Annual maintenance contract for servicing/repair/maintenance of ...
Oversight of Contract Maintenance
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Transcript of Oversight of Contract Maintenance
Federal AviationAdministration
Oversight of Contract Maintenance
Presented to: U.S./ Europe International Aviation Safety Conference
By: Dan Bachelder, Deputy Assistant Manager, Aircraft Maintenance Division
Date: June 5, 2008
Maintenance Workshop
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Overview
• Background outsource maintenance• Air carrier maintenance
– In-House– Uncertificated Facility– Uncertificated Entity– Certified Repair Station– Certified Repair Station Outsources Maintenance
• Conclusion
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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.
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Air Carrier In-House Maintenance
Airworthiness Release is signed by Air Carrier
Work is performed by Certificated and/or Non-Certificated persons at air carrier facilities
Work is performed in accordance with Air Carrier’s procedures
Aircraft or product is inspected by Air Carrier’s inspection department
Air Carrier Maintenance Facility
Air Carrier Internal Work Request
Personnel “Directly-In-Charge” of a maintenance function must be certificated as a airframe or powerplant mechanic or both A&P
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Uncertificated Facility
Airworthiness Release is signed by Air Carrier
Work is performed by Non-Certificated persons
Work is performed in accordance with Air Carrier’s procedures
Aircraft or product is inspected by Air Carrier’s inspection department
Uncertificated Facility(Ref. OIG Report AV-2006-031)
Air Carrier Contracts To
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Uncertificated Entity
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 Carrier’s procedures
Aircraft or product is inspected by certificated mechanics in accordance with Air Carrier’s procedures
Uncertificated Entity (Ref. OIG Report AV-2006-031)
Air Carrier Contracts To
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What Is Contract Maintenance?
Certificated Repair Station
Air Carrier Contracts To
Repair Station personnel “Directly-In-Charge” of a maintenance function must be certificated as a mechanic or Repairman (N/A foreign)
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
Work is performed by the Repair Station
Work is performed in accordance with the appropriate portions of the Air Carrier’s 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
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Repair Station Contracts to Non-Certificated Entity
Non-Certificated Entity
Repair Station Contracts To
Repair Station personnel “Directly-In-Charge” of a maintenance function must be certificated as a mechanic or Repairman (N/A
foreign)
The non-certificated
facility must be inspected by
the certificated Repair Station
Repair Station must hold specific ratings
issued by FAA
The non-certificated entity must have a quality system equal to the Repair Station’s
Airworthiness Release is
signed under the authority of the Repair
Station
Product is inspected by Repair
Station personnel
FAA is authorized surveillance of the non-certificated entity
Maintenance function approved by FAA
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Certificated Repair Station Responsibilities
• 14 CFR 145.211 Quality Control System
• ( c) (1) (iv), Requires repair stations to audit and qualify each of its non–certificated sub-contractors.
• The repair station verifies, by test and/or inspection that the work has been performed satisfactorily.
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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.
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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
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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
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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
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FAA Action Continued
• Inspector Outsource Maintenance Training
– Mandatory training for all inspectors
• Course prototype completed
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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.