Maintenance Workshop Oversight of Contract Maintenance Presented to

Maintenance Workshop 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 Federal Aviation Administration

Overview • Background outsource maintenance • Air carrier maintenance – – – In-House Uncertificated Facility Uncertificated Entity Certified Repair Station Outsources Maintenance • Conclusion Oversight of Contract Maintenance June 5, 2008 Federal Aviation Administration 2

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. Oversight of Contract Maintenance June 5, 2008 Federal Aviation Administration 3

Air Carrier In-House Maintenance Air Carrier Internal Work Request Air Carrier Maintenance Facility Personnel “Directly-In-Charge” of a maintenance function must be certificated as a airframe or powerplant mechanic or both A&P Work is performed by Certificated and/or Non. Certificated persons at air carrier facilities Work is performed in accordance with Air Carrier’s procedures Oversight of Contract Maintenance June 5, 2008 Aircraft or product is inspected by Air Carrier’s inspection department Airworthiness Release is signed by Air Carrier Federal Aviation Administration 4

Uncertificated Facility Air Carrier Contracts To Uncertificated Facility (Ref. OIG Report AV-2006 -031) Work is performed by Non -Certificated persons Work is performed in accordance with Air Carrier’s procedures Oversight of Contract Maintenance June 5, 2008 Aircraft or product is inspected by Air Carrier’s inspection department Airworthiness Release is signed by Air Carrier Federal Aviation Administration 5

Uncertificated Entity Air Carrier Contracts To Uncertificated Entity (Ref. OIG Report AV-2006 -031) Work is performed by mechanics certificated under 14 CFR Part 65 & trained by Air Carrier Work is performed in accordance with Air Carrier’s procedures Oversight of Contract Maintenance June 5, 2008 Aircraft or product is inspected by certificated mechanics in accordance with Air Carrier’s procedures Airworthiness Release is signed by certificated mechanic authorized by the air carrier Federal Aviation Administration 6

What Is Contract Maintenance? Air Carrier Contracts To Certificated Repair Station Work is performed by the Repair Station must hold the specific ratings issued by FAA Repair Station personnel “Directly-In-Charge” of a maintenance function must be certificated as a mechanic or Repairman (N/A foreign) 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 Oversight of Contract Maintenance June 5, 2008 Aircraft or product is inspected by Repair Station personnel Repair Station must have a Quality Control System acceptable to FAA The air carrier, or the person with whom the air carrier arranges for the performance of the maintenance, preventive maintenance, or alterations, prepares or causes to be prepared-an airworthiness release Federal Aviation Administration 7

Repair Station Contracts to Non. Certificated Entity Repair Station Contracts To Non-Certificated Entity Repair Station must hold specific ratings issued by FAA Maintenance function approved by FAA The noncertificated facility must be inspected by the certificated Repair Station The noncertificated entity must have a quality system equal to the Repair Station’s Repair Station personnel “Directly-In-Charge” of a maintenance function must be certificated as a mechanic or Repairman (N/A foreign) Oversight of Contract Maintenance June 5, 2008 Product is inspected by Repair Station personnel FAA is authorized surveillance of the noncertificated entity Airworthiness Release is signed under the authority of the Repair Station Federal Aviation Administration 8

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. Oversight of Contract Maintenance June 5, 2008 Federal Aviation Administration 9

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. Oversight of Contract Maintenance June 5, 2008 Federal Aviation Administration 10

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 Oversight of Contract Maintenance June 5, 2008 Federal Aviation Administration 11

FAA Action Continued • 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 Oversight of Contract Maintenance June 5, 2008 Federal Aviation Administration 12

FAA Action Continued • 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 Oversight of Contract Maintenance June 5, 2008 Federal Aviation Administration 13

FAA Action Continued • Inspector Outsource Maintenance Training – Mandatory training for all inspectors • Course prototype completed Oversight of Contract Maintenance June 5, 2008 Federal Aviation Administration 14

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 June 5, 2008 Federal Aviation Administration 15