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Communication and the 24/7 Alternative Methods of Compliance Process

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Title: Communication and the 24/7 Alternative Methods of Compliance Process


1
Communication and the 24/7 Alternative Methods
of Compliance Process
Flight Standards Part 121 PIs
AVS/AFS/AIR
June 2010
2
Jim Ballough - Senior Advisor to the Associate
Administrator for Aviation SafetySteve
Douglas - Deputy Division Manager, AFS-301A,
Aircraft Maintenance
DivisionKen Kerzner - Manager, Air Carrier
Branch, AFS-330, Aircraft
Maintenance Division Phil Forde - Manager,
Airframe Branch, ANM-120S,
Seattle Aircraft Certification OfficeScott Fung
- Senior Engineer, Airframe Branch, ANM-120S,
Seattle Aircraft Certification Office

2
3
Introduction
  • Background
  • Communication
  • AEG Roles and Responsibilities
  • Alternate Method Of Compliance (AMOC)
  • 24/7 AMOC Process
  • Risk Management Process (RMP)

4
Purpose
  • This briefing is about early Communications,
    AMOCs, and the implementation of the Transport
    Airplane Directorates 24/7 AMOC process and
    the Flight Standards Principal Inspectors (PIs)
    timeliness in responding to urgent requests for
    Alternative Methods of Compliance, (AMOCs) for
    Airworthiness Directives (ADs) during non-duty
    hours.

5
Background
  • In April 3, 2008, the House Committee on
    Transportation and Infrastructure conducted a
    Hearing regarding safety issues at the FAA.
  • In March 2008, the FAA initiated an AD audit.
  • Indicated a 98 compliance rate.
  • Identified a compliance issue with AD
    (2006-15-15).
  • Resulted in flight cancellations for a large
    portion of MD-80 fleet.
  • The FAA established an AD Compliance Review Team
    (CRT) to review events that caused a disruption
    to some airline schedules.

6
Background
  • Independent Review Team (IRT) established by
    Secretary of DOT.
  • Team consisted of 5 aviation industry safety
    experts
  • Tasked to evaluate and make recommendations to
    improve
  • FAAs implementation of the aviation safety
    system
  • FAAs culture of safety
  • The IRT issued their report on September 2, 2008
  • Identified 13 recommendations related to
  • ADs, Voluntary Disclosure Program, Culture of
    FAA, Safety Management Systems, Air
    Transportation Oversight System and the role of
    FAA Inspectors.

7
Background
  • The AD CRT Reports were formally released in
    September 2009.
  • Task 1 Report AD 2006-15-15 (dated June 3,
    2009)
  • 5 findings and 4 recommendations
  • Task 2 Report AD process (dated July 8, 2009)
  • 12 findings and recommendations
  • The Reports conclude
  • AD processes have worked well.
  • Technical collaboration between the FAA and
    industry enhances ADs and safety.
  • Fundamental changes are not needed, but there are
    opportunities for improvements.

8
Background
  • The AD CRT findings and recommendations focus on
  • Service Instructions
  • Compliance Determinations
  • Lead Airline Process (ATA Specification 111)
  • AD process, compliance planning and
    implementation
  • Mandatory Continuing Airworthiness Information
  • Alternative Methods of Compliance (AMOCs)
  • Crisis communication
  • Part 39 regulations and,
  • Industry training programs.

9
Summary of Recommendations
Background
?------- Double Click to Open Copy
included in handouts
9
10
Background
Aviation Rulemaking Committee
ARC Committee FAA Original Equipment
Manufacturers Air Carriers Relevant Industry
Associations (e.g. AIA, ATA, etc.)
Service Information Working Group
AD Implementation Working Group
FAA Organization/ Procedures Working Group
AD Development Working Group
10
11
Background
  • Our briefing focuses primarily on two of the
    recommendations from the AD CRT findings
  • Strengthen the role of the AEG (Communication)
  • AD CRT, Rec. No 2 8
  • Alternative Methods of Compliance (AMOCs)
  • AD CRT, Rec. No 2 8

12
  • Communications
  • AFS/AIR

13
Communication
  • Finding 2
  • The AEGs were not playing a significant role in
    either the AD review process or the operational
    suitability determinations
  • Recommendation 2
  • Strengthen the role of the AEG in developing and
    implementing ADs
  • Ensure ASIs know the AEG is a resource in the AD
    process
  • AEGs act as the liaison between CMOs/CHDOs for AD
    implementation issues

14
Communication
  • Finding No 8
  • FAA administration of the AMOC process was
    reported to be inconsistent and sound technical
    judgment did not always govern decisions
  • Recommendation 8
  • FAA policymakers must ensure individuals
    responsible for the control of the AMOC processes
    are fully aware of the scope of their
    responsibilities. Educating individuals will
    help ensure proper and prompt technical
    resolution of the problems.
  • Staff availability--24/7 basis--(ACOs, AEGs, and
    CMOs)

15
Communication
  • Who are the Stakeholders?
  • Principal Inspectors (PIs) at the CHDOs
  • Aviation Safety Inspectors (ASIs) at the AEGs
  • Aviation Safety Engineers (ASEs) at the ACOs
  • Managers and Supervisors

16
Communication
  • AFS-1 Memo, dated March 20, 2009
  • The purpose of the memo was to address
    communications among the Aircraft Evaluation
    Groups (AEGs), Flight Standards Service (AFS),
    and the Aircraft Certification Service (AIR)
  • The memo clarified, as a member of AFS, the AEGs
    are responsible for
  • Providing guidance to Flight Standards field
    offices
  • Serving as a collection point for technical
    information, and
  • Acting as a liaison with the Aircraft
    Certification Service.

17
Communication
  • AFS-1 AIR-1 Memo, dated Jan 27,
    2010
  • The purpose of the memo announced the
    implementation of TAD 24/7 process to assist AFS
    PIs responding to urgent requests for alternative
    methods of compliance, (AMOC)
  • When AMOC support is needed to avoid significant
    commercial air transportation disruptions
  • Affects 10 or more aircraft
  • Not for individual or small numbers of aircraft

18
Communication
  • Seattle Aircraft Certification Office Memo dated
    2/5 /2010.
  • Purpose of this Memo was to response to a
    request from Air Transport Association (ATA).
  • The memo Implemented a new procedure to shorten
    response times for an AMOC
  • AMOC can be transmitted via electronic mailbox

18
19
Communication
Organizational Influence
  • Differences of opinion between the ACOs and
    AEGs affect safety.
  • 2 AEGs breakdown of communications with the
    field offices
  • ACOs not effective in ensuring continued
    airworthiness in the areas of ADs CMRs, ICAs and
    field approval

Unsafe Supervision
  • . ACO and AFS personnel are not informed about
    AEGs RRIs.
  • 2. A lack of awareness by ACO and AFS personnel
    of existing policy and requirements for
    implementation.

Preconditions for unsafe actions
  • Communications between AEGs, ACOs and AFS impair
    the effective interfaces required to coordinate
    activities.
  • ACOs and AEGs, have differences in opinion

Unsafe Acts
  • AFS field offices do not understand AD
    requirements.
  • ACO may not review ADs in enough detail to
    address concerns or questions that maintenance
    personnel may have when attempting compliance.

19
20
  • Aircraft Evaluation Group Roles and
    Responsibilities

21
AEG Roles and Responsibilities
21
22
AEG Roles and Responsibilities
Flight Standards Service (AFS)
Aircraft Certification Office (ACOs)
AEGs
AEGs are located with ACOs
AEGs communicate directly with ACOs
AEGs are a Communication Link
Domestic and foreign manufacturers
Regulatory authorities i.e. CAAC, EASA, CTA, JAA
The public i.e. ALPA, ATA, others
Air carriers, Operators
Flight Standards District Offices (FSDOs)
22
23
AEG Roles and Responsibilities
  • AEGs serve as liaison between AFS PIs AIR, ASEs
  • They are subject matter experts in reviewing and
    determining operational suitability for
    operations and airworthiness
  • They provide consultation, coordination, and
    assistance to Aviation Safety Engineers (ASEs) in
    AD development
  • AEGs assist the ACOs and manufacturers in the
    evaluation process so they are aware of any
    operating rules that might impact design
  • Participation in the function, reliability and/or
    service during flight tests, as necessary, to
    evaluate new or modified aircraft types for
    compatibility pertaining to all Federal
    Regulations, e.g., FAR Parts 43, 61, 63, 91, 97,
    121, 125, 129, and 135

23
24
AEG Roles and Responsibilities
  • Provide assistance to Directorates and/or
    Headquarters in the development of draft Advisory
    Circulars, Air Carrier Operation Bulletins,
    Maintenance Bulletins and NTSB Recommendations
  • Provide Technical assistance to Regional Offices,
    FSDOs, CHDOs/CMOs Personnel

24
25
AEG Roles and Responsibilities
  • Coordinate with the National Simulator Evaluation
    Team regarding the evaluation of data packages
    for aircraft simulator design, acceptance, and
    approval
  • Serve as liaison between manufacturers and field
    offices for distribution of service bulletins,
    all operator letters, and maintenance alerts
  • Review and concur with ICAs and intervals
    associated with FAR 23.1529, 25.1529, 27.1529,
    and 29.1529 requirements

25
26
AEG Roles and Responsibilities
  • AEGs have responsibilities to the various
    technical boards based on the aircraft assigned
    to the certification directorate and the amount
    of activity generated by the aircraft
    manufacturers and operators
  • (a) Flight Operations Evaluation Boards (FOEB)
  • (b) Maintenance Review Boards (MRB)
  • (c) Flight Standardization Boards (FSB)
  • (d) Type Certification Boards (TCB) - member
  • (e) Flight Manual Review Boards (FMRB) - member

26
27
AEG Roles and Responsibilities
  • AD Responsibilities
  • Participate in development of ADs related to
    operations and/or maintenance
  • Provide technical consultation to the FAA
    Certificate Holding District Offices (CHDOs)
  • Liaison with the Aircraft Certification Office
  • Act as an intermediary between the Original
    Equipment Manufacturers (OEMs) and CHDOs
    distributing service instructions and other forms
    of alerts, (Example, All Operator Letters and
    Maintenance Alerts)

27
28
AEG Roles and Responsibilities
  • AD Complexity
  • Category 1, ADs would result in outreach
    communications to the Flight Standards Aviation
    Safety Inspectors (ASIs) whose air carrier
    operates the affected aircraft. Describe key
    elements and background information regarding
    the need for the AD. This outreach would be
    conducted by the assigned AEG specialist and
    assisted by the ACO engineer. This would be
    accomplished, (prior to the release of the AD) by
    either telecon or polycom.

28
29
AEG Roles and Responsibilities
  • AD complexity (contd)
  • ADs that have multiple service bulletins,
    options,configurations, and sequencing.
  • Apply ADs that cross product lines.
  • Overlapping ADs are ones that have the potential
    of affecting other ADs in the same area of the
    aircraft.
  • ADs applicable to a single component or system
    that is affected by other previously issued ADs.
  • ADs vulnerable to errors due to maintenance
    and/or operational human factors.
  • Emergency ADs

29
30
AEG Roles and Responsibilities
  • AMOC Responsibilities
  • AEGs assist ASEs in evaluating any unique fleet
    or operational characteristics regarding AMOC
    requests
  • AEGs coordinate with the ASEs by contacting
    and/or resolving issues with the CHDOs

30
31
AEG Contacts
AEG Roles and Responsibilities
  • https//avssharepoint.faa.gov/afs/AEG/default.aspx

AEG Assignments
  • https//avssharepoint.faa.gov/afs/AEG/default.aspx

31
32
  • Roles in the AMOC Process

32
33
AMOC Process
  • Air Carrier (Operators)
  • Principal Inspectors (PIs) at the CHDOs
  • Aviation Safety Inspectors (ASIs) at the AEGs
  • Aviation Safety Engineers (ASEs) at the ACOs
  • Managers and Supervisors

33
34
AMOC Process
  • Operators Role
  •  39.19   May I address the unsafe condition in a
    way other than that set out in the airworthiness
    directive?
  • Yes, anyone may propose to FAA an alternative
    method of compliance or a change in the
    compliance time, if the proposal provides an
    acceptable level of safety. Unless FAA authorizes
    otherwise, send your proposal to your principal
    inspector. Include the specific actions you are
    proposing to address the unsafe condition. The
    principal inspector may add comments and will
    send your request to the manager of the office
    identified in the airworthiness directive
    (manager). You may send a copy to the manager at
    the same time you send it to the principal
    inspector.

34
35
AMOC Process
  • Revision FAA Order IR-M-8040.1C
    (Just published May 17, 2010, cancels
    version B)
  • Removes general discussion related to alternative
    method of compliance.
  • Information on AMOCs will be contained within the
    AMOC Order 8110.103
  • The AD Manual provides policy and guidance for
    the drafting, issuance, and distribution of ADs.
    It is inteded to explain the laws that apply to
    ADs, procedures for writing an AD, and policies
    on key AD-related issues.

35
36
AMOC Process
  • PIs Role (Cont)
  • FAA Order 8110.103, Alternative Methods of
    Compliance
  • Item 6, Who Approves AMOCs?
  • (c) PIs cant approve an AMOC request, (for most
    ADs) however, they may comment on an AMOC
    proposal (such as pointing out the unique
    characteristics of the requesters fleet and
    operations) before forwarding it to the manager
    of the FAA office identified in the AD.

37
AMOC Process
  • AEGs Role
  • Provides a strong communication network among the
    CMOs, and ACOs
  • Subject-Matter-Expert for technical assistance
    when the need for a complex AMOC first arises
  • Liaison communicating with the ACOs and
    Headquarters for complex issues with AMOCs

37
38
AMOC Process
  • Engineers Role
  • Identify whether an AMOC is needed
  • Coordinate with AEGs, if needed (Reference
    AIR-ANM-029-WI) for AEG coordination criteria
  • Identify if the PI supports the request
  • Evaluate the AMOC request to establish whether
    request provides an acceptable level of safety
  • Coordinate the draft response with the PMIs, and
    AEGs if needed
  • Issue an AMOC response

38
39
AMOC Process
  • Engineers Role (contd)
  • FAA Order 8110.103, Alternative Methods of
    Compliance
  • Item 7b, Approving an AMOC
  • (3) The assigned engineer must ensure that the
    proposal provides an acceptable level of safety.
    When reviewing an AMOC proposal, the FAA engineer
    should review the comments received from the
    requesters PI. If there is no comment or
    concurrence from the PI, the engineer should
    contact the PI, FSDO, AEG or other appropriate
    flight standards service personnel for help
    evaluating any unique fleet or operational
    characteristics.

40
AMOC Process
  • Roles of Managers and Supervisors in the AMOC
    24/7 Process
  • Communication
  • Engagement
  • Escalation

41
  • What is the AMOC 24/7 Process?
  • When and How do I Use it?

42
24/7 AMOC Process
  • 24/7 Work Instruction
  • The Work Instruction (WI) provides support from
    the Aircraft Certification Service, (AIR) to the
    Flight Standards Service, (AFS) when there is an
    urgent need for an Alternative Method of
    Compliance (AMOC) that impacts transport category
    airplanes.
  • 1. AMOC support is needed after normal business
    hours and in order to support the Flight
    Standards Principal Inspectors (PIs)
  • 2. AMOC support is needed to avoid significant
    commercial air transportation disruptions (i.e.
    approx. 10 or more aircraft). This is not
    intended to be used for AMOCs applicable to
    individual or small numbers of aircraft.

42
43
24/7 AMOC Process
  • AMOC Process
  • Compliance with regulatory requirements
  • Boilerplate AD AMOC paragraph, and
  • 14 CFR 39.19
  • Standard AMOC process follows Transport Airplane
    Directorate (TAD) Work Instruction, (WI)
    AIR-ANM-029-W1
  • 24/7 AMOC Process follows companion TAD WI
    AIR-ANM-029-W2


43
44
24/7 AMOC Process
  • Boilerplate AD AMOC Paragraph Alternative
    Methods of Compliance (i)(1) The Manager,
    Seattle Aircraft Certification Office (ACO), FAA,
    has the authority to approve AMOCs for this AD,
    if requested using the procedures found in 14 CFR
    39.19. Send information to ATTN Binh V. Tran,
    Aerospace Engineer, Systems and Equipment Branch,
    ANM-130S, FAA, Seattle Aircraft Certification
    Office, 1601 Lind Avenue, SW., Renton, Washington
    98057-3356 telephone (425) 917-6485 fax (425)
    917-6590 e-mail information to 9-ANM-
    Seattle-ACO-AMOC-Requests_at_faa.gov. (2) To
    request a different method of compliance or a
    different compliance time for this AD, follow the
    procedures in 14 CFR 39.19. Before using any
    approved AMOC on any airplane to which the AMOC
    applies, notify your principal maintenance
    inspector (PMI) or principal avionics inspector
    (PAI), as appropriate, or lacking a principal
    inspector, your local Flight Standards District
    Office. The AMOC approval letter must
    specifically reference this AD.

44
45
Standard AMOC process WI
24/7 AMOC Process
  • New

45
46
24/7 AMOC WI
24/7 AMOC Process
  • New

46
47
24/7 AMOC Process
  • Features of the 24/7 Process
  • Sharepoint with contact numbers for AFS use
  • TAD Managers contacted by cell phone
  • Evaluate request to determine
  • Tech staff availability?
  • AMOC decision obvious if tech staff not
    available?
  • Are airplanes in a condition for safe operation
    for some short interval (i.e.10 days) until a
    final resolution can be determined?
  • Coordinate with PIs, and AEGs (as needed)
  • Use FAA letters or email to respond with AMOC

47
48
24/7 AMOC Process
  • When is 24/7 Utilized?
  • As a guideline, the 24/7 process may be
    utilized when there is an urgent need for an AMOC
    which impacts transport airplanes, and
  • AMOC support is needed after normal business
    hours and in order to support Flight Standards
    PIs and
  • AMOC support is needed to avoid significant
    commercial air transportation disruptions (as a
    guideline the AMOC affects approximately 10 or
    more aircraft).
  • The 24/7 program is not intended to be used for
    AMOCs applicable to individual or small numbers
    of aircraft.

48
49
24/7 AMOC Process
  • Appropriate Use of 24/7
  • Operator determination that aircraft are out of
    AD compliance
  • Configuration issues with ADs that have been
    complied with or are terminated
  • Accidental misinterpretation of AD requirements
  • Significant fleet disruption is possible (i.e. 10
    or more airplanes)

49
50
24/7 AMOC Process
  • Undesired Use of 24/7 Process
  • Repair station audit findings
  • If communications among repair stations, Air
    Carrier CMOs, and ACOs occurs early, the 24/7
    process not needed
  • Suspected unapproved parts
  • Follow unapproved parts process
  • Stuff left until Friday at 6 pm, that has been
    known since a week ago last Tuesday
  • Lets not make panics out of situations by
    coordinating early

50
51
24/7 AMOC Process
  • Key Points of 24/7
  • Provides support and outreach to the CMOs
  • Involve the AEGs and ACOs early in the process
  • Establish a strong communication network among
    the CMOs, AEGs, and ACOs
  • Utilize the AEGs as a subject-matter-expert for
    technical assistance when the need for an AMOC
    first arises
  • Use the AEGs as a liaison for communicating with
    the ACOs

51
52
24/7 AMOC Process
  • Statistics for 24/7
  • We have been providing 24/7 support for about two
    years now, although the Work Instruction, (WI)
    was approved only late last year
  • We have used the process about 12 times in the
    past two years.

52
53
24/7 AMOC Process
  • Who do I contact for 24/7 Support
  • Hotline numbers
  • Work Instruction
  • Sharepoint site
  • For more information on the 24/7 process, please
    see the Transport Airplane 24/7 Flight Standards
    AMOC Request Support Work Instruction in the
    Aviation Safety Quality Management System (QPM
    AIR-ANM-029-W2), and
  • For information on how to prepare an AMOC
    request, please see Transport Airplane
    Alternative Method of Compliance (AMOC) Letters
    (AIR-ANM-029-W1 )
  • FAA personnel are encouraged to remind operators
    that AMOC requests must be submitted in
    accordance with 14 CFR 39.19

53
54
24/7 AMOC Process
  • Early Communications
  • Involving the AEGs and the ACOs early in the
    process and building a strong communication
    network mitigates the risk of sending an unclear
    message to the air carriers
  • Bringing the right parties to the table (when the
    possible need for an AMOC first arises) will
    reduce disruptions to the air carriers

54
55
  • Risk Management Process

55
56
Risk Management Process
  • Air Transportation Oversight System
  • Risk Management Process, contained in Flight
    Standards Information Management System (FSIMS),
    Volume 10, Chapter 3  
  • Five Major Steps
  • Identify the hazard
  • Analyze and assess the risk
  • Make a decision
  • Implement the decision and
  • Validate the effectiveness of the decision

57
(No Transcript)
58
FAA Order 8110.107 - Monitor Safety/Analyze Data
Risk Management Process
58
59
Summary
  • Involving all parties early in the process and
    building a strong communication network mitigates
    the risk of sending an unclear message to the air
    carrier
  • Bringing the right parties to the table (when the
    possible need for an AMOC first arises) will
    reduce disruptions to the air carriers

60
Reference Material
  • Reference Documents
  • FAA Order 8900.1 Flight Standards Information
    Management System
  • FAA Order 8110.107 Monitor Safety/Analyze Data
  • FAA Order 8110.103 Alternative Methods of
    Compliance (AMOC)
  • FAA Order 8040.1 Airworthiness Directives
  • FAA Order IR-M 8040.1 Airworthiness Directives
    Manual
  • Title 14 Code of Federal Regulations, part 39
  • AIR QMS Documents
  • https//intranet.faa.gov/faaemployees/org/linebusi
    ness/avs/offices/air/qms/doc/master_index/media/AI
    R-ANM-029-W2.pdf
  • AIR-ANM-029-W2 Transport Airplane 24/7 Flight
    Standards AMOC Request Support Work Instruction

61
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