Maintenance Workshop Federal Aviation

Administration

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

Overview
• Background outsource maintenance
• Air carrier maintenance
– In-House
– Uncertificated Facility
– Uncertificated Entity
– Certified Repair Station
– Certified Repair Station Outsources Maintenance
• Conclusion

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June 5, 2008 Administration
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.

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June 5, 2008 Administration
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 Work is performed Aircraft or product Airworthiness

by Certificated in accordance is inspected by Air Release is
and/or Non- with Air Carrier’s Carrier’s signed by Air
Certificated persons procedures inspection Carrier
at air carrier department
facilities

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June 5, 2008 Administration
 Uncertificated Facility
Air Carrier Contracts To

Uncertificated Facility
(Ref. OIG Report AV-2006-031)

Work is Work is Aircraft or product Airworthiness

performed by performed in is inspected by Air Release is
Non-Certificated accordance with Carrier’s signed by Air
persons Air Carrier’s inspection Carrier
procedures department

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June 5, 2008 Administration
 Uncertificated Entity
Air Carrier Contracts To

Uncertificated Entity
(Ref. OIG Report AV-2006-031)

Work is Work is Aircraft or product Airworthiness

performed by performed in is inspected by Release is
mechanics accordance with certificated signed by
certificated under Air Carrier’s mechanics in certificated
14 CFR Part 65 & procedures accordance with mechanic
trained by Air Air Carrier’s authorized by
Carrier procedures the air carrier

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June 5, 2008 Administration
 What Is Contract Maintenance?
Air Carrier Contracts To

The air carrier, or

Certificated Repair the person with
Station whom the air
carrier arranges
for the
Work is performed by performance of the
the Repair Station maintenance,
Work is performed in Aircraft or product is
accordance with the inspected by Repair preventive
appropriate portions of Station personnel maintenance, or
Repair Station must the Air Carrier’s CAMP, alterations,
hold the specific ratings pertinent instructions prepares or causes
issued by FAA from its maintenance Repair Station must to be prepared--
manual and instructions have a Quality Control
for continued an airworthiness
System acceptable to
airworthiness FAA
release
Repair Station personnel
“Directly-In-Charge” of a
maintenance function must
be certificated as a mechanic
or Repairman (N/A foreign)

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June 5, 2008 Administration
 Repair Station Contracts to Non-
Certificated Entity
Repair Station Contracts To

Non-Certificated Entity
Repair Station must
hold specific ratings
issued by FAA
Product is
The non- The non- inspected
certificated Airworthiness
certificated by Repair
facility must be Release is
entity must Station
inspected by signed under
have a quality personnel
the certificated the authority
system equal of the Repair
Maintenance function Repair Station to the Repair FAA is Station
approved by FAA
Station’s authorized
surveillance
of the non-
certificated
Repair Station personnel “Directly-In-Charge” of a maintenance entity
function must be certificated as a mechanic or Repairman (N/A
foreign)

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June 5, 2008 Administration
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.

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June 5, 2008 Administration
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.

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June 5, 2008 Administration
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

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June 5, 2008 Administration
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

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June 5, 2008 Administration
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

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June 5, 2008 Administration
FAA Action Continued

• Inspector Outsource Maintenance Training

– Mandatory training for all inspectors

• Course prototype completed

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June 5, 2008 Administration
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.

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June 5, 2008 Administration