CertificationMaintenance

1
Certification/Maintenance
2
Major Discussion Points (RAFT)

• AVS Repair, Alteration, and Fabrication Team
  (RAFT)
• Concerns raised by TC/PC holders and component
  OEMs about repairs, alterations, fabrications,
  and replacement part designs
• Not adequately engineered and evaluated for
  compliance
• Being performed on more safety critical parts and
  complex systems increasing the threat to safety,
• Are being misrepresented as TC/PC holder parts,
  and
• Create an un-even commercial playing field
  because FAA does not hold all applicants to the
  same standards
• Chartered an AVS team (AFS/AIR) to review all
  regulations and policy related to repair,
  alteration, and fabrication during maintenance
• Identify any gaps and recommend possible
  solutions
• Training and Policy and Rule changes

3
Reaction from the Floor (RAFT)

• Critical part definition
• Difference between acceptable and approved data
• Additional Instructions for Continued
  Airworthiness (ICA) guidance
• RAFT addressing all these items

4
Major Discussion Points (DAH)

• Design Approval Holder (DAH) Rules
• DAH rules are a new approach for facilitating
  timely implementation of certain complex,
  fleet-wide safety initiatives
• DAH rules rely on a proactive, program management
  approach
• The FAA has issued two final rules containing DAH
  requirements
• Enhanced Airworthiness Program for Airplane
  Systems (EAPAS)
• Aging Aircraft Safety Rule (AASR)
• The FAA expects to issue the Widespread Fatigue
  Damage (WFD)
• The FAA, TCCA, EASA, and ANAC have been in close
  coordination since early 2005
• TCCA, EASA, and ANAC intend to issue similar
  rules

5
Major Discussion Points (DAH)

• Design Approval Holder (DAH) Rules (EASA)
• Long term rules
• Amendment to BR216/2008 Article 5 and task
  21.039.
• Temporary changes for Aging systems
• NPA on EWIS (Electrical Wire Interconnect System)
• AMC20

6
Reaction from the Floor (DAH)

• Positive feedback from Industry relative to
  overall approach and process
• Some concerns early on
• Authorities very responsive
• Good example of Industry/Authority cooperation
• Significant harmonization efforts by authorities

7
Outcomes/Additional Ideas

• The RAFT is preparing a final report that will
  address all existing policy and recommended
  changes and/or clarifications
• Considers Industry feedback
• Report is due to be completed by the end of June
• A notice will be published in the Federal
  Register summarizing RAFT results and
  recommendations
• The FAA process/policy owner offices will
  implement the recommended changes