Oversight of Contract Maintenance

1
Oversight of Contract Maintenance
Maintenance Workshop

• Presented to U.S./ Europe International
  Aviation Safety Conference
• By Dan Bachelder, Deputy Assistant Manager,
  Aircraft Maintenance Division
• Date June 5, 2008

2
Overview

• Background outsource maintenance
• Air carrier maintenance
• In-House
• Uncertificated Facility
• Uncertificated Entity
• Certified Repair Station
• Certified Repair Station Outsources Maintenance
• Conclusion

3
Background

• DOT Office of Inspector General (OIG) issued two
  reports
• Air Carrier Use of Repair Stations (2003)
• Air Carrier Use of Non-Certificated Facilities
  (2005)
• These reports detailed Air Carriers use of
  outsource maintenance providers. FAA has been
  working to improve our oversight systems based on
  these reports.
• Important for both FAA and Industry to focus
  awareness to those areas of identified risk and
  take appropriate actions.

4
Air Carrier In-House Maintenance
Air Carrier Internal Work Request
Air Carrier Maintenance Facility
Personnel Directly-In-Charge of a maintenance
function must be certificated as a airframe or
powerplant mechanic or both AP
Work is performed by Certificated and/or
Non-Certificated persons at air carrier
facilities
Work is performed in accordance with Air
Carriers procedures
Aircraft or product is inspected by Air Carriers
inspection department
Airworthiness Release is signed by Air Carrier
5
Uncertificated Facility
Air Carrier Contracts To
Uncertificated Facility (Ref. OIG Report
AV-2006-031)
Airworthiness Release is signed by Air Carrier
Work is performed by Non-Certificated persons
Work is performed in accordance with Air
Carriers procedures
Aircraft or product is inspected by Air Carriers
inspection department
6
Uncertificated Entity
Air Carrier Contracts To
Uncertificated Entity (Ref. OIG Report
AV-2006-031)
Airworthiness Release is signed by certificated
mechanic authorized by the air carrier
Work is performed by mechanics certificated under
14 CFR Part 65 trained by Air Carrier
Work is performed in accordance with Air
Carriers procedures
Aircraft or product is inspected by certificated
mechanics in accordance with Air Carriers
procedures
7
What Is Contract Maintenance?
Air Carrier Contracts To
The air carrier, or the person with whom the air
carrier arranges for the performance of the
maintenance, preventive maintenance,
oralterations, prepares or causes to be
prepared--an airworthiness release
Certificated Repair Station
Work is performed by the Repair Station
Work is performed in accordance with the
appropriate portions of the Air Carriers CAMP,
pertinent instructions from its maintenance
manual and instructions for continued
airworthiness
Aircraft or product is inspected by Repair
Station personnel
Repair Station must hold the specific ratings
issued by FAA
Repair Station must have a Quality Control System
acceptable to FAA
Repair Station personnel Directly-In-Charge of
a maintenance function must be certificated as a
mechanic or Repairman (N/A foreign)
8
Repair Station Contracts to Non-Certificated
Entity
Repair Station Contracts To
Non-Certificated Entity
Repair Station must hold specific ratings issued
by FAA
Product is inspected by Repair Station personnel
The non-certificated facility must be inspected
by the certificated Repair Station
The non-certificated entity must have a quality
system equal to the Repair Stations
Airworthiness Release is signed under the
authority of the Repair Station
Maintenance function approved by FAA
FAA is authorized surveillance of the
non-certificated entity
Repair Station personnel Directly-In-Charge of
a maintenance function must be certificated as a
mechanic or Repairman (N/A foreign)
9
Certificated Repair Station Responsibilities

• 14 CFR 145.211 Quality Control System
• ( c) (1) (iv), Requires repair stations to audit
  and qualify each of its noncertificated
  sub-contractors.
• The repair station verifies, by test and/or
  inspection that the work has been performed
  satisfactorily.

10
FAA Action

• The FAA has taken the following action to
  enhance oversight of Outsource Maintenance
  Providers
• Enhanced Repair Station Oversight System
• A risk-based, standardized oversight system for
  repair station and air carrier outsourcing
  surveillance
• Status Guidance completed.

11
FAA Action Continued

• Quarterly Utilization Report
• Reports that identify maintenance providers that
  air carriers and repair stations use for the
  majority of their critical repairs.
• Status Completed (implemented as a voluntary
  reporting program).
• FAA Team Inspections
• Annual in-depth repair station inspections
  conducted by FAA repair station inspectors and
  air carrier inspectors.
• Status Completed and ongoing

12
FAA Action Continued

• Rulemaking on Air Carrier Manuals for Outsourcing
• This rule would require specific language in air
  carriers manuals pertaining to outsourced
  maintenance, such as policies, procedures, and
  instructions for maintenance completed by
  external repair facilities
• FAA Notice 8000.362 Air Carrier Maintenance
  Provider Oversight Responsibilities (Certificated
  Repair Stations/Non-certificated Facilities)
• New guidance for inspectors
• Currently being incorporated into 8300.9

13
FAA Action Continued

• Proposed Rulemaking on Repair Stations
• This rule would revise the repair station ratings
  and require repair stations to establish a
  quality program. It also specifies instances in
  which FAA can deny a repair station certificate
  (e.g., when a company has had one revoked)
• FAA disposing of comments

14
FAA Action Continued

• Inspector Outsource Maintenance Training
• Mandatory training for all inspectors
• Course prototype completed

15
Conclusion

• Responsibilities for all scenarios
• Remain with the certificate holder
• Are mandated by the Federal Aviation Regulations
• Have checks and balances built in
• Are under continuous oversight by the FAA
• FAA and Industry
• Working to improve oversight systems to
  effectively identify and mitigate risks to the
  appropriate levels.