Earlier this month, FAA sent out a Special Airworthiness Information Bulletin (SAIB) clarifying that operators and MRO providers that rely on Alodine,a corrosion-protection and primer for certain metals, can safely use Bonderite for the same applications.
Both Alodine and Bonderite are made by Henkel. In fact, they are one and the same. Bonderite is simply the new brand name for Alodine. Aside from looping in the end-users—Henkel notes that Bonderite as "known as Alodine"—why did FAA take the step of issuing an SAIB? Because it has a number of regulatory-binding documents that call out Alodine specifically.
"The FAA has issued many [airworthiness directives (ADs)] and [alternative means of compliance, or AMOCs] that specifically call out for application of Alodine," the agency notes in the bulletin. "The unavailability of Alodine will make it difficult to comply with ADs or previously approved AMOCs that require the application of Alodine."
Such is the power of FAA's regulations—and the challenge presented when the agency gets too specific in the rules that govern U.S. aviation.
In an ideal world, FAA's regulations set the basic parameters, and its guidance provides more specific guidelines on how the rules can be followed. When the rules get too specific, industry can be hamstrung, because it's much harder to change a regulation than to issue new guidance.
“The FAA should learn from this,” said Aeronautical Repair Station Association (ARSA) executive director Sarah MacLeod. “When it calls out specific materials in a law, such as an airworthiness directive, a simple marketing change made by a company producing those materials can require bureaucratic backflips. This [new AMOC] is a fine fix, but the government needs to be more circumspect in proscriptive rulemaking.”