The European Aviation Safety Agency (EASA) released a long-awaited notice of proposed amendment (NPA) that would relieve parts documentation requirements imposed on EASA-certificated, U.S.-based repair stations through the U.S.-EU bilateral agreement’s Maintenance Annex Guidance (MAG).
The MAG essentially requires an EASA Form 1 equivalent (i.e., an FAA Form 8130-3) for new parts, creating what industry deems an impossible situation since production approval holders (PAH) are not required to provide the document under FAA regulations. Previous efforts to persuade the European authority to recognize equivalent evidence of airworthiness fell flat.
Industry is particularly embattled by the regulation’s applicability to commercial parts—which are often produced and sold for nonaviation use in the U.S., and therefore sans the required 8130-3—further exacerbating an already tenuous situation.
In August 2016, the FAA published Notice 8900.380, providing an alternative path to compliance if the required
documentation cannot be obtained from the PAH. The notice confirmed a repair station’s privilege to inspect and approve a new part for return to service when it is not accompanied by Form 8130-3, so long as the repair station establishes traceability. The notice’s one-year expiration date was extended to August 2018 while the authorities endeavor to get the language incorporated into MAG Change 7.
Earlier this month, FAA sent out a Special Airworthiness Information Bulletin (SAIB) clarifying that operators and MRO providers that rely on Alodine,a corrosion-protection and primer for certain metals, can safely use Bonderite for the same applications.
Both Alodine and Bonderite are made by Henkel. In fact, they are one and the same. Bonderite is simply the new brand name for Alodine. Aside from looping in the end-users—Henkel notes that Bonderite as "known as Alodine"—why did FAA take the step of issuing an SAIB? Because it has a number of regulatory-binding documents that call out Alodine specifically.
"The FAA has issued many [airworthiness directives (ADs)] and [alternative means of compliance, or AMOCs] that specifically call out for application of Alodine," the agency notes in the bulletin. "The unavailability of Alodine will make it difficult to comply with ADs or previously approved AMOCs that require the application of Alodine."
Such is the power of FAA's regulations—and the challenge
presented when the agency gets too specific in the rules that govern U.S. aviation.
In an ideal world, FAA's regulations set the basic parameters, and its guidance provides more specific guidelines on how the rules can be followed. When the rules get too specific, industry can be hamstrung, because it's much harder to change a regulation than to issue new guidance.
“The FAA should learn from this,” said Aeronautical Repair Station Association (ARSA) executive director Sarah MacLeod. “When it calls out specific materials in a law, such as an airworthiness directive, a simple marketing change made by a company producing those materials can require bureaucratic backflips. This [new AMOC] is a fine fix, but the government needs to be more circumspect in proscriptive rulemaking.”
The FAA has proposed an AD involving 14,653 U.S. Cessna 172, 182, 206 and 210 models after cracks were found in the lower area of the forward cabin doorpost bulkhead. That's where the wing strut attaches and the AD requires repetitive inspections of the area. After one owner reported finding cracks, more inspections revealed them in about 50 more aircraft. "It has been determined that the cracks result from metal fatigue," the AD says. READ MORE
FAA is establishing a working group to review all repair station guidance and recommend ways to better align it with the agency's rules that govern maintenance organizations.
The effort, set up under FAA's Aviation Rulemaking Advisory Committee (ARAC), gives industry the opportunity to weigh in on the myriad advisory circulars, policy statements, and other guidance that FAA leans on to enforce its Part 145 regulations. The rules apply to the 4,800 FAA-certified repair stations, including 800 located outside the U.S.
SAE International Launches New Maintenance, Repair & Overhaul Information Products, Addressing Rapid Growth of MRO Industry
WARRENDALE, Pa. (PRWEB)January 09, 2018
SAE International has introduced new Maintenance, Repair & Overhaul (MRO) Information Products in response to dramatic changes affecting the MRO landscape, including the recent influx of available aircraft data, new manufacturing methods and business models. Featuring technical insights and detailed guides to repairing advanced materials and detecting predictive data patterns, the MRO Information Products were created in support of independent MRO’s, mainline carriers and OEM’s to help them capitalize on new developments in data management and advanced materials to deliver cost-effective maintenance faster.
“The MRO industry is experiencing a fascinating period of rapid growth across the globe, especially in the Asia-Pacific region,” says Frank Menchaca, Chief Product Officer for SAE International. “In fact, according to Oliver Wyman’s 10-year outlook for the commercial airline transport fleet and the associated MRO market, Asia is forecasted to host almost 40% of the global aircraft fleet by 2027, making it the central location of global fleet activity. SAE International saw a need for dependable resources that can help MRO professionals not only keep up with their competition, but with the speed at which their industry is developing, and that’s exactly what our MRO Information Products aim to provide.”
The MRO Information Products will be available for instant access through SAE MOBILUS, the technical resource platform created by the international automotive and aerospace mobility community to provide a critical advantage to develop the future of aerospace engineering. Along with standards, technical papers, books and case studies, the MRO Information Products will also include complimentary white papers and graphical information pieces.
The MRO Information Products, published by SAE International, can be accessed through an annual standards subscription, an annual non-standards subscription or a custom subscription that can be tailored to meet individual organization needs.
- Available at: http://www.sae.org/mro
- Contact SAE Sales:
1.888.875.3976 (U.S. and Canada) | 1.724.772.4086 (Outside North America)
SAE International is a global association committed to being the ultimate knowledge source for the engineering profession. By uniting over 127,000 engineers and technical experts, we drive knowledge and expertise across a broad spectrum of industries. We act on two priorities: encouraging a lifetime of learning for mobility engineering professionals and setting the standards for industry engineering. We strive for a better world through the work of our charitable arm, the SAE Foundation, which helps fund programs like A World in Motion® and the Collegiate Design Series™.