International Acceptance of Repair Data Approval:

1. International Acceptance of Repair Data Approval: Industry Proposal Web Heath Boeing

2. International Acceptance of Repair Data Approval Agenda • Background • Responsibilities • Issues • Proposal

3. International Acceptance of Repair Data Approval Background: • Repairs to aircraft are inevitable even the Wright Brothers had to make repairs. • We have been dealing with repairs for almost 100 years. • We are global, mature, simple things are not always simple anymore. • Technically and physically – it has been successful • Regulatory wise - its been unsuccessful # inefficient # bureaucratic

4. International Acceptance of Repair Data Approval Responsibilities Airlines • Maintain airworthy aircraft that conform to type design • Develop a process for determining major/minor repair • Develop approved and acceptable repair data • Obtain authority approval major repair data. OEM • Provide Continued Airworthiness support of his fleet • Provides various document i.e. SRM, AMM, IPC etc • Provides repair data development support. • Approves data through his Approved Designee System Authority • Assure continued airworthiness of operational fleet • Have safety regulations and guidance material, policy etc. • Issue Type, Production and Airline Operating Certificates • Utilize Designee System to make finding s of compliance. • Perform surveillance/ oversight

5. International Acceptance of Repair Data Approval Issues: Over the years many issues associated with approval of repair data have occurred and it still happening today. Examples: • One Authority was not going to allow its designees to work on foreign registered aircraft • Field inspectors second guessing the determination of major/minor even after approving the process • Two levels of approval being required, one from the state of design and the other from state of registry. • State of registry not accepting the designee system of the state of design even when they have been accepted via the bilateral. . • Requiring one state of design designee system to have regulatory training in another states regulations before allowing sign off of compliance.

6. International Acceptance of Repair Data Approval Issues (continued) • Repair which meets one authority requirements but the accepting authority will not accept the other authority approval. • A major repair is defined and interpreted differently between authorities. • There are different delegation system between authorities.

7. International Acceptance of Repair Data Approval Impact of Support Effort by the OEM: • Repair Data Request/year – 110,000 plus • Percentage US – 50% • Percentage non – US – 50% • Average man-hours spent /request 8 to 10 hrs • Support Staff range from 7 to 300 • Estimate of major repairs that could be classified as minor 85 to 90 %

8. International Acceptance of Repair Data Approval Observation: This reminds me of the situation that existed in the early 1990s regarding acceptance and movement of replacement parts/appliances. This situation resulted in the development and approval of the FAA 8130-3, JAA Form –1 and TCCA 240078..

9. International Acceptance of Repair Data Approval Proposal: Define Major Repair as: Major Repair: (1)A repair that if the results on the approved type design has an appreciable effect on structural performance, weight, balance, system, operation characteristics or other characteristics affecting the airworthiness of the product, part or appliance. or (2)That cannot be accomplished according to accepted practices or be by elementary operations.

10. International Acceptance of Repair Data Approval Proposal (continued) Major Repair Guidance Material: In line with the definition of “major repair”, a repair that if the result on the approved type design has an appreciable effect on structural performance, weight, balance, system, operational characteristics or other characteristics affecting the airworthiness of the product, part or appliance. A repair is classified as a “major repair if it needs extensive static, fatigue and damage tolerance strength justification and /or testing in its own right or if it needs methods, techniques of practices that are unusual (i.e.unusual material selection, heat treatment, material processes etc). A Repair that requires a reassessment and re-evaluation of the original substantiation data to ensure that the aircraft still complies with the type design .

11. International Acceptance of Repair Data Approval Proposal (continued) AIA, has agreed to establish an industry project to develop a complete draft NPRM/NPA (including the preamble, rule text, cost benefit information etc) starting with something like what is proposed. We would have other interested parties participate including the authorities. Once this draft rule package was complete we would submit to the authorities as a petition for rule making.