOS EPI 1.3.7 (Part 121) SAS EP 4.2.7 (Part 145)
1.21 Were maintenance provider personnel trained and competent to perform the assigned work?
15. Verify that the personnel were trained on air carrier maintenance procedures. 16. Verify that the RII inspectors were: #1 Trained in the air carrier's RII procedures including how to perform and record the inspection; and #2 Qualified and authorized by the air carrier.
1.16 Did the maintenance provider accurately and completely document all maintenance they performed?
A SAFE is pending that will ensure this question is incorporated into SAS. See Record ID: Er Id#-00954
1.14 Did the maintenance provider only accomplish the work the operator authorized?
A SAFE is pending that will ensure this question is incorporated into SAS. See Record ID: Er Id#-00954
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Establish common regulatory acceptance of oversight standards between regulators for audits. o (AS 9100 International Aviation Quality Group or other standard)
Increase audit efficiency thru standards harmonization.
Reduce audit burden without compromising safety,
target 15% in the first three years.
Global Improvement
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Outcome
Streamlined and standardized audits Sharing of data
Reduction in the number of audits
Reduction in cost
Reduction in duplication
Enhance Safety
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Global Leadership
Bilateral Relationship
Bilateral Process
Standard Guidance
Policy and Guidance to
Assure Effective
Implementation
Tools to Collect Data and Measure
Effectiveness of Process
Development of Metrics and Indicators Effectively
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C - Canada M - EU States S - Switzerland S - Singapore
S
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Global Leadership
Republic of Austria Kingdom of Belgium Czech Republic Kingdom of Denmark Republic of Finland French Republic Federal Republic of Germany Ireland Italian Republic Grand Duchy of Luxembourg Republic of Malta Kingdom of the Netherlands Republic of Poland Portuguese Republic Kingdom of Spain Kingdom of Sweden United Kingdom of Great Britain and Northern Ireland
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Tim Shaver, Manager Aircraft Maintenance Division, AFS-300 [email protected]