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Aircraft maintenance may face some regulatory challenges in 2017, especially from the EU.

MRO Regulatory Challenges Anticipated In 2017

Aircraft maintenance may face some regulatory challenges in 2017, especially from the EU.

As 2016 ended, the FAA was working on the final rule for aviation maintenance-technician schools. The agency aims to modernize their curriculums and make it easier to change them in the future.

The FAA also wants to issue a rule for drug and alcohol testing of employees at foreign repair stations, required by 2012 legislation. It seeks to issue a proposed rule in May 2017 and close comments in August.

By July 2017, the FAA intends to publish a proposed rule standardizing regulations and guidance for safety assessments of transport airplanes, harmonizing with the European Aviation Safety Agency’s (EASA) approach. By May the agency wants to amend regulations on maintenance of fuel tanks to prevent lightning-induced accidents.

Transport Canada is working on two regulations that might affect aircraft modification. The first would increase the duration of cockpit voice recorder (CVR) recordings to 2 hr., physically separate the CVR from the flight data recorder and require a dedicated, independent power supply for the CVR and cockpit microphone for 10 min. if normal power is lost. The second would ensure that emergency locator transmitters transmit at 406 MHz, in conformity with international standards.

Industry Reactions

Airlines for America (A4A) and 13 other aviation and technical-education organizations object to the direction the FAA is apparently taking in its rulemaking for technician schools. The objectors want, “competency-based guidelines that allow institutions to design programs that match employer needs.” The FAA’s proposed rule mandates course time for each subject, specifies passing norms and student-teacher ratios and requires FAA approval of instructors and any additional instruction. This approach continues the old, unreformed process, wastes time and increases costs, A4A and others say. They would like a flexible program that allows students to progress as they master subjects, regardless of time, place or pace of learning.

Sarah MacLeod executive director of the U.S.’s Aeronautical Repair Station Association (ARSA), is one of the skeptics of the FAA’s training approach. “Rather than specifying compliance, we need to ensure we have the people who can actually do repairs safely in shops and who can turn wrenches,” MacLeod says.

The new regulations would require two years to acquire an aviation maintenance technician certificate. “We do not need to teach to certificate, we need to teach competence,” she says.

MacLeod does not expect the FAA’s final drug-testing rule to come out in 2017. ARSA and others added a qualification to the mandating legislation, that drug tests must be consistent with the laws of each country. “But some countries do not allow their citizens to be tested,” she says. We are not afraid of this rule, but we would like to understand how the FAA is going to split the baby if a country does not allow testing.”

She maintains one reason is that regulators of production, operation and maintenance of aircraft are not working together. “These parts are like arms and hands; you cannot separate them.” This disengagement has caused major inconsistencies and problems in treatment of Form 8130s.

ARSA would prefer such difficulties be straightened out before the U.S. negotiates bilateral maintenance agreements with nations such as Brazil, China or Singapore. The aim is  to reduce Part 145 certificates to fewer than the 91 certificates some ARSA members must now acquire.

ARSA is also concerned with the FAA’s Safety Assessment System, “which was not supposed to change the rules of the game,” McLeod emphasizes. “But it has changed the game for approval and surveillance of certificates.”

The FAA’s preference now is to avoid enforcement actions at the outset, but inspectors use FAA guidance materials, rather than FAA regulations, to determine whether a shop is in compliance. “If you change the guidance materials while training inspectors, they will become more critical,” McLeod says. “You cannot go into a Safety Assessment blind and rearrange the deck chairs. We have a good system.”

She says Canadian regulations are fairly stable and affect a small population of shops. She expects more movement from EASA once its reorganization and reassignment of staff are complete.

EASA Busy In 2017

EASA appears headed for a busy year in 2017. Juan Anton, who manages the agency’s maintenance regulations, says it will be working on several rules related to safety management requirements. These include a Phase 1 rule on introducing such requirements for Continuing Airworthiness Management Organizations (CAMO) and a Phase 2 rule on Safety Management requirements for non-CAMOs that may cover Part 145 production companies.

EASA will also be looking at rules to facilitate cross-border transfers of aircraft. These will include amendments to Part 21 and Part M to guarantee consistency in issuance of a Certificate of Airworthiness and an Airworthiness Review Certificate for aircraft imported into the EU. In addition, EASA will consider amendments to Part M and Part 145 regarding technical records and electronic maintenance records. Finally, Part M will be amended to strengthen the airworthiness review process.

A third area requiring EASA effort in 2017 will be simplifying the licensing of maintenance personnel, especially for new technologies. Licensing requirements will be adapted to the new training and teaching technologies, and EASA will undertake a full review of Part 66 and Part 147 requirements.

EASA also wants to clarify responsibilities of different parties in ensuring the Continuing Airworthiness of aircraft. One rule would clarify the responsibilities of certifying staff, support staff and maintenance personnel, while another would clarify responsibilities of CAMOs and Part 145 maintenance organizations.

Anton stresses that EASA will be working in all these areas in 2017, but final rules will only be issued according to a schedule published on the EASA website by the end of 2016. 

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