Aircraft Maintenance. Compliance, Quality and SMS. Federal Aviation Administration. By: Tim Shaver, Manager (Acting)

Transcription

1 Aircraft Maintenance Compliance, Quality and SMS By: Tim Shaver, Manager (Acting) Aircraft Maintenance Division, AFS-300 To: Regulatory Panel Date: November 4, 2015

2 The Division Rulemaking Activity Policy & Guidance MRO s Audits 2

3 Aircraft Maintenance Division We develop and establish safety & certification standards and associated guidance material for: General Aviation Maintenance Air Carrier Maintenance Avionics Maintenance Designees Airmen FAAST Airworthiness 3

4 Aircraft Maintenance Division, AFS-300 Organizational Chart Tim Shaver (Acting) Division Manager AFS-300 David Rowland Special Assistant Dr. Bill Johnson CSTA ACO, MIDO, AEG Rusty Jones Sr. Technical Specialist for NDI & Composite Frankie Berry Management Assistant Rolandos Lazaris (Acting) Assistant Manager AFS-301a Tony Janco (Acting) Assistant Deputy Manager AFS-301b Senior Field Technical Liaison and Integration AFS-304 Jim Hein FAAST Team DaVetta Ogunlola Admin Support AFS-301a/b Daniel Bryan Program Mgmt. & Info Branch AFS-310 Dale Hawkins Special Programs Branch AFS-320 John Dugan (Acting) Air Carrier Maint. Branch AFS-330 Patricia Williams Repair Station Branch AFS-340 Kevin Morgan General Aviation Branch AFS-350 Chris Parfitt (Acting) Avionics Branch AFS-360

5 Rulemaking Activity Air Carrier Contract Maintenance Requirements Amend Title 14 CFR Part 121 and 135 (new section), to require air carriers to include provisions in their manuals regarding the performance of contract maintenance work Manual Procedures Listing of contract providers Name & physical address Description of work performed Update list by last day of month Status: Final Rule published March 4,

6 Evolution of Contract Maintenance Early Regulatory maintenance manual Requirement DOT/IG Issued Report (Certificated Part 145 repair stations) Congressional Hearing FAA Published Best FAA Practice Reviewed AC manual procedures NPRM Published /2012 3/04/ SabreTech Value Jet Crash DOT/IG Issued Report (Noncertificated repair facilities) DOT/IG Issued Report (Outsourcing Maintenance) 2012 FAA Modernization Reform Act 6

7 Why the new rule? Evaluation of data over the years for maintenance providers has revealed: Inconsistent compliance with the rules; Failures to specify an adequate description of the type of work; Failures to include the name and address of the maintenance provider; No consistent published format for the list across air carriers, inhibiting FAA analysis. 7

8 Contract Maintenance New Section / Maintenance Provider any person who performs maintenance, preventive maintenance,. Covered work - means any of the following: Essential maintenance, if not performed properly or if improper parts or materials are used, could result in a failure, malfunction, or defect endangering the safe operation of an aircraft; Regularly scheduled maintenance; or A required inspection item on an aircraft. 8

9 Contract Maintenance Directly in charge means having responsibility for covered work performed by a maintenance provider. A representative of the certificate holder directly in charge of covered work does not need to physically observe and direct each maintenance provider constantly, they must be available for consultation on matters requiring instruction or decision. 9

10 Safety Assurance System 100% Field Offices will transition to the SAS tool by December (Phase IIa) 10

11 Safety Assurance System SAS is not a separate safety standard and does not impose additional requirements on the certificate holders SAS is an FAA internal tool used to standardize our work and better identify and track the management of risk. 11

12 Safety Assurance System Noteworthy feature of SAS External Portal- certificate holders and applicants can use the portal to submit or view the following: Configuration Data Changes to the scope of your operation Scoped Data Collection Tools For certification purposes; Pre-Application statement of Intent (PASI) 12

13 Safety Assurance System (h) format acceptable to the FAA. Screen shots of the maintenance category entry for contractors could be imported This acceptable format could be in excel 13

14 Maintenance, Repair and Overhaul (MRO) Audit and Data Sharing Initiative 14

15 Areas for Improvement Standardize audit techniques and systems to review audits performed by regulators and customers. Reduce redundancy of audits not only with MROs and airlines, but with FAA resources. 15

16 Addressing the Issue The Aircraft Maintenance Division is initiating a new auditing concept for MROs: MRO Audit and Data Sharing Initiative Goals of this initiative are: Develop a process that will reduce the number of unnecessary audits. (Includes the multitude of regulator audits as well as those audits performed by certificated entities on each other) Develop a technical Information Sharing of Safety Data process that facilitates access to de-identified safety data of any participating MRO, airline, or regulator. Focused risk-based inspections supported by data, in lieu of random selection. Address Safety Management Systems as related to these audits. 16

17 Where we are going - Philosophy Past: Annual Regional Team Focused Inspections (R items) were mandated in FAA Order N (August 14, 2013) National Flight Standards Work Program Guidelines for air carrier contract maintenance providers. Present: The mandatory requirement for these inspections was removed in revision O of this Order. (December 3, 2014) Future: Regional Team Focused Inspections will be conducted based on risk indicators. Contract Maintenance Providers (CMP) will be audited based on risk with supporting data shared through systems such as SAS and SPAS. 17

18 Where we are going Policy and Tools Update FAA Order Requirements to provide new policy for streamlined MRO audits. Require new/revision to ASI training to ensure that the new processes/methodologies and/or techniques are fully understood. Full understanding of risk-based decision making for part 145 ASI s with oversight responsibility of MROs. 18

19 MRO Audit and Data Sharing Initiative From a global leadership perspective there is a clear need to improve current audit methods. Multiple audits of the same MRO, unless warranted by risk concerns, are neither productive nor do they enhance safety. Anticipated results from this initiative: Reduction in both monetary and human resources thereby returning these resources to support the common goal of standardized compliance and improved safety. Promote interdependence among regulators and industry with FAA maintaining its inherent responsibility to ensure certificate holders adhere to applicable regulations. 19

20 Global Safety Conference Held February 5, 2015 Topic: ICAO, States, and industry initiate discussions on how best to evolve the surveillance of maintenance organizations while still fulfilling national oversight obligations. Recommendations: States evaluate how they may reduce duplicative certification and surveillance of Approved Maintenance Organizations (AMOs) at a national, regional, and international level. States collaborate with ICAO and Industry, to develop an international framework to facilitate reducing such duplication. ICAO charter an expert group to coordinate these discussions and develop recommendations for consideration by the 39 th Assembly. 20

21 Global Improvement Establish common regulatory acceptance of oversight standards between regulators for audits. o (AS 9100 International Aviation Quality Group or other standard) Increase audit efficiency thru standards harmonization. Reduce audit burden without compromising safety, target 15% in the first three years. 21

22 Outcome Streamlined and standardized audits Sharing of data Reduction in the number of audits Reduction in cost Reduction in duplication Enhance Safety 22

23 QUESTIONS? Timothy W. Shaver Division Manager (Acting) Aircraft Maintenance Division FAA/AFS-300 (202)