AD ARC

							                                                    Federal Aviation
 2010 US / Europe                                   Administration

 International Aviation
 Safety Conference

Airworthiness Directive
Implementation ARC

 By: Ali Bahrami
     Manager, Transport Airplane Directorate, FAA
 Date: June 10, 2010
Outline

• Background

• Recommendations and Activities
      –   Service Information
      –   AD Development
      –   AD Implementation
      –   FAA Organization and Procedures




2010 US/Europe International Aviation Safety Conference   Federal Aviation   2
June 10, 2010                                             Administration
Background – What is the ARC?




2010 US/Europe International Aviation Safety Conference   Federal Aviation   3
June 10, 2010                                             Administration
Background – Drivers for the ARC
  • Independent Review Team (IRT) established by
    Secretary of DOT.
        – Team consisted of 5 aviation and safety experts.
        – Tasked to evaluate and make recommendations to
          improve:
              • FAA’s implementation of the aviation safety system
              • FAA’s culture of safety
  • IRT report issued 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.

2010 US/Europe International Aviation Safety Conference   Federal Aviation   4
June 10, 2010                                             Administration
Background
  • In March 2008, the FAA initiated an AD audit.
        – Indicated a 98% compliance rate.
        – Identified a compliance issue with an AD (2006-15-15).
              • Resulted in flight cancellations for a large portion of the MD-
                80 fleet.

  • The FAA established an AD Compliance Review
    Team (CRT) to review events that caused a
    disruption to some airline schedules.




2010 US/Europe International Aviation Safety Conference    Federal Aviation       5
June 10, 2010                                              Administration
Background
 • The AD CRT reports were released in September
   2009.
       – Task 1 Report: AD 2006-15-15 (dated June 3, 2009)
       – Task 2 Report: AD process (dated July 8, 2009)


 • 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.


2010 US/Europe International Aviation Safety Conference   Federal Aviation   6
June 10, 2010                                             Administration
Background
• AD CRT Reports:
     – Task 1: 5 findings and 4 recommendations
     – Task 2: 12 findings and recommendations

• The AD CRT findings & 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.
2010 US/Europe International Aviation Safety Conference   Federal Aviation   7
June 10, 2010                                             Administration
Recommendations and Activities

•    Key Objectives:
      – Service Information: Revise the way service bulletins are written to
        avoid mandating actions that are not required to meet the safety intent
        of the AD.

      – AD Development: Ensure the AD development process is effective
        and efficient.

      – AD Implementation: Identify and develop guiding principles,
        processes, procedures, and best practices for implementing and
        maintaining compliance with AD’s to ensure a safe product.

      – FAA Organization/Procedures: Define decision making processes for
        compliance versus non-compliance that can be used by FAA and
        Industry in any situation.


2010 US/Europe International Aviation Safety Conference    Federal Aviation       8
June 10, 2010                                              Administration
Service Information

• Associated Recommendations
      – Revise format of service instructions to avoid mandating
        things that are not required to meet the safety intent
      – “User-Friendly” improvements to service instructions to
        include; critical task differentiation, standard practices,
        flexibility, to name a few
      – Revise ATA Specification 111 (for Lead Airline Process)




2010 US/Europe International Aviation Safety Conference   Federal Aviation   9
June 10, 2010                                             Administration
Service Information

• Accomplishments
       Drafted prototype SB with critical aspects
       Formalized the Lead Airline review process
       Implemented the AD Friendly service bulletin format
       Changes to Boeing Service Instructions, including; listing
        of affected maintenance zones and inclusion of general
        notes
       Began posting Boeing Service Bulletins to the Electronic
        Docket Management System
       FAA issued a memo to clarify ex parte communications


2010 US/Europe International Aviation Safety Conference   Federal Aviation   10
June 10, 2010                                             Administration
Service Information

• In – Work
       Expansion on the use of general notes to increase
        operator flexibility
       Differentiation of critical tasks within the service
        information




2010 US/Europe International Aviation Safety Conference   Federal Aviation   11
June 10, 2010                                             Administration
Airworthiness Directives

• Associated Recommendations
      – Effectiveness of ADs; Public Access to NPRMs; referred
        to in AD; Compliance times stated in ADs,
      – Extend comment period on MCAI NPRMs to 45 days




2010 US/Europe International Aviation Safety Conference   Federal Aviation   12
June 10, 2010                                             Administration
Airworthiness Directives

• In – Work
       Revised FAA Orders – Airworthiness Directive handbook
        revisions
       Changes to Service Bulletin structure (critical task
        identification) and resulting references in ADs to clarify
        what is required
       Assessing how to review call outs of replacement parts
        for increased flexibility and reduced non-compliances
       Assessing how to address overlapping ADs




2010 US/Europe International Aviation Safety Conference   Federal Aviation   13
June 10, 2010                                             Administration
AD Implementation

• Associated Recommendations
      – Air Carrier processes to prototype ADs in coordination
        with the FAA-ASI and continually verify accomplishment
        or an AD
      – Industry training on AD processes/best practices
      – FAA and ATA process for participating in compliance
        planning and AD prototypes
      – Develop means to develop global AMOCs
      – Air Carriers to develop best practices to address normal
        maintenance actions that could de-modify an AD
        configuration

2010 US/Europe International Aviation Safety Conference   Federal Aviation   14
June 10, 2010                                             Administration
AD Implementation

• Accomplishments
       Affected maintenance zones identified in service
        instructions for Boeing
       Provided AD training and developed EWIS training




2010 US/Europe International Aviation Safety Conference   Federal Aviation   15
June 10, 2010                                             Administration
AD Implementation

• In – Work
       Compliance planning, implementation, and monitoring
        process. Compliance planning will be categorized into
        five areas; planning, engineering, provisioning, executing
        and recording.




2010 US/Europe International Aviation Safety Conference   Federal Aviation   16
June 10, 2010                                             Administration
FAA Organization/Procedures

• Associated Recommendations
      – Clarify roles and responsibilities for ASIs, including a
        communication and decision making processes
      – Ensure AEG personnel are included in AD processes
      – Strengthen the AMOC Process; Communication
        channels, coordination with CMO, concurrence on
        between offices, delegation of, and staff availability 24/7
      – Revise ATOS guidance material
      – Review §§ 39.7 and 39.9, and, if necessary, revise to
        clarify that AD compliance is an action required of the
        operator

2010 US/Europe International Aviation Safety Conference   Federal Aviation   17
June 10, 2010                                             Administration
FAA Organization/Procedures

• Accomplishments
       The FAA published AMOC processes for general
        coordination and ‘24/7’ support for urgent requests.
       The FAA chartered an internal team to review expansion
        of certain AMOC delegations
       Issued a memo to re-enforce the role of the AEG




2010 US/Europe International Aviation Safety Conference   Federal Aviation   18
June 10, 2010                                             Administration
FAA Organization/Procedures
• In – Work
       ’24/7’ briefings to FAA personnel
       Proposal for ARC on increased AMOC delegation
       Revised coordination for simultaneous coordination of
        AMOCS
       Decision document regarding revision to Part 39
       Formal training for AEG roles and responsibilities




2010 US/Europe International Aviation Safety Conference   Federal Aviation   19
June 10, 2010                                             Administration
                                     Questions?




2010 US/Europe International Aviation Safety Conference   Federal Aviation   20
June 10, 2010                                             Administration