JAA/FAA 20th Annual JAA/FAA International Conference 1 Repair Data Acceptance Presented by W. Schulze-Marmeling

JAA/FAAJAA/FAA

20th Annual JAA/FAA International Conference1

Repair Data Acceptance

Presented by

W. Schulze-Marmeling

JAA/FAAJAA/FAA


1st Meeting

February 10-12, 2003 in Braunschweig

Attendees from

Minutes, mutually agreed, are available

FAA

CJAA

Austrocontrol, DGAC-F, CAA-UK, CAA-NL, LBA

Airbus/AECMA, Boeing, KLM, Lufthansa Technik

JAA/FAAJAA/FAA


Terms of Referenceas of 07.11.2002

Specific tasks and interface issues (Deliverables):

FAA and JAA representatives will meet and examine FAA and JAA/NAA system for classification, approval, and documentation of repairs.

The authorities will identify systems differences and potential methods to mitigate these differences.

JAA/FAAJAA/FAA


Terms of Reference (cont‘d)as of 07.11.2002

The authorities will make a determination whether a system of reciprocal acceptance can be established.

The authorities will draft procedures and internal guidance to streamline reciprocal acceptance of repairs.

These documents will cover the classification, approval, documentation and accomplishment of repairs.

JAA/FAAJAA/FAA


Terms of Reference (cont‘d)as of 07.11.2002

Develop and deliver a training to the appropriate authority and industry personnel affected by the agreement prior to implementation.

Recommend any changes to be considered for future reciprocal agreements between Europe and US. The Subgroup tasked to finalize the Repair Design Approval Sheet will provide the outcome of their work to the Full Group.

JAA/FAAJAA/FAA


1st MeetingChairmen: Mr. Frank Steffens and Mr. Kevin Kendall

Discussion of ToRs

Accomplishment of repairs sufficiently covered by JAR-/FAR-145

Focus on

general comparison of FAA- and JAA-systems of classification approval and documentation of repair

identify and evaluate of system differences

identify potential methods to mitigate system differences as necessary

JAA/FAAJAA/FAA


1st Meeting (cont‘d)

Discussion of ToRs (cont’d)

determine whether a system of reciprocal acceptance of repairs can be established and make corresponding proposals to the CST and the FAA management for endorsement finalize the existing JAA draft repair design approval sheet to enablemutual acceptance

draft the necessary procedures and internal guidance for reciprocal acceptance of repairs

recommend provisions for future bilateral agreements between the US and Europe for the reciprocal acceptance of repairs

Training: cannot be accomplished within the timeframe given

JAA/FAAJAA/FAA



Subgroups nominated to deal with specific areas

FAA field approval process vs. JAA repair data approval process FAA DER authorizations vs. ASI authorizations

FAA definition of acceptable data vs. approved data FAA system of classification major/minor repairs (121 operators process vs. other processes)

FAA designee system vs. JAA DOA system Qualification of JAA DOA staff Approval / Oversight of JAA DOAs

Conformity of repair data with importing country’s TC-basis Repair development for products for which the NAA is not the state of design Connection between repair designer and TC / STC-holder

Language of approvals and documentation of repairs Mutually acceptable repair approval sheet

JAA/FAAJAA/FAA



Basic guideline

Both the FAA and the NAA BAAs/BASAs and IPAs have previously accepted each other’s system as described in the individual agreements. This has to be respected to the maximum possible extent.

General objectives Seek equivalency / sufficient similarity to enable mutual

acceptance with a minimum of changes (keep in mind what is current practice)

Identify extent or possible limitations of mutual acceptance (safety aspects first, legal aspects not to be forgotten)

Identify best practice (secondary objective) Identify procedures and guidance for mutual acceptance

where necessary (second step)

JAA/FAAJAA/FAA


Amendments to Terms of References

1. Accomplishment of repairs deleted, sufficiently covered by JAR/FAR 145

2. Development of training material, postponed

3. Delivery of the report, extended until end of August 2003

JAA/FAAJAA/FAA


2nd Meeting

April 28-29 in Hoofddorp

Review of specific areas as defined during 1. Meeting

JAA/FAAJAA/FAA


2nd MeetingFAA field approval process vs. JAA repair data approval process (Subgroup 1)

Draft Conclusion:

FAA field approval process provides an equivalent level of airworthinesscompared to JAR-21 subpart M approvalprocess

Action:

Clarification why the field approval process is not always applicable(Part 121 Air Carrier aircraft are not generally eligible)

JAA/FAAJAA/FAA


2nd Meeting

Comparison FAA DER Authorisation vs. ASI Authorisation (Subgroup 1)

Draft Conclusion:

both authorisations provide an acceptable level of confidence

JAA/FAAJAA/FAA


2nd Meeting

FAA definition of acceptable data vs. approved data (Subgroup 2)

Draft Conclusion:

the FAA system provides an equivalent level of airworthiness comparable to what JAR-21subpart M requires

JAA/FAAJAA/FAA


2nd Meeting

FAA system of classification major / minor repairs (Subpart 2)

Draft Conclusion: the classification and processing of data provide an equivalent level of airworthiness compared to what JAR-21 subpart M requires

Action: Delivery of background information, why the classification is granted as a specific privilege to operators and repair stations, and the benefit of this privilege.

JAA/FAAJAA/FAA


2nd Meeting

FAA designee system vs. JAA DOA system (Subgroup 3)

Draft Conclusion: the approval of repair data by the FAA‘s designee and delegated organisation system should be given the same validity as those made directly by the FAA.

Action: future changes of the FAA delegated organisation / designee (ODA) system to be included in the final report.

JAA/FAAJAA/FAA


2nd Meeting

Qualification of JAA DOA staff (Subgroup 3)

Draft Conclusion: A sufficient level of technical competence is provided

JAA/FAAJAA/FAA


2nd Meeting

Approval / Oversight of JAA DOAs(Subgroup 3)

Draft Conclusion: The JAA approval and oversight procedures for DOAs are acceptable to the FAA

JAA/FAAJAA/FAA


2nd Meeting

Conformity of repair data with importing country‘s TC basis(Subgroup 4)

Draft Conclusion: compliance with the TC basis of the State of Design is acceptable, unless repair data are technically incompatible with the configuration of the a/c or product to be repaired

JAA/FAAJAA/FAA


2nd MeetingRepair development for products for which the NAA is not the Authority of the State of Design (Subgroup 4)

Draft Conclusion: both Systems (FAA‘s and JAA‘s) provide a sufficient level of airworthiness irrespective of the State of Design of the product repaired.

JAA/FAAJAA/FAA


2nd Meeting

Cooperation between the repair designer and theTC/STC-holder

Draft Conclusion: FAA system ensures that basicproduct data are available at the repair designer- however, engine critical parts are exempted from

this conclusion due to specific JAR-21 requirements- helicopter critical parts still under discussion

Note: Currently, the FAA is evaluating the subject with regard to engine critical parts; change of the FAA system might take place in future.

JAA/FAAJAA/FAA


2nd Meeting

Language of approvals and documentation of repairs (Subgroup 5)

Draft Conclusion: for mutually acceptable repairs the English language should be required

JAA/FAAJAA/FAA


2nd Meeting

Approval Sheet(Subgroup 5)

Status: most of the changes proposed up to now are editorial. The minimum data to accept a repair (reference to TC, STC, limitations etc.) have to be filled in

Action: AECMA agreement, to be provided

JAA/FAAJAA/FAA


Next steps1. Next meeting in the United States July 14-18

2. Final meeting in the United Kingdom July 28-29

3. Report to be submitted End of August 2003

Documents

JAA/FAA 20th Annual JAA/FAA International Conference 1 Repair Data Acceptance Presented by W. Schulze-Marmeling