Continued Airworthiness Initiatives

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Continued Airworthiness Initiatives in the United
States
Presentation to Europe/U.S. International
Aviation Safety
ConferenceName Dave Hempe Ali Bahrami Date
June 9, 2005
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Anticipated Outcome

• Collaboration with aviation authorities,
  manufacturers, and other stakeholders on FAA
  continued airworthiness initiatives
• Streamlined AD process for mandatory continuing
  airworthiness information (MCAI)
• AD-Friendly service bulletins Transport
  Airplane Directorate
• Instructions for Continued Airworthiness (ICA)
• Exchange of information and new ideas for future
  actions to enhance these initiatives

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Streamlined MCAI AD Process

• Goal
• Issuance of FAA MCAI-related ADs in a more
  expeditious manner by simplifying how we assess
  and write them
• Key elements
• Preamble will include no technical discussions,
  only a reference and link to the MCAI through the
  electronic docket management system (i.e., fixed
  boilerplate requiring no creative writing)
• Rule portion of AD will contain text from the
  MCAI, copied into boilerplate headings to conform
  to Federal Register drafting requirements
• FAA will continue to work with the
  State-of-Design to resolve our technical and
  legal differences

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Streamlined MCAI Process (contd)

• Information needed to draft a FAA MCAI-related AD
• MCAI that provide adequate notice for public
  comment
• Correct applicability
• Clear and enforceable compliance times
• Clear explanation of the unsafe condition and
  corrective actions
• Adequate information for economic cost impact
• Cost of replacement parts
• Time associated with performing each corrective
  action
• Service bulletins with accurate and complete
  corrective actions (i.e., AD friendly effort)

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Streamlined MCAI Process (contd)

• Docket Management System
• Contains official DOT dockets for rulemaking
• Allows the public to view dockets and comment on
  rules electronically
• Service bulletins and un-scannable (e.g. too
  large) documents are retained in supplemental
  dockets at Directorate locations
• There have been concerns raised on technology
  transfer issues/export licensing and transport
  security
• Can access DMS website at http//dms.dot.gov

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Streamlined MCAI Process (contd)

• Bottom Line on MCAIs
• FAA still owns Unsafe Condition Decision
• Streamlined effort relies on state of design for
  details of corrective action
• Minimum differences can streamline the time to
  corrective action which has a direct impact on
  safety

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AD-Friendly Service BulletinsTransport
Airplane Directorate

• Goal
• Collaboration between the Transport Airplane
  Directorate and major airframe manufacturers to
  improve the level of safety of transport
  airplanes by analyzing and improving our
  respective products (i.e., ADs and SBs) to
  promote timely, accurate accomplishment and
  verification of safety actions
• Provide clear statement of the unsafe condition
  and effect on products
• Define clear and specific compliance times that
  meet the enforceability requirements for U.S. ADs
• Ensure complete and accurate corrective actions
• Consider customer feedback and needs

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AD-Friendly Service BulletinsTransport
Airplane Directorate

• Service Bulletin Enhancements for more timely
  improvement
• Describe precipitating event, cause, unsafe
  condition and end-level effect on the aircraft
• Use table formats for specifying complex
  compliance times
• Always provide corrective actions
• Compliance times should try to be precise

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AD-Friendly Service BulletinsTransport
Airplane Directorate (cont.)

• Benefits
• Reduced paperwork and resources for airlinesno
  need to correlate between a SB and an AD
• Fewer questions among stakeholders (i.e.,
  airlines, manufacturers, and authorities)
• Easier for operators to demonstrate compliance
• Less time to develop ADs

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AD-Friendly Service BulletinsTransport
Airplane Directorate (cont.)

• Future activities
• Continue collaborating with stakeholders to
  identify and implement concepts - stay on course
• Expand to involve other manufacturers
• Solicit additional operator feedback
• Continue collaborative effort to document
  guidance and processes for reviewing transport
  service bulletin for compatibility with ADs

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Instructions for Continued Airworthiness

• Goal
• Document instructions and requirements for
  maintenance that are essential to the continued
  airworthiness of an aircraft, engine, or
  propeller
• Developed guidance
• Clarification when ICA is required (14 CFR
  21.50 )
• Defined procedures and responsibilities for
  reviewing and accepting ICA
• Guidance for accurate and complete ICA content
• Policy for Component Maintenance Manuals
• Identification of conditions upon which a design
  approval holder must make available the ICA to a
  third party