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IATA 8th Maintenance
Cost Conference
18th October 2012 Atlanta, GA
CAN SASMAZ
Executive Vice President OPERATIONS
Harmonization of the Regulatory
Environment & Its Impact on Safety
and Maintenance Costs
Page 2
CIVIL AVIATION REGULATORY ENVIRONMENT
HARMONIZATION EFFORTS
REGULATION EFFECTS on FOREIGN MROs
COST EFFECTS on FOREIGN MROs
PRESSURES on MRO COMPANIES
AGENDA
IATA 8th MAINTENANCE COST CONFERENCE, Atlanta, GA
Page 3
CIVIL AVIATION REGULATORY ENVIRONMENT
IATA 8th MAINTENANCE COST CONFERENCE, Atlanta, GA
Foreign
MRO
Other
CAAs
EASA and FAA, two of the largest civil aviation authorities in the world
Differences between regulations of these two authorities
Progress is underway to reduce differences in the two regulations
Local
CAA
EASA
Page 4
HARMONIZATION EFFORTS
IATA 8th MAINTENANCE COST CONFERENCE, Atlanta, GA
Source: IATA, EASA Web Sites
Bilateral Agreement between EASA and FAA, Maintenance Annex Guidance, 22 November 2011
An EU company having an EASA Part 145 certificate needs no additional certification to gain an FAA certificate.
IATA Press Release, 24 April 2012
Harmonization and Global Standards Key to a Safer Aviation Industry
IATA Operations Committee (OPC) listed Harmonization among four main topics
The OPC urged governments to focus on the implementation of targeted safety measures instead of adding costly and cumbersome regulations that do little to improve safety. IATA will submit three priority areas for industry to work with ICAO, FAA and EASA with a goal of harmonization
Page 5
REGULATION EFFECTS on FOREIGN MROs
IATA 8th MAINTENANCE COST CONFERENCE, Atlanta, GA
Different Approvals for Different Authorities
Customers want approval of their countrys civil aviation authority.
Lease return conditions FAA or EASA release
The countrys approval includes EASA Part 145 requirements and also additional requirements changing by country to country
Time, effort,cost for getting approvals and renewal of these approvals
A non EU member country
Different application procedures to have a certificate
Separate documentary preparations, increases time, effort and cost
EU member country can apply to its NCAA
EASA Release Issue for non-EU registered aircraft
Page 6
COST EFFECTS on FOREIGN MROs
IATA 8th MAINTENANCE COST CONFERENCE, Atlanta, GA
Different Documentation for Different Authorities
EASA MOE for EASA, RSM for FAA and NCAA MOE and authority supplements for local civil aviation authority
Different PM (Procedures Manual) version needs for different MOEs listed above.
Establishing Different Quality System for Each Regulation
Establish and implement different quality systems
Quality system should demonstrate full compliance with regulation
Archiving, creating different forms, revisions of these forms
Documentation Follow Up Team!
Page 7
COST EFFECTS on FOREIGN MROs
IATA 8th MAINTENANCE COST CONFERENCE, Atlanta, GA
Different Audits & Different Requirements From Authorities
Different correspondences.
Non standardization of the auditors
Different works for the same subject for each authority
Duplication of works
Timely corrective actions shall be taken within requested time frame
Shortage of qualified auditors from regulatory authorities increase waiting time
PMA/DER confusion between regulatory authorities
DOCUMENTATION-MANIA
Page 8
COST EFFECTS on FOREIGN MROs
IATA 8th MAINTENANCE COST CONFERENCE, Atlanta, GA
Training Needs Increasing
Company Procedures Training
Confusion among employees, increasing rework
Mandatory Trainings are increasing
EWIS
Fuel Tank Safety
Human Factors, etc.
Training increase causes decrease in billable work hours
Page 9
COST EFFECTS on FOREIGN MROs
IATA 8th MAINTENANCE COST CONFERENCE, Atlanta, GA
Source: Boeing, 2011
Shortage of Technical Staff
Page 10
COST EFFECTS on FOREIGN MROs
IATA 8th MAINTENANCE COST CONFERENCE, Atlanta, GA
Shortage of Technical Staff
Page 11
COST EFFECTS on FOREIGN MROs
IATA 8th MAINTENANCE COST CONFERENCE, Atlanta, GA
Shortage of Technical Staff
Page 12
COST EFFECTS on FOREIGN MROs
IATA 8th MAINTENANCE COST CONFERENCE, Atlanta, GA
Different Requirements for Technical Staff from Different Authorities
TARGET
AIRWORTHY + SAFETY
or
LEGALITY
BOTH
Page 13
OEM Documents, Training and Specialized Services started to be a problem for MROs
Rolls-Royce: Total Care, GE: On Point Solutions , IAE: FHA (Flight Hour Agreement), Gulfstream: Corporate Care
Salaries are increasing
Competition is increasing
Material cost is increasing
Maintenance periods are extending
A320 C Check from 15 to 24 months
B737NG C Check from 6.000 to 7.500 FHs
A340 C Check from 15 to 24 months
B777 C check from 2 to 3 years
Training, duplication of work is increasing
PRESSURES ON MRO COMPANIES
IATA 8th MAINTENANCE COST CONFERENCE, Atlanta, GA
Page 14
Billable man hours are decreasing
PRESSURES ON MRO COMPANIES
IATA 8th MAINTENANCE COST CONFERENCE, Atlanta, GA
Weekly Work Hours 45
Annual Work Hours 2,340 Official Holiday 7 days Sick Leave 7 days
Vacation 4 weeks OJT + Practical Training 2 to 16 weeks
Type Training 6 weeks Human Factors (Initial) 2 days Fuel Tank Safety (Initial) 1 day
Company Procedures (Initial) 1 day
EWIS B2 (Initial ) 1 week Aviation Regulation (Initial) 3 days EH&S (Initial) 1 day
Easa Part145 (Initial) 1 day FAR 145 (Initial) 1 day
Continous Training online continously
Remaining Work Hours
900 to 1,530 hours
38% to 65%
Page 15
but maintenance price is decreasing ?
PRESSURES ON MRO COMPANIES
IATA 8th MAINTENANCE COST CONFERENCE, Atlanta, GA
LOW COST MAINTENANCE? A DREAM..
Page 16 IATA 8th MAINTENANCE COST CONFERENCE, Atlanta, GA