International Acceptance of Repair Data Approval:

1
International Acceptance of Repair Data Approval

• Industry Proposal
• Web Heath
• Boeing

2
International Acceptance of Repair Data Approval

• Agenda
• Background
• Responsibilities
• Issues
• Proposal

3
International Acceptance of Repair Data Approval

• Background
• Repairs to aircraft are inevitable even the
  Wright
• Brothers had to make repairs.
• We have been dealing with repairs for almost 100
  years.
• We are global, mature, simple things are not
  always simple anymore.
• Technically and physically it has been
  successful
• Regulatory wise - its been unsuccessful
• inefficient
• bureaucratic

4
International Acceptance of Repair Data Approval

• Responsibilities
• Airlines
• Maintain airworthy aircraft that conform to type
  design
  
• Develop a process for determining major/minor
  repair
• Develop approved and acceptable repair data
• Obtain authority approval major repair data.
• OEM
• Provide Continued Airworthiness support of his
  fleet
• Provides various document i.e. SRM, AMM, IPC etc
• Provides repair data development support.
• Approves data through his Approved Designee
  System
• Authority
• Assure continued airworthiness of operational
  fleet
• Have safety regulations and guidance material,
  policy etc.
• Issue Type, Production and Airline Operating
  Certificates
• Utilize Designee System to make finding s of
  compliance.
• Perform surveillance/ oversight

5
International Acceptance of Repair Data Approval

• Issues
• Over the years many issues associated with
  approval of repair data have
• occurred and it still happening today. Examples
• One Authority was not going to allow its
  designees to work on foreign
• registered aircraft
• Field inspectors second guessing the
  determination of major/minor
• even after approving the process
• Two levels of approval being required, one from
  the state of design and the
• other from state of registry.
• State of registry not accepting the designee
  system of the state of design even
• when they have been accepted via the
  bilateral. .
• Requiring one state of design designee system to
  have regulatory training in
• another states regulations before allowing
  sign off of compliance.

6
International Acceptance of Repair Data Approval

• Issues (continued)
• Repair which meets one authority requirements but
  the accepting authority will not accept the other
  authority approval.
• A major repair is defined and interpreted
  differently between authorities.
• There are different delegation system between
  authorities.

7
International Acceptance of Repair Data Approval

• Impact of Support Effort by the OEM
• Repair Data Request/year 110,000 plus
  
• Percentage US 50
• Percentage non US 50
• Average man-hours spent /request 8 to 10 hrs
• Support Staff range from 7 to 300
• Estimate of major repairs that could be
  classified as minor 85 to 90

8
International Acceptance of Repair Data Approval

• Observation
• This reminds me of the situation that existed in
  the early
• 1990s regarding acceptance and movement of
  replacement
• parts/appliances. This situation resulted in the
  development
• and approval of the FAA 8130-3, JAA Form 1 and
• TCCA 240078..

9
International Acceptance of Repair Data Approval

• Proposal
• Define Major Repair as
• Major Repair
• (1)A repair that if the results on the approved
  type design has an appreciable effect on
  structural performance, weight, balance, system,
  operation characteristics or other
  characteristics affecting the airworthiness of
  the product, part or appliance.
• or
• (2)That cannot be accomplished according to
  accepted practices or be by
• elementary operations.

10
International Acceptance of Repair Data Approval

• Proposal (continued)
• Major Repair Guidance Material
• In line with the definition of major repair, a
  repair that if the result on
• the approved type design has an appreciable
  effect on structural
• performance, weight, balance, system, operational
  characteristics or other
• characteristics affecting the airworthiness of
  the product, part or
• appliance.
• A repair is classified as a major repair if it
  needs extensive static, fatigue
• and damage tolerance strength justification and
  /or testing in its own right
• or if it needs methods, techniques of practices
  that are unusual (i.e.unusual
• material selection, heat treatment, material
  processes etc).
• A Repair that requires a reassessment and
  re-evaluation of the original
• substantiation data to ensure that the aircraft
  still complies with the type
• design .

11
International Acceptance of Repair Data Approval

• Proposal (continued)
• AIA, has agreed to establish an industry project
  to develop a
• complete draft NPRM/NPA (including the preamble,
  rule
• text, cost benefit information etc) starting with
  something like
• what is proposed. We would have other interested
  parties
• participate including the authorities.
• Once this draft rule package was complete we
  would submit
• to the authorities as a petition for rule making.