Universal: Special Case In commercial aviation Universal
Avionics currently focuses on the retrofit market, freeing it from the constraints of Boeing and Airbus product support agreements and allowing it an unusual degree of control over its aftermarket. With few exceptions, Universal controls the servicing of its products through its network of around 10 authorized repair stations using company- designed automatic test equipment (ATE).
One exception is the regional carrier Horizon Air, a big customer. Universal approved Horizon and provided it the means to perform LRU return-to-service procedures. Universal’s business model also leaves the company less exposed to data access issues. The company provides CMMs mainly to its authorized service facilities, says Bob Raterink, manager of technical and field support. Board-level repairs, however, typically come back to us, says Robert Clare, director of marketing. Avionics issues can “absolutely”
result in AOG incidents, Clare says. Depending on the criticality of the equipment, minimum equipment list (MEL) items can have a 3-10-day replacement time. In most cases Universal has stock on the shelf and ships out replacement units to the customer the same day, he says. “There’s usually not a Universal product we can’t turn within a week.
cheaper to repair a board than buy a new board or box. If an airline has only been provided a Level 1 CMM, “that means we have to replace the whole LRU every time it is a confirmed fail,” Klink says. Replacement is OK for inexpensive or expendable parts, he says. But at $200,000 or more for a complex, “black box” LRU, that’s not practical. Level 2 maintenance is likewise “cost-ineffective” as it involves buying a new circuit card, which can cost the airline $20,000 or more. “It is difficult…but not impossible to develop appropriate repair capability” for complex technologies if there are sufficient engineering resources and financial investment, Latendorf says. As long as it is cheaper to repair instead of to buy new components, we will recommend the repair approach to our customers, he says. Some CMMs are being thinned down
from Level 3 to Level 2, Segars agrees. “But we invoke the airframer support agreement to regain the Level 3 content,” he says. Ditto for data availability issues with the component OEMs. Moving to electronic CMMs hasn’t helped that much, he adds. “It is disappointing that the move to electronic CMMs has not coincided with the promised increase in the revision cycles.”
Reg Reminders
“Ultimately we must have the data that we need to operate our fleet and create our maintenance program,” Segars says. “If we use an outside vendor, they must perform maintenance as per our program.” This includes the OEM, he says. “So if a vendor is not willing to share data, they cannot use it to perform maintenance on our components. It’s important that vendors understand that this is called out in the regulations.” But because the regulations are broad, “airframer product support agreements can help close the gap,” he says. AMC has dealt with several cases of OEMs’ using maintenance documentation that’s unapproved by the operators when repairing the operators’ components, Klink recalls. This is a violation of FAR 121.361 through .379—further explained in Federal Aviation Administration (FAA) Order 8900.1—and puts the operator’s continuous airworthiness maintenance program (CAMP) at risk for legal compliance, he says. “When the OEMs create internal
processes and procedures relating to component test and repair outside of the CMM, they often call this information ‘intellectual property,’ and do not share
50 Aviation Maintenance |
avm-mag.com | December 2011 / January 2012
Mitch Klink, chairman of the ARINC Avionics Maintenance Committee.
this data outside of their own repair facilities,” Klink says. This practice has been labeled as a competitive advantage for the OEMs over third- party maintenance organizations, but unless this data is part of the operator’s instructions for continued airworthiness (ICA), it’s a violation of the FARs.” The data access issue appears to be
a source of confusion for the OEMs, Klink observes. “The OEMs feel that since they manufactured the LRU, they are the ones best equipped to repair it since they have the assembly and manufacturing drawings associated with that component.” But if those drawings are outside of the CMM, they must be reviewed, approved and under revision service control of the operator as part of the operator’s ICA, he says. The operator’s obligation to safeguard IP is nothing new, Klink says. “But now there are cases where OEMs are not incorporating IP data into the CMMs and not sharing it with the operators for review, approval and control.” The FAA “is keenly aware of these situations and will be issuing a policy clarification letter in early 2012,” Klink says. The draft memo on “Inappropriate Design Approval Holder Restrictions on the Use and Availability of Instructions for Continued Airworthiness” addresses inappropriate actions taken by some design approval holders to restrict the availability, distribution and use of ICA through contractual agreements or restrictive language in the ICA itself. The data restriction issue is not a trivial
problem, Klink says. If, for example, a loss- of-life accident were traced to an avionics component which lacked proper repair documentation, the airline “absolutely” would be left holding the bag, he says. AM
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