LEGAL SPIN
BY JASON DICKSTEIN
SPOTLIGHT ON FAA EFFORTS TO PROMOTE AIRCRAFT PARTS SAFETY
here is a lot of policy work going on right now in the Federal Aviation Administration (FAA) that affects aircraft parts safety. These are the sort of efforts that yield real safety results, but that seldom see the headlines. The FAA is constantly developing policies to promote safe practices, to discourage unsafe practices, and also to better allocate their scant resources. This month, I would like to highlight three current FAA safety efforts that will affect aircraft parts safety.
T
Promoting Safety One example of the FAA’s successful programs for promoting safety is the Voluntary Industry Distributor Accreditation Program, which was published in FAA AC 00-56. This program set voluntary quality assurance standards for aircraft parts distributors. If you buy parts for commercial aircraft, chances are your main sources of supply are probably all AC 00-56 accredited. Eight years into the program, the FAA conducted an audit that found that “AC 00-56 is a well- written guidance material that has helped industry to police itself in lieu of regulatory requirements.” This was an important finding for the FAA, because the FAA recognized that it did not have the resources to regulate distributors directly, but it wanted to ensure that there were safety standards that were applied to these critical links in the chain of safety. The FAA’s audit examined AC 00-56 accredited distributors and found that these companies strove to meet higher standards than those than the FAA had set and that the program provided added safety benefits that were recognized by the aviation community. The program was a tremendous success and the FAA resolved to promote participation in the program. The FAA’s audit also focused on the Aviation Suppliers Association (ASA), which is the leading audit
provider on the FAA AC 00-56 registry. The FAA announced that ASA “has a quality system that far exceeds the requirements of AC 00-56.” The FAA is developing revisions to make this an even stronger program for assuring aircraft parts
safety, and the FAA’s expected revisions should also better facilitate global safety standards. But perhaps the greatest compliments to the FAA’s program come from the fact that China has
recognized the importance of AC 00-56 and has developed their own distributor guidelines (which recognize and accept AC 00-56 accreditation) and the European Community is now developing guidance material to recognize the AC 00-56 elements as important elements for anyone that sells parts into the EC (look for these later this year).
Discouraging Unsafe Practices The FAA also realizes that there are undesirable practices that undermine safety, and that the Administration has an obligation to communicate that such practices are unacceptable. The FAA will soon publish a Policy Statement on Instructions for Continuous Airworthiness (ICAs). Known as “PS-AIR-21.50-01: Inappropriate DAH Restrictions on the Use and Availability of ICA),”
the FAA policy was written in response to the growing practice of manufacturers licensing their manuals on the condition that the licensee repair station or air carrier/operator pledge to refrain from using competitive products like DER repairs or PMA parts. In some cases, this practice has used licensing agreements to make legal compliance with the FAA
regulations impossible. One way that this has happened is in agreements that prohibit the use of the a set of ICAs for maintaining a competing article. The problem arises with the fact that in many cases, the FAA encourages PMA manufacturers to (they are required to show compliance with existing ICAs unless an alteration makes those ICAs inapplicable). Then, the FAA approves the PMA part in the context of the use of existing ICAs. Thus, the inspection standards of the existing ICAs (for example), may apply to th PMA parts. But if the repair station is legally precluded (by a licensing agreement) from
46 Aviation Maintenance |
avm-mag.com | February / March 2012
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