1. 1 19 March 2014Engineering & Maintenance Sub-Committee Briefing SSCC Engineering & Maintenance Sub-Committee Briefing to P&M TAG Liam Sisk Chairman

2. 2 19 March 2014Engineering & Maintenance Sub-Committee Briefing Why are rules too complex?  Requirements spread across different rules and AMC material (e.g. Part M and Part 145 overlap)  Requirements not ‘proportionate’ despite assertions to that effect – see GA activities to address now….  No clear ‘philosophy’ behind rules – is it performance, objective or risk based regulation?  AMC material not written in a consistent manner and frequently contains too many words to describe a potentially straightforward and simple requirement – what is wrong with using a simple table to clarify a requirement?  Translation of AMC results in different interpretations caused in some cases by the (English) language inconsistencies in the AMC itself (use of ‘shall’; ‘should’; ‘may’; etc)  Have fallen into trap (perhaps) of ‘paper doesn’t refuse ink’

3. 3 19 March 2014Engineering & Maintenance Sub-Committee Briefing Size of Rulemaking Programme  Needs to be much reduced  Develop ‘quota’ or limit for number of tasks which can be progressed at one time under each major regulatory heading (once established)  Process for determining which tasks are being progressed must have room for tasks driven by ‘industry needs’ as well as safety related tasks

4. 4 19 March 2014Engineering & Maintenance Sub-Committee Briefing What type of material should be in the rules  Keep the Basic Rule simple and do not add complex requirements into Basic Rule  Should be a ‘light’ framework for the areas being addressed  This philosophy will only work with a much more effective and transparent standardisation process  Should industry have a role in standardisation?

5. 5 19 March 2014Engineering & Maintenance Sub-Committee Briefing What type of material should be in the AMC/GM  Clear philosophy required as to what is AMC and what should be included there and what GM should be used for  Working groups need clear instructions / guidelines re development of proposed rule changes and associated AMC/GM  AMC should amplify and clarify the rule in a simple and clearly written manner – long sentences and paragraphs to be avoided

6. 6 19 March 2014Engineering & Maintenance Sub-Committee Briefing Current implementation issues  See GA input from Franz x 2  Implementation issues more frequently raised from certain member states – ‘standardisation’ appears not to be effective in resolving these issues

7. 7 19 March 2014Engineering & Maintenance Sub-Committee Briefing Implementation difficulties  Over complex regulations  Too many regulations  Increased difficulties in bringing new personnel through licencing system  Fewer certifying staff available for small and medium organisations  More ‘pressure’ in the system = potential longer term safety concern?

8. 8 19 March 2014Engineering & Maintenance Sub-Committee Briefing Summary  ‘Simplify, simplify, simplify’ – outgoing ED statement