FAA’s revamped administrative requirements for air carriers that contract out maintenance is being finalized and should be published by mid-year, the FAA’s Maintenance Division chief reports.
The contract maintenance notice of proposed rulemaking (NPRM), issued in November 2012, calls for Part 121 and some Part 135 operators to tailor their manuals to better suit contractors, rather than legacy in-house operations. Operators also will be required to keep updated, more detailed “approved vendor lists” (AVLs), including physical locations and the type of work that contractors are doing.
These requirements will form the final rule’s foundation, confirms Aircraft Maintenance Division Manager Steve Douglas, who earlier this month told MRO Americas attendees that the final rule is on track for release around mid-year.
The rulemaking addresses recommendations from the Department of Transportation’s Inspector General (IG) aimed at helping FAA improve oversight of third-party maintenance providers, and establishing standards that give providers more specific instructions. Congress mandated the rule as part of the FAA Modernization and Reform Act of 2012, giving the agency a deadline of February 2015.
Several IG reports during the past decade studying the increase in outsourced maintenance noted that some carriers have not adapted their manuals or processes to account for the outsourcing shift. In other cases, maintenance manuals may be clear, but carriers and repair stations don’t have separate agreements that cover basic policies and procedures, such as who is responsible for calibrating tooling.
Douglas notes that while the NPRM does not reference related advisory material, FAA urges operators to follow guidance provided in Advisory Circular 120-106, which covers recommended content in a contract maintenance agreement.
IG also found that FAA does not have a clear picture of where operators are sending their work. As a result the draft rule calls for operators to update the new, more detailed AVLs monthly, and Douglas says that the final rule will include the requirement. Under current regulations, operators must keep lists, but do not have to update them.
Douglas also suggested that—as hinted in the draft rule—the vehicle for maintaining and updating the AVLs would be air carrier operations specifications, or opspecs.
Several organizations are concerned with this approach. American Airlines notes in its comments that the current requirements call for the AVL to be included in a manual, so the carrier set up its electronic system to connect its AVL database with its manual system. Re-creating the AVL as part of the opspecs would be duplicative, the carrier notes.
While one of the rule’s primary goals is to ensure contractors are following a clear set of customer-supplied maintenance instructions, several MROs see negative ramifications. MTU says that requiring MROs to follow multiple sets of instructions to do the same work for different carriers “would have a negative effect on safety and efficiency.” Aviation Technical Services expresses similar concern.