Repair Station Audit & Other Regulatory Changes


Airline repair station operations, unapproved parts, and the quality of airplane fasteners are all subject to recent changes in Federal regulations or public laws. These changes were implemented to increase aviation safety and will require compliance by all repair stations and airlines.

Several recent changes to Federal regulatory requirements have noticeably increased airline audit activity at repair stations, and will likely result in more of this activity. These changes were prompted by the identification of concerns that appear to be common throughout the airline and repair station industries.

Two of the changes resulted in revisions to the United States Federal Aviation Administration (FAA) oversight procedures. The third change resulted from passage of a public law. These changes, all intended to increase aviation safety, are related to:

1 Airline audit of repair stations.
2 Unapproved parts.
3 The Fastener Quality Act.

1 AIRLINE AUDIT OF REPAIR STATIONS
The first regulatory change involves a revision to the FAA inspection policy intended to strengthen FAA oversight of airlines that rely on contract maintenance and training. The release of this change followed an FAA review of operators' compliance to their internal procedures. The FAA review suggested the need for the FAA to enhance oversight procedures that address operator surveillance of their suppliers.

As a result, FAA Flight Standards Handbook Bulletins For Airworthiness (HBAW) 96-05 (B) (Amended), was released effective August 15, 1996. The bulletin is titled: Airline Operations Specifications Authorizations to Make Arrangements With Other Organiza-tions To Perform Substantial Maintenance. The revisions in the bulletin will eventually be incorporated into FAA Order 8300.10, Airworthiness Inspector's Handbook, which directs the activities and provides guidance for FAA Airworthiness Aviation Safety inspectors. These FAA inspectors have oversight responsibility for airline and repair station operation.

Bulletin 96-05 (B) (Amended) revised the FAA inspection policy by enhancing both the FAA's and the operator's requirements for surveillance of maintenance activity. The FAA's improved inspection policy focused on three areas:

The inspection policy's requirements are outlined below: Airlines must now demonstrate the regulatory compliance of each of the following two major contract programs:Maintenance.Airlines must demonstrate regulatory compliance at each facility performing substantial heavy maintenance or repairs. The FAA defines substantial heavy maintenance as:

The FAA will review the procedures used to perform this work to ensure that they are part of the airline's approved maintenance program. In addition, the FAA will review the airline's oversight of the work conducted by the contractor to ensure that the work conforms with the airline's approved maintenance program, and is carried out in accordance with applicable regulatory requirements.

Training. The FAA will review the contracted training conducted at each training facility employed by the airline. It will also review the contractor's training curriculum to ensure consistency with the airline's approved training program. In addition, the FAA will review "check airmen" involvement (designees who evaluate check flight performance), and the airline's on-site oversight of the contractor's services to ensure that the services provided comply with applicable regulatory requirements.

All contractors performing substantial maintenance and training for an airline now must be listed on the airline's operations specifications. The contractor must be added to the airline's operations specifications before an airline can use a new contractor, and the FAA must approve this addition.

The airline must audit the contractor before the FAA approves the addition of a new contractor to the airline's operations specifications. This audit must demonstrate to the FAA that the contractor is capable of performing the contracted work in accordance with the airline's approved program.

Oversight requirements have been enhanced for FAA inspectors who monitor repair stations and training centers. These new requirements include special attention to airline maintenance activities performed at repair stations. For example:

2 UNAPPROVED PARTS
A second change in FAA regulatory requirements that affects repair stations applies to the detection of suspected unapproved parts (SUP). FAA Order 8120.10A, SUP Program, defines these parts as "parts that have been maintained, rebuilt, altered, overhauled or approved for return to service which are subsequently found not to conform to approved data."

The recent regulatory change resulted from a recommendation of the FAA SUP task force for an FAA review of the receiving and inspection systems at airlines and air agencies. The purpose of the review is to ensure that "appropriate steps have been taken to preclude the introduction of unapproved parts into inventories or their installation on aircraft."

The change became effective October 28, 1996, and is documented in HBAW 96-08, Aviation Safety Inspectors (ASI) Guidance for Detecting Unapproved Parts to Accomplish PTRS (Program Tracking Reporting System) Codes 3622/5622 for Air Carriers and 3668/5668 for Air Agencies. The revisions in the bulletin will eventually be incorporated into FAA Order 8300.10, Airworthiness Inspector's Handbook.

The bulletin addresses FAA evaluation of existing airline and air agency incoming and receiving inspection systems. The evaluation requires examination of a representative sample of the airline's or agency's inventory to validate parts (as applicable) for the following:

The evaluation should also verify that the operator's or agency's system or plan includes a procedure for segregating, evaluating, or removing parts when a part's status is not apparent. Suspected unapproved parts should be reported promptly. (FAA Advisory Circular 21-29B provides information and guidance for both the detection and reporting of SUPs.) The removal of unapproved parts found installed on airplanes may be deferred using the procedures established in the airline's Minimum Equipment List (MEL) authorization, or its approved Configuration Deviation List (CDL) procedures.

In addition to the above requirements, the airline must be able to demonstrate that:

3 FASTENER QUALITY ACT (FQA)
The third recent regulatory change, known as the Fastener Quality Act (FQA), resulted from the passage of Public Law 101-592 (as amended by P. L. 104-113. The FQA becomes effective May 26, 1998. Regulations contained in the FQA were prepared by the U.S. National Institute of Standards and Technology (NIST), and released through the U.S. Department of Commerce in September 1996. The FQA applies to all fasteners -- nuts, bolts, and washers -- with these characteristics:

The FQA contains separate requirements for fasteners sold both before and after the effective date:

The FQA potentially affects repair station operations because repair stations can resell any excess inventory of fasteners they may accumulate. Repair stations must become aware of, and comply with, the FQA requirements if they are to retain this ability.

SUMMARY
Changes in FAA inspection policies for repair station operations and unapproved parts, along with a new law on fastener quality, are increasing the level of activity at airline repair stations. The FAA has already expanded its oversight of airlines that rely on contractors for maintenance, and is verifying airlines' surveillance of their suppliers. Repair stations and airlines should review the changes to FAA guidance materials and the new regulatory requirements, and act accordingly to increase aviation safety and to ensure continued compliance with these regulations.

Rosita Scoones
Manager
Quality Assurance
Boeing Commercial Airplane Group

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