Communication and the 24 7 Alternative Methods of Compliance

Communication and the 24/7 Alternative Methods of Compliance Process Presented to: Flight Standards Part 121 PI’s By: AVS/AFS/AIR Date: June 2010 Federal Aviation Administration

Jim Ballough - Senior Advisor to the Associate Administrator for Aviation Safety Steve Douglas - Deputy Division Manager, AFS-301 A, Aircraft Maintenance Division Kerzner - Manager, Air Carrier Branch, AFS-330, Aircraft Maintenance Division Phil Forde - Manager, Airframe Branch, ANM-120 S, Seattle Aircraft Certification Office Scott Fung - Senior Engineer, Airframe Branch, ANM-120 S, Seattle Aircraft Certification Office Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 2

Introduction • • • Background Communication AEG Roles and Responsibilities Alternate Method Of Compliance (AMOC) “ 24/7 AMOC Process” Risk Management Process (RMP) Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 3

Purpose This briefing is about early Communications, AMOCs, and the implementation of the Transport Airplane Directorate’s “ 24/7” AMOC process; and the Flight Standards Principal Inspectors (PI’s) timeliness in responding to urgent requests for Alternative Methods of Compliance, (AMOCs) for Airworthiness Directives (ADs) during nonduty hours. Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 4

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. Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 5

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 • FAA’s implementation of the aviation safety system • FAA’s 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. Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 6

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. Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 7

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. Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 8

Background Summary of Recommendations ------- Double Click to Open Copy included in handouts Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 9

Background Aviation Rulemaking Committee ARC Sponsor AVS-1, Peggy Gilligan ARC Committee FAA; Original Equipment Manufacturers; Air Carriers; Relevant Industry Associations (e. g. AIA, ATA, etc. ) Service Information AD Implementation Working Group AD Development Working Group Communications and 24/7 AMOC Process V 7. 0 FAA Organization/ Procedures Working Group Federal Aviation Administration 10

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 Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 11

Communications AFS/AIR Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 12

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 Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 13

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) Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 14

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 Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 15

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. Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 16

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 Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 17

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 can be transmitted via electronic mailbox Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 18

Communication Organizational Influence 1 Differences of opinion between the ACOs and AEGs affect safety. 2 AEGs breakdown of communications with the field offices 3 ACOs not effective in ensuring continued airworthiness in the areas of ADs CMRs, ICAs and field approval Unsafe Supervision 1. ACO and AFS personnel are not informed about AEG’s RR&Is. 2. A lack of awareness by ACO and AFS personnel of existing policy and requirements for implementation. Preconditions for unsafe actions 1 Communications between AEGs, ACOs and AFS impair the effective interfaces required to coordinate activities. 2 ACOs and AEGs, have differences in opinion Unsafe Acts 1. AFS field offices do not understand AD requirements. 2. ACO may not review ADs in enough detail to address concerns or questions that maintenance personnel may have when attempting compliance. 3. Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 19

Aircraft Evaluation Group Roles and Responsibilities Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 20

AEG Roles and Responsibilities Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 21

AEG Roles and Responsibilities Flight Standards Service (AFS) Aircraft Certification Office (ACOs) AEGs are located with ACOs AEGs are a Communication Link Flight Standards District Offices (FSDOs) Air carriers, Operators Communications and 24/7 AMOC Process V 7. 0 Domestic and foreign manufacturers AEGs communicate directly with ACOs Regulatory authorities i. e. CAAC, EASA, CTA, JAA The public i. e. ALPA, ATA, others Federal Aviation Administration 22

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 Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 23

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 Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 24

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 Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 25

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 Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 26

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) Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 27

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. Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 28

AEG Roles and Responsibilities AD complexity • • • (cont’d) 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 vulnerable to errors due to maintenance and/or operational human factors. Emergency ADs Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 29

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 Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 30

AEG Roles and Responsibilities AEG Contacts • https: //avssharepoint. faa. gov/afs/AEG/default. aspx AEG Assignments • https: //avssharepoint. faa. gov/afs/AEG/default. aspx Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 31

Roles in the AMOC Process Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 32

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 Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 33

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. Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 34

AMOC Process Revision: FAA Order IR-M-8040. 1 C (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. Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 35

AMOC Process PIs Role: (Con’t) • FAA Order 8110. 103, Alternative Methods of Compliance • Item 6, Who Approves AMOCs? – (c) PIs can’t approve an AMOC request, (for most ADs); however, they may comment on an AMOC proposal (such as pointing out the unique characteristics of the requester’s fleet and operations) before forwarding it to the manager of the FAA office identified in the AD. Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 36

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 Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 37

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 Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 38

AMOC Process Engineers Role: (cont’d) • FAA Order 8110. 103, Alternative Methods of Compliance • Item 7 b, 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 requester’s 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. Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 39

AMOC Process Roles of Managers and Supervisors in the AMOC & “ 24/7 Process” • Communication • Engagement • Escalation Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 40

What is the AMOC “ 24/7” Process? When and How do I Use it? Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 41

“ 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. Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 42

“ 24/7” 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 W 1 • 24/7 AMOC Process follows companion TAD WI AIR-ANM-029 -W 2 Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 43

“ 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-130 S, 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@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. Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 44

“ 24/7” AMOC Process Standard AMOC process WI Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 45

“ 24/7” AMOC Process 24/7 AMOC WI Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 46

“ 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 Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 47

“ 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. Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 48

“ 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) Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 49

“ 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 – Let’s not make panics out of situations by coordinating early Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 50

“ 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 Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 51

“ 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. Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 52

“ 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 -W 2), and • For information on how to prepare an AMOC request, please see Transport Airplane Alternative Method of Compliance (AMOC) Letters (AIR-ANM-029 -W 1 ) • FAA personnel are encouraged to remind operators that AMOC requests must be submitted in accordance with 14 CFR 39. 19 Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 53

“ 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 Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 54

Risk Management Process Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 55

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 Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 56

Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 57

Risk Management Process FAA Order 8110. 107 - Monitor Safety/Analyze Data Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 58

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 Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 59

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/linebusiness/avs/offices/air/qms/doc/master_index/ media/AIR-ANM-029 -W 2. pdf • AIR-ANM-029 -W 2 Transport Airplane 24/7 Flight Standards AMOC Request Support Work Instruction https: //intranet. faa. gov/faaemployees/org/linebusiness/avs/offices/air/qms/doc/master_index/ media/AIR-ANM-029 -W 1. pdf Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 60

Questions Communications and 24/7 AMOC Process V 7. 0 Federal Aviation Administration 61