Presentation on theme: "Installation Requirements Paperwork Trail Difficulties"— Presentation transcript:
1 Installation Requirements Paperwork Trail Difficulties Leo WestonFederal Aviation Administration
2 Import Aircraft Repair Data The acceptance of repair data on these aircraft is subject to the requirements of FAR (d)Applicant must provide evidence of Conformity to TC &STC’s all Applicable AD’s
3 Import Aircraft Repair Data Must have a 100 hr. inspection per the Additional Performance Standards of FAR 43.15This requires that this aircraft must “be inspected to meet all airworthiness requirements.”Airworthiness as stated on the Airworthiness Certificate meets the requirements of the TC and is maintained in accordance with FAR’ 21, 43 , 91.
4 Import Aircraft Repair Data Repair data is only one item related to the certification requirements of FAR (d)Records necessary to Conform the aircraft are in many instances Insufficient.Basic records needed are as follows1. AD compliance status2.Life limited part records3.Modification Status4.“repair Listing or repair Identification or appropriate data.
5 Import Aircraft Repair Data Data Continued:5.Maintenance and Inspection status of the Aircraft, Engine,Time controlled components etc6.Aging aircraft program statusAircraft Configuration Status in regards to approved equipment I.e. seats.electronic equipment,
6 Import Aircraft Repair Data Is there any standard regulatory requirement for the transfer of Aircraft.FAR Transfer of Maintenance records. Refers as to when a aircraft is “sold”.Includes Total Time ,Life Limited parts,Current status of life limited parts and AD’s Inspection status and last overhaul status.It also requires a description or reference to data Acceptable to the Administrator of work performed
7 Import Aircraft Repair Data This Regulation does not apply to aircraft being transferred from a Foreign registryThis rule has also been applied to the lease transfer of aircraft but is usually a agreement between the operator and lessor.
8 Import Aircraft Repair Data Acceptable Repair Data that if a part of the transfer of a US. T.C. Manufactured product.1. FAA approved structural manual.2.DER approved data3.FAA approved Service Bulletin4.SFAR-365.TCCA Per FAA MOU.6. Appliance Manuals if included in ICA.7. T.C. holders ICA
9 Import Aircraft Repair Data Acceptable Repair Data for U.S.Type Certificated Foreign Manufactured Aircraft under a Bilateral Agreement.FCAA Structural repair manual.FCAA approved data when applicable to a US Registered Aircraft.FAA DER approved Data.Appliance Manuals if a included in the ICA.Data that may be developed under a Bilateral agreement for repair data.
10 Import-Export IssuesProblems Identified with Import of USED Aircraft per FAR (d)This FAR has clearly prescribed requirements in that specific items must be provided and it clearly states that the inspection required by FAR requires compliance with ALL airworthiness requirements.This requires three basic Items .1.Complete records2.Inspection to satisfy FAR 43.153. Conformity finding by the FAA .
11 Import-Export Issues Problem Items regarding Certification. 1.Lack of Maintenance documents(a) Total aircraft times(b) A.D.Compliance(c) Records for repairs and modifications(d) Aging Aircraft program.(e) Life limited part status(f) Aircraft Inspection Status.2. Records not readable due to poor documents or not in the English .Major -minor repair classification.
12 Import-Export Issues Inspection Requirements of FAR-43.15 This FAR requires a 100 hr Inspection.Large aircraft are usually on different type programs and it is necessary on a airplane by airplane to determine compliance with the intent of Appendix-D of FAR 43.This section of the Regulation states the aircraft must be inspected to meet all the “airworthiness requirements”
14 SummaryThere is no regulatory requirement for the transfer of data for the import of aircraft into the USAdvisory Circular AC21-2 does specify requirements when exporting Aircraft from the U.SFAR (d) Other Aircraft &FAR set up the basic requirements for certification of import aircraft to the US.There is a need to develop a process to make it clear what is acceptable data to comply with not only repair data but the necessary requirements to meet the requirements of FAR 43.15
15 Summary Establish a TOR in the HMT to: 1. Identify the issues and recommend standard procedures2.Review present BA to determine acceptance of a FCAA certifications.3.Recommend a list of records and a standard language and policy for acceptance of repair data required for the certification process.
16 SummaryThis was a item was proposed twice and industry cooperation was not received .If the certification process is going to function properly either a regulatory process or agreed to industry practices needs to be developed.