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Repair Data Acceptance Presented by W. Schulze-Marmeling. 1st Meeting. February 10-12, 2003 in Braunschweig Attendees from Minutes, mutually agreed, are available. Terms of Reference as of 07.11.2002. S pecific tasks and interface issues (Deliverables):
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February 10-12, 2003 in Braunschweig
Minutes, mutually agreed, are available
Specific tasks and interface issues (Deliverables):
FAA and JAA representatives will meet and examine FAA and JAA/NAA system for classification, approval, and documentation of repairs.
The authorities will identify systems differences and potential methods to mitigate these differences.
The authorities will make a determination whether a system of reciprocal acceptance can be established.
The authorities will draft procedures and internal guidance to streamline reciprocal acceptance of repairs.
These documents will cover the classification, approval, documentation and accomplishment of repairs.
Develop and deliver a training to the appropriate authority and industry personnel affected by the agreement prior to implementation.
Recommend any changes to be considered for future reciprocal agreements between Europe and US. The Subgroup tasked to finalize the Repair Design Approval Sheet will provide the outcome of their work to the Full Group.
Chairmen: Mr. Frank Steffens and Mr. Kevin Kendall
Discussion of ToRs
Accomplishment of repairs sufficiently covered by
Discussion of ToRs (cont’d)
Training: cannot be accomplished within the time
Subgroups nominated to deal with specific areas
FAA definition of acceptable data vs. approved data FAA system of classification major/minor repairs (121 operators process vs. other processes)
Conformity of repair data with importing country’s TC-basis Repair development for products for which the NAA is not the state of design Connection between repair designer and TC / STC-holder
Language of approvals and documentation of repairs Mutually acceptable repair approval sheet
Both the FAA and the NAA BAAs/BASAs and IPAs have previously accepted each other’s system as described in the individual agreements. This has to be respected to the maximum possible extent.
1. Accomplishment of repairs deleted, sufficiently covered by JAR/FAR 145
2. Development of training material, postponed
3. Delivery of the report, extended until end of August 2003
April 28-29 in HoofddorpReview of specific areas as defined during 1. Meeting
FAA field approval process vs. JAA repair data approval process (Subgroup 1)
FAA field approval process provides an equivalent level of airworthinesscompared to JAR-21 subpart M approvalprocess
Clarification why the field approval process is not always applicable(Part 121 Air Carrier aircraft are not generally eligible)
Comparison FAA DER Authorisation vs. ASI Authorisation (Subgroup 1)
both authorisations provide an acceptable level of confidence
FAA definition of acceptable data vs. approved data (Subgroup 2)
the FAA system provides an equivalent level of airworthiness comparable to what JAR-21subpart M requires
FAA system of classification major / minor repairs (Subpart 2)
Draft Conclusion: the classification and processing of data provide an equivalent level of airworthiness compared to what JAR-21 subpart M requires
Action: Delivery of background information, why the classification is granted as a specific privilege to operators and repair stations, and the benefit of this privilege.
FAA designee system vs. JAA DOA system (Subgroup 3)
Draft Conclusion: the approval of repair data by the FAA‘s designee and delegated organisation system should be given the same validity as those made directly by the FAA.
Action: future changes of the FAA delegated organisation / designee (ODA) system to be included in the final report.
Qualification of JAA DOA staff
Draft Conclusion: A sufficient level of technical competence is provided
Approval / Oversight of JAA DOAs(Subgroup 3)
Draft Conclusion: The JAA approval and oversight procedures for DOAs are acceptable to the FAA
Conformity of repair data with importing country‘s TC basis(Subgroup 4)
Draft Conclusion: compliance with the TC basis of the State of Design is acceptable, unless repair data are technically incompatible with the configuration of the a/c or product to be repaired
Repair development for products for which the NAA is not the Authority of the State of Design (Subgroup 4)
Draft Conclusion: both Systems (FAA‘s and JAA‘s) provide a sufficient level of airworthiness irrespective of the State of Design of the product repaired.
Cooperation between the repair designer and the
Draft Conclusion: FAA system ensures that basic
product data are available at the repair designer
Currently, the FAA is evaluating the subject with regard to engine critical parts; change of the FAA system might take place in future.
Language of approvals and documentation of repairs (Subgroup 5)
Draft Conclusion: for mutually acceptable repairs the English language should be required
Approval Sheet(Subgroup 5)
Status: most of the changes proposed up to now are editorial. The minimum data to accept a repair (reference to TC, STC, limitations etc.) have to be filled in
Action: AECMA agreement, to be provided
1. Next meeting in the United States July 14-18
2. Final meeting in the United Kingdom July 28-29
3. Report to be submitted End of August 2003