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Certification/Maintenance

Certification/Maintenance. Major Discussion Points (RAFT). AVS Repair, Alteration, and Fabrication Team (RAFT) Concerns raised by TC/PC holders and component OEMs about repairs, alterations, fabrications, and replacement part designs: Not adequately engineered and evaluated for compliance

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Certification/Maintenance

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  1. Certification/Maintenance

  2. Major Discussion Points (RAFT) AVS Repair, Alteration, and Fabrication Team (RAFT) • Concerns raised by TC/PC holders and component OEMs about repairs, alterations, fabrications, and replacement part designs: • Not adequately engineered and evaluated for compliance • Being performed on more safety critical parts and complex systems increasing the threat to safety, • Are being misrepresented as TC/PC holder parts, and • Create an un-even commercial playing field because FAA does not hold all applicants to the same standards • Chartered an AVS team (AFS/AIR) to review all regulations and policy related to repair, alteration, and fabrication during maintenance • Identify any gaps and recommend possible solutions • Training and Policy and Rule changes

  3. Reaction from the Floor (RAFT) • Critical part definition • Difference between acceptable and approved data • Additional Instructions for Continued Airworthiness (ICA) guidance • RAFT addressing all these items

  4. Major Discussion Points (DAH) Design Approval Holder (DAH) Rules • DAH rules are a new approach for facilitating timely implementation of certain complex, fleet-wide safety initiatives • DAH rules rely on a proactive, program management approach • The FAA has issued two final rules containing DAH requirements • Enhanced Airworthiness Program for Airplane Systems (EAPAS) • Aging Aircraft Safety Rule (AASR) • The FAA expects to issue the Widespread Fatigue Damage (WFD) • The FAA, TCCA, EASA, and ANAC have been in close coordination since early 2005 • TCCA, EASA, and ANAC intend to issue similar rules

  5. Major Discussion Points (DAH) Design Approval Holder (DAH) Rules (EASA) • Long term rules • Amendment to BR216/2008 Article 5 and task 21.039. • Temporary changes for Aging systems • NPA on EWIS (Electrical Wire Interconnect System) • AMC20

  6. Reaction from the Floor (DAH) • Positive feedback from Industry relative to overall approach and process • Some concerns early on • Authorities very responsive • Good example of Industry/Authority cooperation • Significant harmonization efforts by authorities

  7. Outcomes/Additional Ideas • The RAFT is preparing a final report that will address all existing policy and recommended changes and/or clarifications • Considers Industry feedback • Report is due to be completed by the end of June • A notice will be published in the Federal Register summarizing RAFT results and recommendations • The FAA process/policy owner offices will implement the recommended changes

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