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Aircraft MaintenanceMaintenance Division
Regulations &Regulations & Policy Updates
Presented to: NACA
Date: July 2012
Presented by: Steve Douglas, ManagerAircraft Maintenance Division
1Federal AviationAdministrationFederal AviationAdministration
AFS-300 Updates for Regulations & Policies
AFS-300Steve Douglas
Manager Senior AdvisorCSTA g Senior AdvisorTony Janco
Special AssistantSalli Rowe
Human FactorsSenior Technical Special
AFS-301A
Ken Kerzner
Dr Bill JohnsonSTS
Rusty Jones
AFS-301B
Dan Bachelder
Ken KerznerAssistant Manager
AFS 350AFS 320AFS 310 S 360
Dan BachelderDeputy Assistant Manager
AFS-350Marty Bailey
ManagerGeneral Aviation
AFS-320Carol Martineau
ManagerSpecial Programs
AFS-310Gianna Sands
ManagerProgram Mgmt
AFS-360Tim Shaver
ManagerAvionics
AFS-330Patty Williams
ManagerAir Carrier
AFS-340Elbert Bush
ManagerRepair Station
Total 65
2Federal AviationAdministrationFederal AviationAdministration
AFS-300 Updates for Regulations & Policies
Overview
• Division Updates• Regulations in work
– NPRM Part 145NPRM Part 145• Policy/Guidance Updates
– MEL Component Swapping– MEL Component Swapping– Training Maint OpSpecs
• What’s New• What s New
3Federal AviationAdministrationFederal AviationAdministration
AFS-300 Updates for Regulations & Policies
Regulations In WorkAir Carrier Contract Maintenance Requirements
• Amend Title 14 CFR Part 121, (new section) to require air carriers to include provisions in q ptheir manuals regarding the performance of contract maintenance work.
M l P d– Manual Procedures– Oversight thru CAS– Listing of contract providersListing of contract providers
Status: Pending NPRM
4Federal AviationAdministrationFederal AviationAdministration
AFS-300 Updates for Regulations & Policies
Regulations In Work
Air Carrier Maintenance Training Program
• Mandate FAA Approval of all 14 CFR Part 121 and Part 135 - 10 or more air carrier maintenance-t i itraining programs
• This would amend§121.375 and§135.433, ti FAA T i i P hi h ldcreating new FAA Training Program which would
include a Human Factors requirement
Status: Pending NPRM
5Federal AviationAdministrationFederal AviationAdministration
AFS-300 Updates for Regulations & Policies
Regulations In Work
Part 145 Repair Stations
A New system of ratings
Revised certification requirements
Revised rules for repair stations Revised rules for repair stations performing maintenance for air carriers
Status: NPRM Out for Comment
6Federal AviationAdministrationFederal AviationAdministration
AFS-300 Updates for Regulations & Policies
Rating System ChangeRegulations In Work
Rating System ChangeCURRENT PROPOSED
Airframe Class Airframe Category• Composite Small• Composite Large• All-Metal Small• All Metal Large
g y• FAR Part 23, 27• FAR Part 25, 29• All others
• All-Metal Large
Powerplant Class • Recip 400 HP or less
R i th 400 HP
Powerplant Category• Recip
T bi• Recip more than 400 HP• Turbine engines
• Turbine• APU• All others
Propeller Class Propeller CategoryPropeller Class• All Fixed and Ground Adjustable• All other propellers
Propeller Category• Fixed Pitch and Ground Adjustable• Variable Pitch• All others
7Federal AviationAdministrationFederal AviationAdministration
AFS-300 Updates for Regulations & Policies
Regulations In Work
CURRENT PROPOSED
Rating System Change
RadioComponent
InstrumentComponent
Accessory Classes Component
Limited Rating Specialized Service Specialized Services
Li it d R ti (145 61(b) li t 12Limited Ratings (145.61(b) lists 12 possible limited ratings) Eliminated
8Federal AviationAdministrationFederal AviationAdministration
AFS-300 Updates for Regulations & Policies
Regulations In WorkCertification Requirements NEW
§ 145.1012 Repair Station Records: Falsification, reproduction, or alteration Fraudulent entry on application for repair station certificate will be basis for suspending or revokingcertificate will be basis for suspending or revoking any certificate issued by the FAA.
§ 145.1051 Application for certificateCertificate may be denied if a previous repair station certificate was revoked or fills a management positioncertificate was revoked or fills a management position with a person who was in a similar position with a repair station whose certificate was revoked
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AFS-300 Updates for Regulations & Policies
Work Preformed for Air CarriersRegulations In Work
Work Preformed for Air CarriersCURRENT PROPOSED
When performing maintenance for When performing maintenance for an p g121 air carriers or 135 air operators, the repair station must follow the carrier’s or operator’s program and applicable sections
p gair carrier or commercial operator, the repair station must comply with instructions provided by the carrierprogram and applicable sections
of its maintenance manual.carrier.
When performing maintenance for When performing inspections for anWhen performing maintenance for 129 foreign operators or inspections for 125 operators the repair station must follow the
d i t
When performing inspections for an operator with an approved inspection program, the repair station must comply with the
dapproved maintenance program for the 129 operator or approved inspection program for the 125 operator.
approved program.
10Federal AviationAdministrationFederal AviationAdministration
AFS-300 Updates for Regulations & Policies
operator.
Work Preformed for Air CarriersRegulations In Work
CURRENT PROPOSEDNotwithstanding the housing Revised to a rating limitation
Work Preformed for Air Carriers
g grequirement, FAA may grant approval for line maintenance authorization
g
Line maintenance means(1) Any unscheduled maintenance resulting from unforeseen events; or(2) S h d l d h k th t t i
Line Maintenance - Maintenance performed for an air carrier certificated under part 121 or part 135, or a foreign air carrier or foreign person operating a(2) Scheduled checks that contain
servicing and/or inspections that do not require specialized training, equipment, or facilities.
air carrier or foreign person operating a U.S.-registered aircraft in common carriage under part 129, which is generally performed at the ramp, parking
t d t i ll ill tq p ,
area, or gate, and typically will not exceed 72 continuous hours per aircraft.
11Federal AviationAdministrationFederal AviationAdministration
AFS-300 Updates for Regulations & Policies
Regulations In Work
Transition NEW Rule• Will include both rules for 24 months• Current repair stations may comply with
old rule for 24 months• New applicants and repair stations
requesting a change must comply with new rule
• After 24 months the original rule will expire and be removed
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AFS-300 Updates for Regulations & Policies
Repair Station Security Rule
US President signs Vision 100 (Century
f A i ti )
ATA Survey 1/3 of heavy
airframe h k t
Public Comment
Period E d
TSA rule time limit expires
– no new FAA FRS
TSA familiarization
visits (>75 FRS) & D t
Draft NPRM published
Legislation post 9-11
Commission
TSA Security Rule TimelineProjected Release Dates ????
12/2003 2005 8/2007
of Aviation) checks at non US RS
EndsFAA FRS certificates
FRS) & Data collection
8/3/2008 2006-09 12/2009 2/2010
????
?12/2003 2005 8/2007 8/3/2008 2006-09 12/2009 2/2010
Requires TSA “to issue final
regulations” to ensure the security
of foreign and domestic aircraft
TSA has 1 yr to issue security regulations or no new FAA FRS
Mandates TSA audits cpt. w/in 6 mos of
New TSA Administrator appointed in
August
TSA coordinated
with Department of Homeland
Security
TSA, Office of Global Strategies,
benchmarked 7 GE FAA certificated
Repair Stations in UK in 2009
New RuleReleased Projected
END of 2012
General Categories:
domestic aircraft repair stations?
psecurity rule UK in 2009
• Security Program• Employee Background Checks
• Security Coordinator
• Security Awareness Training
• Access Control
• Contingency Planning
13Federal AviationAdministrationFederal AviationAdministration
AFS-300 Updates for Regulations & Policies
Security Awareness Training Contingency Planning
Policy/Guidance Updates
14Federal AviationAdministrationFederal AviationAdministration
AFS-300 Updates for Regulations & Policies
Policy/Guidance Updates
• Information for Operators (InFO) issued 2/15/2012 regarding 121.703 “Service Difficulty Reports – explained the agency’s position regarding aircraft
undergoing scheduled maintenance, preventive g g , pmaintenance and alterations that have been out of service for more than 72 hours
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AFS-300 Updates for Regulations & Policies
Policy/Guidance Updates
• InFO #12005 Cont’d
• When an aircraft is out-of-service for more than 72 hours due to scheduled maintenance, preventive maintenance or alteration activity then the reporting requirement will be within 96 hours after the work on the aircraft is approvedhours after the work on the aircraft is approved for return to service
16Federal AviationAdministrationFederal AviationAdministration
AFS-300 Updates for Regulations & Policies
Policy/Guidance Updates
NOTICE 8900.191 issued June 14, 2012
•Purpose is to clarify the terminology used in 14 CFR 121.701(a) “critical to the safety of flight”
•The intent of this verbiage is to require reported failures entered in the airplane log, as required by section 121.563, be corrected prior to operation
17Federal AviationAdministrationFederal AviationAdministration
AFS-300 Updates for Regulations & Policies
, p p
Policy/Guidance Updates
N 8900.191 Cont’d
Section 121 701 establishes the onboard• Section 121.701 establishes the onboard maintenance log as part of the required records for the aircraft• The regulation specifically addresses only those discrepancies that are “critical to the safety of flight”that were reported and originally entered in thethat were reported and originally entered in the airplane log. This regulation is a performance-based regulation that affords the certificate holder a
f fl ibilit t d l it ifimeasure of flexibility to develop its own specific procedures to comply with section 121.701 & 121.369 (c)
18Federal AviationAdministrationFederal AviationAdministration
AFS-300 Updates for Regulations & Policies
( )
Policy/Guidance UpdatesDRAFT
DRAFT
Swapping Compatible Component to Apply MEL Relief
DRAFT
“DRAFT ONLY”DRAFT ONLY•Notice on MEL “swapping compatible component positions to apply MEL list relief”
19Federal AviationAdministrationFederal AviationAdministration
AFS-300 Updates for Regulations & Policies
Policy/Guidance Updatesgr
ams
on P
rog
ty A
ctio
on S
afet
Avia
tio
20Federal AviationAdministrationFederal AviationAdministration
AFS-300 Updates for Regulations & Policies
Policy/Guidance Updates
Participating Parties
Aviation Safety Action Programs
Active MOU'sOthers, 7 Flt. Attendants,
22
Pilots, 85
, ,
Dispatchers, 56
Mechanics, 67
237 Active Programs
21Federal AviationAdministrationFederal AviationAdministration
AFS-300 Updates for Regulations & Policies
Policy/Guidance Updates
Does ASAP Work?• Programs:• Programs:
– 237 MOU’s have been establishedApproximately 90% of reports have been– Approximately 90% of reports have been sole-source
• The program has enabled participants to• The program has enabled participants to identify risks and implement corrective action for both individual and systemicaction for both individual and systemic issues.
22Federal AviationAdministrationFederal AviationAdministration
AFS-300 Updates for Regulations & Policies
Policy/Guidance Updates
What are the top five reported categories/events in maintenance?
Pilot1.Altitude deviation
Disp1.Company
d
MX1.Company
d
Inflight/Onboard1.Exit Row
2.Course deviation3.Company procedure deviations
procedure deviation2.Dispatch operations
procedure deviations 2.Manuals/logbookpaperwork
2.Jump seat3.Manuals 4.Safety Procedures and
4.Maintenance operations5.Manuals/logbookpaperwork
3.Load planning/ MX operations4.Manuals/logbookpaperwork
paperwork3.Maintenance operations4.FAR deviations
Procedures and Policies5.Slides
paperwork paperwork5.Weather 5.Ramp Safety
23Federal AviationAdministrationFederal AviationAdministration
AFS-300 Updates for Regulations & Policies
Policy/Guidance Updates
Aviation Safety Action Programs
• Maintenance participation is lagging– Need to promote more maintenance ASAP reportingNeed to promote more maintenance ASAP reporting– Develop an outreach program for ASAP– FAA Relationshipsp– What are the barriers if any limiting participation
24Federal AviationAdministrationFederal AviationAdministration
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NextGen Challengesg
25Federal AviationAdministrationFederal AviationAdministration
AFS-300 Updates for Regulations & Policies
Policy/Guidance Updatesnt
s Directive Type Number of Active Projects
Number Published CY 2012
As of 6/28/12
Number Published CY 2011
cum
en
As of 6/28/12
8900.1 85 29 64
AC 22 3 7
ed D
oc
AC 22 3 7
Notice 4 4 4
Other Orders 5 1 5
ublis
he InFO 4 2 2
SAFO 4 1 4
Pu JTA 2 20 5
TOTAL 126 60 91
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AFS-300 Updates for Regulations & Policies
Sec 308 (a-c), Inspection of Repair Stations located outside the United States��Lead: AFS-900 (AFS-300 coordinating)Deliverables:
) Withi 1 E t bli h d i l t f ta) Within 1 year - Establish and implement a safety assessment system (SAS) for part 145 repair stations
b) N if C f i i l h 30b) Notify to Congress of negotiations not later than 30 days after initiating formal negotiations with foreign aviation authorities …….. on a new maintenance safety or maintenance implementation agreement.
c) Publish an annual report on the Administrators oversight of part 145 repair stations and implementation of the SAS
28Federal AviationAdministrationFederal AviationAdministration
AFS-300 Updates for Regulations & Policies
Sec 308 (d), Alcohol and Controlled Substance Testing Program Requirementsg g q
Lead: AAM-800 (AFS-300 coordinating)( g)
Deliverable:d) Within 1 year - Promulgate a proposed ruled) Within 1 year Promulgate a proposed rule
requiring that all part 145 repair station employees responsible for safety sensitive maintenance functions on part 121 air carrier aircraft are subjectfunctions on part 121 air carrier aircraft are subject to an alcohol and controlled substances testing program determined acceptable by the Administrator and consistent with the laws of the country in which the repair station is located.
29Federal AviationAdministrationFederal AviationAdministration
AFS-300 Updates for Regulations & Policies
Sec 319, Air Carrier Maintenance Providers
Lead: AFS-300
Deliverable:a) Issue regulations (not later than 3 years after the
date of enactment of the Act) on Air Carrier Contract Maintenance Requirements.q
30Federal AviationAdministrationFederal AviationAdministration
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Sec 344, Improved Voluntary Disclosure Reporting SystemLead: AFS-200 (AFS-300 coordinating)
Deliverables:Deliverables:b) Modify the Voluntary disclosure Reporting Program to
require inspectors to:1) Verify that air carriers are implementing comprehensive1) Verify that air carriers are implementing comprehensive
solutions to correct the underlying causes of the violations voluntarily disclosed
2) Confirm, before approving a final report of a violation, that i l i i h h h ba violation with the same root causes has not been
previously discovered by an inspector or self-disclosed by the air carrier.
c) Establish a process by which voluntary self disclosures arec) Establish a process by which voluntary self-disclosures are reviewed and approved by a supervisor after the initial review by an inspector.
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Sec 410, Use of Cell Phones on Passenger Aircraft
Lead: AIR-100 (AFS-300 coordinating)
Deliverables:
a) Within 120 days - Conduct a study on the use of cella) Within 120 days Conduct a study on the use of cell phones by foreign operators in foreign airspace.
b) Within 180 days - Publish in the Federal Register the ) y gresult of the study and allow 60 days for public comment.
c) Within 270 days - Submit the results of the study to Congress.
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AFS-300 Updates for Regulations & Policies
Sec 805, Limiting Access to Flight Desks of all Cargo Aircraft
Lead: AFS-300Deliverables:
a) Within 180 days - In consultation with appropriate air carriers aircraft manufacturers and air carrier laborcarriers, aircraft manufacturers, and air carrier labor representatives, shall conduct a study to assess the feasibility of developing a physical means, or a combination of physical and procedural means, to prohibit individuals p y p , pother than authorized flight crewmembers from accessing the flight deck of an all-cargo aircraft.
b) Within 1 year - Submit a report to Congress on the ) y p gresults of the study.
33Federal AviationAdministrationFederal AviationAdministration
AFS-300 Updates for Regulations & Policies
Look Ahead• Audits – Repair
Stations/Airlines/Maintenance Repair & pOverhaul (MRO)
• Aviation Education and Outreach– Part 147 Aviation Rulemaking Advisory Committee
RecommendationsRecommendations
• Promotion of Maintenance VoluntaryPromotion of Maintenance Voluntary Disclosure Reporting Program
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AFS-300 Updates for Regulations & Policies
Steve DouglasSteve DouglasManager, AFS-300Aircraft Maintenance Division950 L’Enfant Plaza, S.W. 5th Fl.Washington D C 20024Washington, D.C. 20024
Phone: 202.385.6392
E mail: steven w douglas@faa gov
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AFS-300 Updates for Regulations & Policies
E-mail: [email protected]