Industry has 30 more days to comment on proposed new requirements for air carriers that contract out maintenance, as FAA granted an extension requested by the Regional Air Cargo Carriers Association, which said its members need more time to analyze the proposal.

The proposed rule, issued Nov. 13, 2012, and required by Section 319 of the FAA Modernization and Reform Act of 2011, seeks to have operators that outsource work create more contractor-centric maintenance instructions and include them in their maintenance manuals.

Operators would then be required to provide the relevant parts of their manuals to contractors performing the work. Operators also would be required to keep an updated list of their maintenance contractors.

Despite the extension, published in the Feb. 12 Federal Register, more than a dozen sets of comments were submitted by the original Monday Feb. 11 deadline. Several comments expressed general support of the proposed changes but noted potential unintended consequences.

American Eagle Airlines points out the FAA’s proposal to have operators create policies and procedures for all of their contract repair station partners to follow may be appropriate for airframe maintenance, but could be a challenge at the component shop level.

For instance, requiring component repair stations to follow carrier-specific programs for each item they repair could mean that rotables could not be removed from one carrier’s plane, refurbished and installed on another. “The current method allows for each component repair station to develop and follow their own procedures that include the policies specified by each of their customers to allow for uniformity in the repair station’s work, and interchangeability of components while still providing the oversight desired,” Eagle says.

Compliance Challenges

Repair station Aviation Technical Services (ATS) argues that standardizing repair station procedures should send the FAA in the opposite direction.

While specific, maintenance task-related operator instructions must always be followed, requiring repair stations to follow an operator’s administrative processes creates major compliance challenges for shops with multiple customers.

“Under the current, nonsensical standard, a repair station with 15 air carrier customers must execute 15 different qualification requirements for their [non-destructive inspection] inspectors, 15 programs to track calibrated equipment, 15 methods to receive incoming parts, 15 standards of required inspection items, and so on,” ATS points out.

“The proposed amendment would actually further this faulty approach by initiating additional air carrier requirements that would supersede the repair station’s own FAA-accepted procedures,” it adds.

Several operators expressed concern at FAA’s planned one-year implementation period. UPS said a one-year time line is “unrealistic,” given the operators’ needs to “first agree on what the rule means, establish conditions of acceptability, revise applicable manuals, train personnel and, in some cases, hire additional personnel.” The package carrier suggests a two-year implementation period.

The congressional mandate discussed only Part 121 operators, but FAA’s proposal includes Part 135 operators if their aircraft can have 10 or more seats. Under the law, FAA has three years—or until Feb. 14, 2015—to issue a final rule. The new comment deadline is March 13.