Could You Approve Your Own Data?

The FAA is working on a totally new paradigm for oversight that could result in important new privileges for the aviation community. One of the centerpieces of this program could be the opportunity for facilities to approve their own data.

Nearly all maintenance facilities rely on approved data. In the U. S., this can come from a wide variety of sources. Production approval holder maintenance manuals (instructions for continued airworthiness) are based on type design data, which is considered to reflect FAA-approved data.

Supplemental type certificates are sources of approved data. Designated Engineering Representatives (DERs) sign 8110-3 forms in order to document their approval of data on behalf of the FAA. Depending on how you count them, there are dozens of different ways to obtain approved data to support MRO activities.

But every method for achieving approved data relies on the intervention of the FAA at some point in the process. Empirical data has shown that this intervention does not seem to guarantee any uniformity in the process. More than 10 years ago, the Aircraft Electronics Association commissioned Dale Horner to study FAA form 337s filed in Oklahoma City to record major alterations and/or repairs.

After reviewing several hundred of them, he found that only about a third of them were correct. About one third of them were minor repairs or minor alterations that had been mischaracterized as major, and for which the FAA had approved data despite the fact that it was a minor repair or alteration that did not need approved data. And another full third of them were actually major changes in type design that should have been reflected in Supplemental Type Certificates (but were not).

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