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

2Federal AviationAdministration

Oversight of Contract MaintenanceJune 5, 2008

Overview

• Background outsource maintenance• Air carrier maintenance

– In-House– Uncertificated Facility– Uncertificated Entity– Certified Repair Station– Certified Repair Station Outsources Maintenance

• Conclusion



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.



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



Uncertificated Facility

Airworthiness Release is signed by Air Carrier

Work is performed by Non-Certificated persons


Aircraft or product is inspected by Air Carrier’s inspection department

Uncertificated Facility(Ref. OIG Report AV-2006-031)

Air Carrier Contracts To



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


Aircraft or product is inspected by certificated mechanics in accordance with Air Carrier’s procedures

Uncertificated Entity (Ref. OIG Report AV-2006-031)




What Is Contract Maintenance?

Certificated Repair Station


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



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



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.



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.



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




• 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




• 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




• Inspector Outsource Maintenance Training

– Mandatory training for all inspectors

• Course prototype completed



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.

Oversight of Contract Maintenance

Documents

Transcript of Oversight of Contract Maintenance