Input from nearly 70 repair stations in a recent industry survey on audits underscores the thoroughness that regulators and customers exhibit when auditing facilities to ensure they comply with rules and standards.
The survey, conducted by the Aeronautical Repair Station Association (ARSA), represents 369 facilities tied to 69 repair station organizations. The facilities reported 6,723 total audits—both paper-based and in-person—in the previous 12 months. Not surprisingly, the largest source of audits was customers, with 2,700 of the audits. Internal audits, such as those required by quality systems, generated 1,180, while the FAA was responsible for 800. All respondents are FAA-certificated repair stations.
The audits resulted in 561 findings, including 173 generated internally and 79 by the FAA. The majority of these—57%—were “typographical,” while 25% were classified as contradictory views on what constitutes compliance.
The survey also touches on costs associated with audits. Respondents reported that Civil Aviation Administration of China (CAAC) audit costs topped the list, averaging $11,000 each. Nearly 30% of the respondents hold CAAC certification.
ARSA, which summarized its survey findings in its hotline newsletter, has made reducing duplicative or unnecessary audits a priority for its members. The FAA, which recognizes the resource drain that unneeded audits create, is on board.
The agency’s new Safety Assurance System (SAS) surveillance tool is a key part of an effort to rely on data to boost system safety. At last year’s annual ARSA gathering, John Hickey, FAA deputy associate administrator of aviation safety, outlined an approach in which audit information gathered from certificate holders is shared internally, eliminating the need for duplicative audits.
For instance, a repair station with five airline customers is scrutinized by each airline’s representative FAA certificate management office (CMO), plus the FAA team that oversees the repair station. Under a mature version of SAS, one audit would suffice.
SAS is rolling out, and it is a work in progress. ARSA noted that its 69 repair station survey respondents reported 209 audits from FAA CMOs, “which illustrates the continuance of redundant agency reviews.”
Meanwhile, a presentation at ARSA’s recent annual conference highlighted confusion among repair stations that need to meet multiple civil aviation agency standards to maintain certifications. Karl Specht, the European Aviation Safety Agency (EASA) continuing airworthiness organizations manager, told attendees that EASA often finds inadequate audit programs when reviewing U.S.-based repair stations with EASA certification. The agreement between the U.S. and the EU—specifically the supplemental Maintenance Annex Guidance (MAG)—requires most U.S. shops to have a quality assurance system that audits both procedures and products independently.
The procedural programs usually fall short because they do not cover every procedure. Similarly, the product audits do not meet EASA’s requirements because they do not cover all “primary” product lines—engine, component, etc.—or they are not done often enough.
ARSA encourages members to review the MAG for details on what EASA expects. The association also has a sample template that shops can use to comply with the MAG.
Minor PMA Fixes Clarified
An FAA draft policy statement clarifies that the agency’s Parts Manufacturer Approvals (PMA) process can be used to modify a product and not be considered a so-called “major change” that would require a type certificate amendment or supplemental type certificate.
“PMA is a suitable method to approve an article, and provide for that article’s installation, in cases where the installation would not constitute introduction of a major change in a product’s type design,” the draft policy says.
“In order to use this approach, the change resulting from installation of an article must first be identified and justified as not being major with respect to the product (meaning the aircraft, aircraft engine or propeller) by the PMA applicant and agreed to by the project [FAA aircraft certification office (ACO)] in accordance with the current process.”
The policy clarifies what the FAA acknowledges has been a “confusing and inconsistent” approach within the agency. Some ACOs have permitted PMAs without labeling the major changes, while others “instituted a self-imposed prohibition on those same practices,” the agency’s proposed policy notice explains. Further confusion led to requests from ACOs for a clarification from FAA headquarters.
The Modification and Replacement Parts Association (Marpa) expressed cautious optimism about the proposed language.
“On balance this looks like a positive policy for the PMA industry,” Marpa says, adding that it would seek input from members to identify any “unintended consequences” before throwing its full support behind the policy.
The FAA sought comments through May 1 and is expected to issue a final version later this year.