A data-driven safety system only works if the data is manageable and meaningful. A cross-section of industry stakeholders believes that one stream of data—service difficulty reports (SDRs) filed by FAA-approved repair stations—is neither.
The issue revolves around FAA’s requirement to have repair stations file SDRs on "any serious failure, malfunction, or defect of an article"—meaning an aircraft, engine, or part. The problem, the stakeholders argue, is that nearly everything sent to a repair station has a serious defect. Fixing such defects—in other words, making things airworthy—is what repair stations do.
The mandate to have repair stations report “serious” defects was introduced in 2003 following an industry push to create differentiation between major issues and run-of-the-mill problems. The word was left out of a 2014 rule update, but an effort led by the Aeronautical Repair Station Association (ARSA) convinced FAA to reinstate the “serious” qualifier.
Now, however, ARSA and a dozen others, including Boeing, Gulfstream, Airlines For America, and the Aviation Suppliers Association, say that a more specific standard needs to be established.
Their proposal: evaluate each defect noted by repair station personnel and determine if any of them are unusual or unknown. If so, they are then cross-referenced against FAA’s SDR-filling criteria for design-approval holders.
For instance, Part 121 operators are required to file SDRs for 17 conditions, ranging from in-flight fires to airframe cracks beyond allowable limits. If the repair station finds something that would trigger an SDR from the operator or design-approval holder, then the MRO shop should file one, too.
“In most cases, whether or not the design approval holder or operator generates a report will not be known to the maintenance provider,” the group wrote in a letter to FAA Flight Standards Service Director John Duncan. “Nevertheless, information from the proposed [repair station] reports could and would be more closely aligned with those mandated submissions.”
The net result: reports from repair stations on real problems, vs. a flood of submissions detailing routine issues already noted in maintenance manuals, service bulletins, or airworthiness directives. The change also would give inspectors clearer guidance on how to evaluate repair stations on compliance with the SDR-filing requirements.
"The agency can alleviate enforcement inconsistencies by focusing on issues without appropriate corrective actions,” ARSA explained. "When maintenance providers have the data or practices to support a fix, there is no 'serious' issue."