1. AVS Repair, Alteration and Fabrication Team (RAFT) Results

2. 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 today’s 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. TC/PC holders diversifying into leasing and maintenance
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

5. 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

6. What Will the Team’s 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

7. FAA’s 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
When did
we start?
Study complete
Industry input
Develop policy…
February 07
End 07
1ST Qtr. 08

8. Who is responsible for the airworthiness of the product?
Standard Certificate of Airworthiness (C of A) is issued under 14 CFR
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

9. 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 using approved or accepted data

10. Fabrication of Parts and Sub-parts
Fabrication of parts using FAA approved or accepted data during the conduct of maintenance is permitted by today’s 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 product’s original or properly altered condition
14 CFR (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

11. Repairs Extensive repairs are allowed by current rules and policy:
FAA’s 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

12. Effect on the Product’s 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 and 21.93
Guidance for this is not as explicit as it should be
Currently Designees are not permitted to make that determination ( )

13. Repair or Alteration Process
Proposed Repair
or Alteration
MINOR
MAJOR
Major / Minor
Part 43
Effect on
MINOR
MAJOR
Product Design
Approved Data
21.113
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

14. 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
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.

15. 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

16. 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 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
FAA and EASA have been working on a common understanding of critical parts based upon the output of the TC holders Safety Assessments that are required to be conducted for type certification and validation.
The FAA has not disagreed with the importance of repaired and PMAed parts brought to our attention by the TC/PC holders. While there is a difference of opinion between FAA and some TC/PC holders over the various strict definitions of “critical” as used within some current FAA documents versus Industry definitions, the basic premise of the need to pay attention to adequately designing and showing compliance for any part is not in dispute.
There are a variety of definitions used by FAA in different orders and regulations so when using the term “critical” you need to be clear about the context of its use. We apply the term “critical” to parts, systems and processes; and in a variety of context’s were the consequences of a failure could be hazardous.
For example; In CFR Part 45 for part marking, a “Critical Part” is simply any part subject to an “Airworthiness Limitation.” The part is not “critical” because it has an Airworthiness Limitation, rather because the failure of the part could be hazardous, it is deemed to be critical and therefore the FAA Administrator has placed an AWL on it.
Part criticality is also used for the FAA’s Risk-Based-Resource Targeting Certificate Management process, regulatory (CFR) prioritization, Risk analyses, and to require closer coordination with the FAA Directorates for repair and PMA approvals.
Our PMA Order uses critical as a part that: “may cause a significant degradation of the airworthiness of a product during all phases of operation.”
In the FAA’s Flight Safety Critical Aircraft Parts AC (for military parts); a critical part is one whose failure, malfunction or absence could cause a catastrophic failure resulting in loss or serious damage to the aircraft or an uncommanded engine shutdown resulting in an unsafe condition.
If the FAA is going to use the definition of “critical” to control classification of repairs and alterations or to require different approval procedure for repairs and alterations of such parts, then we need to get clearer agreement on the definition. That includes establishing expectations for how those parts would be identified and managed in service.
AC “Repair and Alteration Data” was initially developed to help transport aircraft operators (CFR 121, 129, 135) develop changes to major repairs such as in the Structural Repair Manuals (SRMs) and other manufacturers service documents. Use of that AC has expanded and it will also need to be reevaluated in light of changes resulting from other RAF Team recommendations.
FAA is developing templates for repair and PMA compliance on engine components. FAA will also look into the need for a similar effort on critical aircraft parts.

17. 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.

18. 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 ICA, and
Clarify how ICA are to be documented and transmitted including those for repair, alteration and PMA.
(Note: AC recommends an ICA assessment for fabrication of parts)

19. 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

20. 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.

21. Thank You !
Questions?