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JAA/FAAJAA/FAA
20th Annual JAA/FAA International Conference1
Repair Data Acceptance
Presented by
W. Schulze-Marmeling
JAA/FAAJAA/FAA
20th Annual JAA/FAA International Conference2
1st Meeting
February 10-12, 2003 in Braunschweig
Attendees from
Minutes, mutually agreed, are available
FAA
CJAA
Austrocontrol, DGAC-F, CAA-UK, CAA-NL, LBA
Airbus/AECMA, Boeing, KLM, Lufthansa Technik
JAA/FAAJAA/FAA
20th Annual JAA/FAA International Conference3
Terms of Referenceas of 07.11.2002
Specific tasks and interface issues (Deliverables):
FAA and JAA representatives will meet and examine FAA and JAA/NAA system for classification, approval, and documentation of repairs.
The authorities will identify systems differences and potential methods to mitigate these differences.
JAA/FAAJAA/FAA
20th Annual JAA/FAA International Conference4
Terms of Reference (cont‘d)as of 07.11.2002
The authorities will make a determination whether a system of reciprocal acceptance can be established.
The authorities will draft procedures and internal guidance to streamline reciprocal acceptance of repairs.
These documents will cover the classification, approval, documentation and accomplishment of repairs.
JAA/FAAJAA/FAA
20th Annual JAA/FAA International Conference5
Terms of Reference (cont‘d)as of 07.11.2002
Develop and deliver a training to the appropriate authority and industry personnel affected by the agreement prior to implementation.
Recommend any changes to be considered for future reciprocal agreements between Europe and US. The Subgroup tasked to finalize the Repair Design Approval Sheet will provide the outcome of their work to the Full Group.
JAA/FAAJAA/FAA
20th Annual JAA/FAA International Conference6
1st MeetingChairmen: Mr. Frank Steffens and Mr. Kevin Kendall
Discussion of ToRs
Accomplishment of repairs sufficiently covered by JAR-/FAR-145
Focus on
general comparison of FAA- and JAA-systems of classification approval and documentation of repair
identify and evaluate of system differences
identify potential methods to mitigate system differences as necessary
JAA/FAAJAA/FAA
20th Annual JAA/FAA International Conference7
1st Meeting (cont‘d)
Discussion of ToRs (cont’d)
determine whether a system of reciprocal acceptance of repairs can be established and make corresponding proposals to the CST and the FAA management for endorsement finalize the existing JAA draft repair design approval sheet to enablemutual acceptance
draft the necessary procedures and internal guidance for reciprocal acceptance of repairs
recommend provisions for future bilateral agreements between the US and Europe for the reciprocal acceptance of repairs
Training: cannot be accomplished within the timeframe given
JAA/FAAJAA/FAA
20th Annual JAA/FAA International Conference8
1st Meeting (cont‘d)
Subgroups nominated to deal with specific areas
FAA field approval process vs. JAA repair data approval process FAA DER authorizations vs. ASI authorizations
FAA definition of acceptable data vs. approved data FAA system of classification major/minor repairs (121 operators process vs. other processes)
FAA designee system vs. JAA DOA system Qualification of JAA DOA staff Approval / Oversight of JAA DOAs
Conformity of repair data with importing country’s TC-basis Repair development for products for which the NAA is not the state of design Connection between repair designer and TC / STC-holder
Language of approvals and documentation of repairs Mutually acceptable repair approval sheet
JAA/FAAJAA/FAA
20th Annual JAA/FAA International Conference9
1st Meeting (cont‘d)
Basic guideline
Both the FAA and the NAA BAAs/BASAs and IPAs have previously accepted each other’s system as described in the individual agreements. This has to be respected to the maximum possible extent.
General objectives Seek equivalency / sufficient similarity to enable mutual
acceptance with a minimum of changes (keep in mind what is current practice)
Identify extent or possible limitations of mutual acceptance (safety aspects first, legal aspects not to be forgotten)
Identify best practice (secondary objective) Identify procedures and guidance for mutual acceptance
where necessary (second step)
JAA/FAAJAA/FAA
20th Annual JAA/FAA International Conference10
Amendments to Terms of References
1. Accomplishment of repairs deleted, sufficiently covered by JAR/FAR 145
2. Development of training material, postponed
3. Delivery of the report, extended until end of August 2003
JAA/FAAJAA/FAA
20th Annual JAA/FAA International Conference11
2nd Meeting
April 28-29 in Hoofddorp
Review of specific areas as defined during 1. Meeting
JAA/FAAJAA/FAA
20th Annual JAA/FAA International Conference12
2nd MeetingFAA field approval process vs. JAA repair data approval process (Subgroup 1)
Draft Conclusion:
FAA field approval process provides an equivalent level of airworthinesscompared to JAR-21 subpart M approvalprocess
Action:
Clarification why the field approval process is not always applicable(Part 121 Air Carrier aircraft are not generally eligible)
JAA/FAAJAA/FAA
20th Annual JAA/FAA International Conference13
2nd Meeting
Comparison FAA DER Authorisation vs. ASI Authorisation (Subgroup 1)
Draft Conclusion:
both authorisations provide an acceptable level of confidence
JAA/FAAJAA/FAA
20th Annual JAA/FAA International Conference14
2nd Meeting
FAA definition of acceptable data vs. approved data (Subgroup 2)
Draft Conclusion:
the FAA system provides an equivalent level of airworthiness comparable to what JAR-21subpart M requires
JAA/FAAJAA/FAA
20th Annual JAA/FAA International Conference15
2nd Meeting
FAA system of classification major / minor repairs (Subpart 2)
Draft Conclusion: the classification and processing of data provide an equivalent level of airworthiness compared to what JAR-21 subpart M requires
Action: Delivery of background information, why the classification is granted as a specific privilege to operators and repair stations, and the benefit of this privilege.
JAA/FAAJAA/FAA
20th Annual JAA/FAA International Conference16
2nd Meeting
FAA designee system vs. JAA DOA system (Subgroup 3)
Draft Conclusion: the approval of repair data by the FAA‘s designee and delegated organisation system should be given the same validity as those made directly by the FAA.
Action: future changes of the FAA delegated organisation / designee (ODA) system to be included in the final report.
JAA/FAAJAA/FAA
20th Annual JAA/FAA International Conference17
2nd Meeting
Qualification of JAA DOA staff (Subgroup 3)
Draft Conclusion: A sufficient level of technical competence is provided
JAA/FAAJAA/FAA
20th Annual JAA/FAA International Conference18
2nd Meeting
Approval / Oversight of JAA DOAs(Subgroup 3)
Draft Conclusion: The JAA approval and oversight procedures for DOAs are acceptable to the FAA
JAA/FAAJAA/FAA
20th Annual JAA/FAA International Conference19
2nd Meeting
Conformity of repair data with importing country‘s TC basis(Subgroup 4)
Draft Conclusion: compliance with the TC basis of the State of Design is acceptable, unless repair data are technically incompatible with the configuration of the a/c or product to be repaired
JAA/FAAJAA/FAA
20th Annual JAA/FAA International Conference20
2nd MeetingRepair development for products for which the NAA is not the Authority of the State of Design (Subgroup 4)
Draft Conclusion: both Systems (FAA‘s and JAA‘s) provide a sufficient level of airworthiness irrespective of the State of Design of the product repaired.
JAA/FAAJAA/FAA
20th Annual JAA/FAA International Conference21
2nd Meeting
Cooperation between the repair designer and theTC/STC-holder
Draft Conclusion: FAA system ensures that basicproduct data are available at the repair designer- however, engine critical parts are exempted from
this conclusion due to specific JAR-21 requirements- helicopter critical parts still under discussion
Note: Currently, the FAA is evaluating the subject with regard to engine critical parts; change of the FAA system might take place in future.
JAA/FAAJAA/FAA
20th Annual JAA/FAA International Conference22
2nd Meeting
Language of approvals and documentation of repairs (Subgroup 5)
Draft Conclusion: for mutually acceptable repairs the English language should be required
JAA/FAAJAA/FAA
20th Annual JAA/FAA International Conference23
2nd Meeting
Approval Sheet(Subgroup 5)
Status: most of the changes proposed up to now are editorial. The minimum data to accept a repair (reference to TC, STC, limitations etc.) have to be filled in
Action: AECMA agreement, to be provided