1. Federal Aviation Administration Oversight of Contract Maintenance Presented to: U.S./ Europe International Aviation Safety Conference By: Dan Bachelder, Deputy Assistant Manager, Aircraft Maintenance Division Date: June 5, 2008 Maintenance Workshop

2. 2 Federal Aviation Administration Oversight of Contract Maintenance June 5, 2008 Overview Background outsource maintenance Air carrier maintenance –In-House –Uncertificated Facility –Uncertificated Entity –Certified Repair Station –Certified Repair Station Outsources Maintenance Conclusion

3. 3 Federal Aviation Administration Oversight of Contract Maintenance June 5, 2008 Background DOT Office of Inspector General (OIG) issued two reports: Air Carrier Use of Repair Stations (2003) Air Carrier Use of Non-Certificated Facilities (2005) –These reports detailed Air Carriers use of outsource maintenance providers. FAA has been working to improve our oversight systems based on these reports. –Important for both FAA and Industry to focus awareness to those areas of identified risk and take appropriate actions.

4. 4 Federal Aviation Administration Oversight of Contract Maintenance June 5, 2008 Air Carrier In-House Maintenance Airworthiness Release is signed by Air Carrier Work is performed by Certificated and/or Non- Certificated persons at air carrier facilities Work is performed in accordance with Air Carrier’s procedures Aircraft or product is inspected by Air Carrier’s inspection department Air Carrier Maintenance Facility Air Carrier Internal Work Request Personnel “Directly-In-Charge” of a maintenance function must be certificated as a airframe or powerplant mechanic or both A&P

5. 5 Federal Aviation Administration Oversight of Contract Maintenance June 5, 2008 Uncertificated Facility Airworthiness Release is signed by Air Carrier Work is performed by Non-Certificated persons Work is performed in accordance with Air Carrier’s procedures Aircraft or product is inspected by Air Carrier’s inspection department Uncertificated Facility (Ref. OIG Report AV-2006-031) Air Carrier Contracts To

6. 6 Federal Aviation Administration Oversight of Contract Maintenance June 5, 2008 Uncertificated Entity Airworthiness Release is signed by certificated mechanic authorized by the air carrier Work is performed by mechanics certificated under 14 CFR Part 65 & trained by Air Carrier Work is performed in accordance with Air Carrier’s procedures Aircraft or product is inspected by certificated mechanics in accordance with Air Carrier’s procedures Uncertificated Entity (Ref. OIG Report AV-2006-031) Air Carrier Contracts To

7. 7 Federal Aviation Administration Oversight of Contract Maintenance June 5, 2008 What Is Contract Maintenance? Certificated Repair Station Air Carrier Contracts To Repair Station personnel “Directly-In-Charge” of a maintenance function must be certificated as a mechanic or Repairman (N/A foreign) The air carrier, or the person with whom the air carrier arranges for the performance of the maintenance, preventive maintenance, or alterations, prepares or causes to be prepared-- an airworthiness release Work is performed by the Repair Station Work is performed in accordance with the appropriate portions of the Air Carrier’s CAMP, pertinent instructions from its maintenance manual and instructions for continued airworthiness Aircraft or product is inspected by Repair Station personnel Repair Station must hold the specific ratings issued by FAA Repair Station must have a Quality Control System acceptable to FAA

8. 8 Federal Aviation Administration Oversight of Contract Maintenance June 5, 2008 Repair Station Contracts to Non- Certificated Entity Non-Certificated Entity Repair Station Contracts To Repair Station personnel “Directly-In-Charge” of a maintenance function must be certificated as a mechanic or Repairman (N/A foreign) The non- certificated facility must be inspected by the certificated Repair Station Repair Station must hold specific ratings issued by FAA The non- certificated entity must have a quality system equal to the Repair Station’s Airworthiness Release is signed under the authority of the Repair Station Product is inspected by Repair Station personnel FAA is authorized surveillance of the non- certificated entity Maintenance function approved by FAA

9. 9 Federal Aviation Administration Oversight of Contract Maintenance June 5, 2008 Certificated Repair Station Responsibilities 14 CFR 145.211 Quality Control System ( c) (1) (iv), Requires repair stations to audit and qualify each of its non–certificated sub-contractors. The repair station verifies, by test and/or inspection that the work has been performed satisfactorily.

10. 10 Federal Aviation Administration Oversight of Contract Maintenance June 5, 2008 FAA Action The FAA has taken the following action to enhance oversight of Outsource Maintenance Providers: Enhanced Repair Station Oversight System A risk-based, standardized oversight system for repair station and air carrier outsourcing surveillance Status: Guidance completed.

11. 11 Federal Aviation Administration Oversight of Contract Maintenance June 5, 2008 FAA Action Continued Quarterly Utilization Report –Reports that identify maintenance providers that air carriers and repair stations use for the majority of their critical repairs. –Status: Completed (implemented as a voluntary reporting program). FAA Team Inspections –Annual in-depth repair station inspections conducted by FAA repair station inspectors and air carrier inspectors. –Status: Completed and ongoing

12. 12 Federal Aviation Administration Oversight of Contract Maintenance June 5, 2008 FAA Action Continued Rulemaking on Air Carrier Manuals for Outsourcing –This rule would require specific language in air carriers’ manuals pertaining to outsourced maintenance, such as policies, procedures, and instructions for maintenance completed by external repair facilities FAA Notice 8000.362 Air Carrier Maintenance Provider Oversight Responsibilities (Certificated Repair Stations/Non-certificated Facilities) –New guidance for inspectors Currently being incorporated into 8300.9

13. 13 Federal Aviation Administration Oversight of Contract Maintenance June 5, 2008 FAA Action Continued Proposed Rulemaking on Repair Stations –This rule would revise the repair station ratings and require repair stations to establish a quality program. It also specifies instances in which FAA can deny a repair station certificate (e.g., when a company has had one revoked) FAA disposing of comments

14. 14 Federal Aviation Administration Oversight of Contract Maintenance June 5, 2008 FAA Action Continued Inspector Outsource Maintenance Training –Mandatory training for all inspectors Course prototype completed

15. 15 Federal Aviation Administration Oversight of Contract Maintenance June 5, 2008 Conclusion Responsibilities for all scenarios: –Remain with the certificate holder –Are mandated by the Federal Aviation Regulations –Have checks and balances built in –Are under continuous oversight by the FAA FAA and Industry – Working to improve oversight systems to effectively identify and mitigate risks to the appropriate levels.