A year ago, the stage was set for a notable burst of new and revised regulations aimed directly at the aviation maintenance, repair and overhaul (MRO) community. Civil aviation authorities did not disappoint.
In the U.S., the Transportation Security Administration (TSA) issued long-awaited security rules for repair stations, and the FAA pushed out the latest revision to its Part 145 regulation governing all U.S.-approved repair stations, including some 700 on foreign soil. Most in the industry expressed general satisfaction with both, crediting the agencies with demonstrating rare sensibility in crafting practical standards that simplified broader draft proposals.
Among the European Aviation Safety Agency’s (EASA) MRO-centric moves was a fast-tracked rule on upgrading flight recorder and underwater locator-device standards—a move triggered by the March 2014 disappearance of Malaysia Airlines Flight 370. EASA also released proposed revisions to technical records.
The 2015 calendar is setting up to be similarly busy. EASA started early, with a December release of proposed clarifications to the responsibilities of Part 145 repair stations and continuing airworthiness management organizations (CAMOs). “The objective is to mitigate the risks linked to a faulty assessment of the responsibilities of CAMOs and maintenance organizations, especially in relation to the coordination needed in complex maintenance and operational arrangements,” EASA explains in the draft rule.
The rule also will clarify that a Certificate of Release to Service (CRS) “only certifies . . . certain maintenance and does not necessarily certify that the aircraft/component is airworthy,” EASA noted. The clarification “should reduce the risk of installing components [that] do not meet all the airworthiness requirements.” The rule is open for comment through March 2 and is expected to be finalized sometime in 2018.
Meanwhile, FAA faces a February deadline to finalize new regulations for how operators document contract-maintenance relationships. Mandated by Congress as part of the February 2012 FAA reauthorization bill, the rule will require operators to provide more detailed information on where maintenance work is being sent. Long-required approved-vendor lists are expected to become more detailed and to be updated more frequently. Early last year, FAA expected to have the rule out by 2015 but now appears destined to run up against its three-year deadline.
As the new year approached, FAA was poised to release its final rule mandating Safety Management Systems (SMS) for Part 121 (scheduled) airlines. The Office of Management and Budget—which signs off on all rules before they are finalized—approved the SMS rule in late November following a six-month review, setting the stage for a public release in early 2015 if not before.
The SMS rule will not directly cover maintenance providers. But because they are required to follow customers’ maintenance procedures, MRO shops will be affected by the mandate.
FAA’s to-do list also includes new requirements for training in air carrier maintenance. Originally slated for a 2012 release, the rule fell victim to what FAA called “other, higher priorities.”
The agency confirmed in 2014 that the rule was finally being written and would include about 10 specific elements, including human-factors training. Since the rule will apply only to Part 121 and Part 135 carriers, it will not mean a long-anticipated human-factors mandate for repair stations. But Steve Douglas, who manages FAA’s maintenance branch, confirmed at a 2014 industry gathering that the agency “is looking at” requiring human factors training for certified MRO shops.
FAA faces a self-imposed deadline of late 2015 to begin gathering more information from the Aviation Safety Information Analysis and Sharing (ASIAS) safety data aggregation program into the hands of its own inspectors. ASIAS is a key component in FAA’s push to a risk-based, forward-looking oversight system. It has about 75 participants, most of whom voluntarily contribute safety-related data that is aggregated and mined for trends. One of FAA’s major pushes in 2014 was encouraging MRO providers to join; AAR Corp. and Haeco Americas became the first two to sign up.
While ASIAS has been instrumental in identifying trends before they contribute to accidents, FAA has struggled to plug ASIAS-related data into general surveillance conducted by its own inspectors. ASIAS and other volunteer data programs do not target specific operators, but general trends can help guide inspectors on where to focus their efforts.
A 2013 Transportation Department Office of Inspector General (OIG) report lauded FAA’s general progress with ASIAS, but urged FAA to close the loop with its inspectors. The agency has been working on the challenge for several years, missing several self-imposed deadlines along the way.
A version of this article appears in the December 29, 2014/January 14, 2015 issue of Aviation Week & Space Technology.