Category: Issue Highlights

I get a lot of questions about the FAA’s requirements for aircraft parts traceability. And one of the first things I remind people of, when they ask, is that there is no general requirement under FAA regulations for aircraft parts traceability.

None. Yes, there are requirements for certain parties to prepare or maintain certain documents under U.S. law. For example, when any authorized party completes maintenance, they must complete a record of that work under 14 C.F.R. § 43.9. When a repair station completes a major alteration, it must complete a FAA Form 337. If that same repair station completes a major repair, then it must either complete a FAA Form 337, or else must place the maintenance release language found in the regulations on the work order (and return that work order to the client).

Those who remove life-limited aircraft parts from aircraft are required to engage in safe disposition of those parts, which can include documenting the current life status of the part, but this obligation can also be met through other non-document-based solutions. Operators are required to retain certain records. Records of major repairs must be retained for a year (or until superseded) while records of major alterations must be retained for the life of the product.

But in all of these requirements, there is no requirement under U.S. law that ANY document follow the aircraft parts from one owner to the next. This is a surprising revelation to most people in the aviation industry, who are used to the idea that an aircraft part cannot be purchased without “the right traceability.”

The idea of treating documentation of aircraft parts differently from documentation of complete aircraft is not a novel one. In FAA Registry cases, for example, the courts have recognized that the way that the law treats documentation of complete aircraft is different from the way that the law treats documentation of aircraft parts.

At this point, most of my readers will be thinking “well, Mr. Smarty-Pants Lawyer, if there is no legal requirement for aircraft parts traceability, then why do all of my customers as for traceability?”

The answer is, because of commercial practice. Let’s take life-limited parts as an example. Even though most people think that back-to-birth traceability is mandatory for such parts, the FAA has repeatedly said that U.S. law does not require back-to-birth traceability – not even for life-limited parts. A record of current life status is sufficient to meet the regulatory obligations of the operator. The FAA Chief Counsel’s Office has issued multiple opinion letters on the subject., But just try to sell a life-limited part without back-to-birth traceability! The marketplace has deemed that this is the “appropriate” paperwork for life-limited parts, and so commercial practice has evolved such that this form of traceability is a de facto requirement for U.S. transactions in life-limited parts. If you think about the commercial utility of such traceability, then its value becomes apparent. Life-limited parts are the parts that engineering analysis has shown to need to be removed from the aircraft before a likelihood of failure begins to be realistic. The life-limit is a known safe point, before which failure from fatigue or other related causes is unlikely. Thus, ensuring that a part has not yet reached its life limit is an important safety obligation. It is so important that installers wish to be able to review the paperwork to validate the allegations of current life status found in the records of current life status.

Thus, it has become a commercial norm to ask for back-to-birth traceability in order to have the documentation that validates the allegation of current life status.

In the 1990s, there was tremendous debate about unapproved parts. Ensuring that aircraft parts were manufactured under FAA production approval (or under a legally acceptable alternative) became an important goal for many in the 1990s. As a consequence, documentation supporting the contention that the part is an “approved” part became more transactionally important in the 1990s.

There is no one piece of paper that is always appropriate in every case. Often, an airworthiness approval tag (8130-3 tag) is a very reliable document asserting approval and airworthiness, because it cannot be issued under today’s standards without a finding that the part in question was produced under FAA production approval. And yet it is important for installers to recognize that the airworthiness approval tag tells you that the parts was an airworthy, approved, part at the time that the document was issued. It does not tell you whether the part is still airworthy (It could have been damaged or suffered degradation since the airworthiness approval tag was issued) and that is why the installer continues to play an important role in assessing current status of parts.

The installer’s role in assessing parts is another commercial driver for traceability. The installer of a part has an obligation to make a determination of airworthiness under Part 43 of the regulations (find that the part will return the product to a condition at least equal to original or properly altered condition), but it is common to rely on documents to help make that determination. Traceability, is thus an important tool to assist the installer in making the installer’s regulatorily-required findings.

So what does this tell us about the “right” traceability? It is whatever the installer feels is useful to help determine the quality and nature of the part. If the part can be discerned as an “approved part” based on part markings (e.g. TSOA markings or PMA markings) then these markings might be just as useful to an installer as paperwork would be. In other cases, manufacturer’s packaging might yield evidence of source. In still yet other cases, there might be nothing more than a certificate from an airline verifying that the part is a new surplus part. Do you have to rely on such documentation? NO! Are you allowed to rely on this documentation? YES (as long as it is trustworthy)!

And this is the real trick with traceability.

Certain documentation is deemed to be inherently more trustworthy than other documentation by the marketplace (remember the regulations do not describe appropriate nor inappropriate traceability documentation). Sometimes there will clearly be a “right” document. When exporting aircraft parts from the United States to Europe, for example, an 8130-3 is the “right” document according to the existing US-EU guidance.

And because the 8130-3 tag is issued by the FAA, that document has been considered to be an acceptable document for many other transactions. But if you are receiving a new surplus expendable, any document that you trust to validate that the part is really a genuine article that remains unused is sufficient. So, for example, an airline certificate verifying that the part was received new, and remains unused at the time of sale may be sufficient documentation of new status for many purchasers.

For aircraft parts distributors, this lack of uniformity creates a potential nightmare: every repair station and every air carrier could have different standards for what they will accept (and many do have divergent standards for acceptance). The FAA recognized this issue, and as a consequence the FAA published recommended guidance for what the FAA believes to be acceptable documentation in FAA Advisory Circular (AC) 00-56A.

AC 00-56A was created by the FAA in partnership with the manufacturing, air carrier, repair station and distribution communities. It provides reasonable standards for documentation: the documentation should identify the part and it should identify the part’s condition.

It does not require documentation that does not add value (and some commercial documentation matrices do seem to seek non-value-added documentation). Remember, AC 00-56A is not the law – it is merely guidance; but it is generally acknowledged as the starting point for any traceability list developed to discern appropriate documentation upon receiving inspection and upon subsequent transfer of an aircraft part.

AC 00-56A is available on the FAA’s website. The documentation matrix from AC 00-56A is also reproduced in the ASA- 100 standard, which is available at www.aviationsuppliers.org.

Rosetta Stone has announced a new agreement with the International Air Transport Association (IATA) that means employees in the aviation industry will have the opportunity to learn a new language and develop their communication skills as part of a wide-ranging career development program administered by the IATA Training and Development Institute (ITDI).

The program gives ITDI students access to groundbreaking software solutions from Rosetta Stone, the global leader in language-learning technology for schools, businesses and individuals. The company’s TOTALe PRO solution—recently expanded to include mobile applications, live online tutoring with native speakers and group-based interactive learning games—is available in more than 20 languages. The Rosetta Stone partnership marks the first time language training has been offered through IATA’s training curriculum, which already features classroom and distance learning in aviation administration, security, tourism, safety and many other subjects.

This year, over three billion passengers will crisscross the world aboard flights served by 8.4 million aviation industry workers. IATA represents member airlines and interacts with people at every touch-point of the aviation supply chain. Given the aviation industry’s global breadth, multilingualism has become a key area for employee development, compliance and competitiveness.

“If ever there was a truly global industry, aviation is it,” said Judy Verses, president, Global Institutions at Rosetta Stone. “Being able to communicate across borders and cultures is a vital skill for global organizations.”

The ITDI client base is drawn from the employees of 240 member airlines. Participants who successfully complete Level 3 and Level 5 of Rosetta Stone TOTALe PRO as part of ITDI’s curriculum will earn certificates reflecting their language proficiency.

“Airlines and supply companies serving the global aviation industry may operate in dozens of different countries,” said Ismail Albaidhani, head of Global Partnership & Learning Innovation and interim head, ITDI. “Language and communications skills are critical. This partnership with Rosetta Stone will enable us to better serve the education and training needs of the industry.”

While Rosetta Stone counts many international airlines and airports among its customers, the agreement with IATA marks the company’s broadest foray yet into the aviation industry.

Tips on how to make minor repairs to new basecoat/clearcoat paint finishes.

As you read in Dave Jensen’s story New Promise in Paint, which appeared in our (see Aviation Maintenance, April/May 2012) issue, the aviation industry has pretty much switched from the old lead-based primers and single-stage top coats to a much more environmentally-friendly generation of basecoat/clearcoat (BC/CC) finishes.

According to the various manufacturers, these new BC/CC paints offer a variety of benefits beyond their safety: they dry faster, have a greater resistance to wear, provide a much wider range of colors and, they also offer, what promises to be a much longer life on the aircraft. And while they’re better, they’re not ‘bulletproof.’

“Even the most durable, high-quality aerospace coating system will require thorough inspections and regular maintenance,” explained Julie Voisin, product manager, Sherwin-Williams Aerospace Coatings. “Today’s latest coatings are far easier to maintain and repair. The clearcoat also makes the aircraft’s surface easier to clean than traditional single-stage coatings.”

Ms. Voisin also stated repairs to minor blemishes in the clearcoat are especially easy. “Repairs can be as simple as buffing just the clearcoat or a localized section of the basecoat section,” she said. “In addition, the shortened processing time, (up to 30-percent off traditional coating processing times) means aircraft will spend less time in the maintenance hangar.”

This Isn’t Your Father’s Oldsmobile… “Aviation is now kind of catching up to where automotive paint technology has been for over 20-years,” added Joseph Wood, North American business director, Liquid Industrial Coatings Group, Axalta Coating Systems (formerly DuPont Performance Coatings). “These new paints and coatings offer many benefits, but they also require a stricter adherence to procedures. Mainly because they have less solvents and a higher solids content.”

“We’re constantly working to enhance the application ‘robustness’ of these new finishes,” he said. “By robustness, I mean the ease of application, where if you follow a certain set of parameters you’ll get a consistent finish, cure and film properties.”

In fact, following processes and procedures is so critical to achieving the level of finish quality today’s customer demands that Embry-Riddle Aeronautical University and the Society of Protective Coatings have joined to create the industry’s first Certification for Coatings Application (see sidebar).

“We have a rule-of-thumb, that states if you are going to paint anything bigger than a dollar bill, you really need to do it in the right facility and environment to do it correctly,” Wood said. “You need to be precise in your measurement of the materials. Precise in the equipment you are using. You need the correct ventilation and air flow.”

“Remember that a lot of these new paints have modular components based on their application conditions. The size of the panel to be painted, ambient air temperature, air flow – all these kinds of things,” he said. “Really, if you’re going to paint an eight-inch square, you going to want to use a different solvent than if you’re going to paint the entire wing or airplane.”

Paint Repair 101 Wood said that today’s BC/CC coatings are a lot easier to repair than the old finishes and that you can definitely use today’s paint with the old paints. “It’s not going to crater or fish-eye massively or anything like that,” he said. “That old paint has long cured enough so that won’t be a problem.”

However, Wood stressed that you would need to follow the paint manufacturer’s published procedures and processes, including the appropriate pre-treatment steps to the letter. “I’ve seen more mistakes caused by people being in a hurry than anything,” Wood warned. “If they would just slow down a bit on the front side and make sure everything is correct before they actually mix the paint.”

Ed Mullins, technical specialist, Aerospace Coatings, PPG Aerospace stated that a good rule-of-thumb is to start with a checklist. “Best practices within the paint industry always lead back to the cleanliness of the substrate,” he said. “A good clean substrate provides a solid foundation for good paint application.”

He also suggested that technicians take full advantage of the information available to them on the Internet. “There’s much more good information available now than in past years,” he said. “It’s always best to stop when a question or concern arises and refer to the information that is available. That often leads to an answer that eliminates a costly mistake.”

And when you are doing your research, remember that, unlike a single-stage paint, you’re dealing with a BC/CC finish so you may have repair options and the Internet is a good place to search them out.

For example, if, like on your car’s finish, you see a white mark on one of the color areas, you may be only looking at damage to the clearcoat. In fact, clearcoat is very tough and there are multiple mills of it on top of the basecoat. “Repairs can be as simple as buffing the clearcoat or a localized section of the basecoat scheme,” Ms. Voisin said.

Sherwin-Williams has a really good video on repairing minor surface damage/blemishes on YouTube: (www.youtube.com/watch?v=AifGkQ87HJA) `“The only caveat on buffing is you really need to get in tune with your supplier of these types of materials,” Wood stated. “They have really changed a lot in the past few years – not only the compounds but also the technology of the pads and equipment. They’re really more designed for today’s paint coatings.”

Sometimes the clearcoat itself is damaged to the extent where you will need to respray. “You can do some of what I call ‘blending of clearcoats,’” he explained, “but I tell technicians all the time if you can get a clean panel-break and you can tape off the panel, then go ahead and respray the entire panel. You’ll get a much better repair.”

So what if you know that the damage goes down to the base color coat or even to the structure below? Again, the right repair is tied to the severity of the damage. If the scratch goes all the way to the metal or composite, it’s a totally different, and much more involved process. “A very simplified version of a repair would look like this:” Mullins explained. “Ensure the area is clean and remove all the color on the defect. From that point the repair can either be blended with a blending solvent or cleared then blended.”

“In many cases,” he added, “the area is then lightly polished to remove any overspray, being very careful not to damage the new repair.” Wood also suggested that even if you do a spot fix to the color that you clearcoat the entire panel. “That’s going to give you the highest durability and it going to wear at the same rate as the rest of the aircraft’s finish,” he said.

Ready, Aim… While a complete understanding of the exact chemistry of the primer and BC/CC is critical to achieving the high-level of quality you want, Wood also stressed that you have to use the right type of spray gun.

“The latest achievements and improvements in spray gun technologies have been tremendous,” he said. “If you think back to the ‘70’s and the old Binks model 7 syphon spray gun you’re missing a lot in what today’s sprayers can do.”

“Today probably 95-percent of repairs are done with a new gravity-feed type gun. This works so much better with the high-solids paints because you are not using energy to pull the paint up then trying to atomize it,” Wood explained. “It minimizes overspray, minimizes consumption and still gives you a great finish – especially on smaller, touch-up repairs.”

“There have also been big advancements in the paint cup itself,” he added. “Several companies now offer disposable liner cups so you don’t have to waste time and chemicals to wash the cups and it takes a lot less solvent to clean the guns.”

Interiors Need Help Too Of course with all the wear and tear that interiors suffer, sooner than later you’re going to have to do some paint touch-ups on the inside. AkzoNobel recently introduced its Dab2Fix (www.anac.com/Brochures/AkzoNobel_Aerofine_Dab2Fix.pdf ) paint application system created for quick interior paint repairs.

According to the company, the system “allows controlled application to interior surfaces, correcting surface damage in a simple and effective way. The sponge applicator ensures areas can receive a touch-up repair to maintain the overall appearance of the aircraft interior.”

StandardAero is First MRO to Complete ERAU/SSPC’s New Aerospace Coatings Application Certification As paints and their proper application requirements become more sophisticated, so must the training that aircraft painters receive to do the job properly. “Historically, learning how to paint has been primarily on-the-job type training,” explained Mike Menard, VP/GM, StardardAero’s Springfield Completions Center. “A lot of ‘tribal knowledge’ was passed along, but there was no consistent baseline or body of knowledge.”

To ensure that its customers are getting the best quality of work possible, when Menard heard about the Aerospace Coatings Application (www.sspc.org/ACAS/) certification programing being offered as a joint venture between Embry-Riddle Aeronautical University and the Society for Protective Coatings (SSPC), the StandardAero team wanted to be the first MRO to take advantage of the certification training.

“The program is great. It offers technicians a good theoretical base on which to build their craft and that translates into a better result for our customers,” Menard said. “That theoretical knowledge is often what’s missing from OJT – you know what needs to be done but you don’t know why. Knowing why is more important today than ever.”

“For example, any painter worth their salt will tell you that proper surface cleaning and preparation is critical,” he added. “But they really don’t know why. What are the things at the chemical level that make it work or not work? This certification creates a much better, more consistent foundation for our craftsmen.”

The ERAU/SSPC certification program consists of six training modules that are completed by the technician online. Menard said that it takes about six-weeks for a working painter to complete that part of the training.

“For the final exam an Embry-Riddle instructor came to the shop to see each technician put his or her knowledge into practice,” he said. “You have to prep and paint a piece of aluminum using the proper technical data sheets and you have to know why you are doing each step.”

“Going through the course doesn’t make you a painter, it just gives you the understanding of what you are doing and why you are doing it,” Menard said. “Now they know why humidity is important and why it matters what order you mix the two-part paints. They now know how each little part comes together to make a better paint job.”

Menard said that it also helps make for better moral among its employees. “It’s been a good way to challenge our painters. They use the same techniques they always have, but now they have a clear understanding of how it all works,” he said. “We’re investing in our employees’ futures. They are true craftsmen. We’re just providing them with a better foundation.”

And as we all know, when it comes to painting, the better the foundation, the better the finished product.

Bombardier Aerospace recently announced that after a very successful launch last year, Safety Standdown Latin America is returning to Brazil for a second edition of the seminar. The seminar is scheduled to be held on Wednesday, August 10, at the Grand Hyatt Sa?o Paulo Hotel on the eve of the opening of the eighth annual Latin American Business Aviation Conference and Exhibition (LABACE). Held in Wichita (Kansas), Geneva (Switzerland) and for a first time this year in Shanghai (China), Safety Standdown returns to Brazil, a key market for the development of business aviation. “The Latin American business aviation market is very dynamic and LABACE provides us with the perfect venue to share the principles of Safety Standdown with a wide audience of professional aviators,” said Steve Ridolfi, president, Bombardier Business Aircraft.

The ExecuJet Aviation Group has gained Authorized Service Center (ASC) status from Hawker Beechcraft (HBC) at six of its worldwide MRO facilities – Lanseria and Cape Town, South Africa; Dubai, UAE; Melbourne and Sydney, Australia; and Lagos, Nigeria. The company will provide line and base maintenance on HBC’s current line of Hawker series products, including the Hawker 4000, Hawker 900XP, Hawker 750 and Hawker 400XP. Other ExecuJet locations will be considered for representation as the mutual need arises. ExecuJet has recently added a number of engineering staff to support its enhanced contract with HBC. “We are delighted to expand our relationship with Hawker Beechcraft and be recognised as a full service center in Africa, Australia and Dubai,” said Graeme Duckworth, ExecuJet group maintenance director. ExecuJet Dubai also recently obtained extension to their EASA and GCAA Line and Base Approvals in support of the Hawker 400XP, 125 Series and 4000 aircraft.  The maintenance facility has trebled its capacity with the addition of a new hangar and now employs a team of over 135 maintenance staff.

BY JOY FINNEGAN, EDITOR-IN-CHIEF

I’ve come full circle as they say. I was a part of this publication for about six years, first as managing editor and then as editor-in-chief. When the magazine’s previous ownership sold Aviation Maintenance to the new owner, the previous media company kept me on and gave me the opportunity to take the helm of Rotor & Wing magazine. I did that and had a blast.

But on numerous occasions I looked over at Aviation Maintenance beginning to thrive under the new management and thought, if only I could have stayed with it. I missed covering the maintenance, service and support sector. I missed the people I had covered in the business jet world, the commercial sector and the GA area. Well, lo and behold, the universe shifted. I relocated to Florida, requiring me to resign my position at Rotor & Wing. Next, the previous editor here got an offer he couldn’t refuse. And then, I got a call — Aviation Maintenance was looking for an editor! Sometimes life just works out, doesn’t it? I’m thrilled to be back and the June/July issue is a great way to kick off my second go around with AVM.

We have some great feature stories this month including a look at how some of the premiere maintenance companies are using Lean, even in the high variability world of aircraft, engine and avionics maintenance (see Leveraging Lean, page 18). We also look at maintenance software and asked as many aviation maintenance software companies as we could to tell us what they have to offer (see Harnessing the Power of Aviation Maintenance Software, page 28). We introduce you to Kelly Reich, Cessna’s new vice president of product support for Customer Service (page 34). David Schober offers some caveats for maintainers considering working on light sport aircraft (page 38). We also have a new regular column from the new president of the Professional Aviation Maintenance Association (PAMA), Dale Forton (page 50) and a new regular column in the Intelligence section called Mx Reg Log, which will take a look at regulatory news around the world. I hope you enjoy the issue.

I also want to take this opportunity to tell you about our International PMA Summit being held in London on November 3 and 4. This is the first major PMA conference based in Europe and we are delighted to be working with the Modification and Replacement Parts Association (MARPA) to bring information about PMA parts to Europe. Some in the United States and elsewhere are embracing the use of PMA parts. For anyone wanting to learn more about their development, quality, potential savings, delivery availability and to debunk any myths, please consider attending this conference. We will have PMA experts and leaders, regulatory representatives and users who can speak with experience and have the facts and figures to back up what they say about the use of PMA parts. We are currently offering a 20 percent discount on the attendance fee for all airline personnel and MARPA members. If you are considering using PMA parts, please attend and learn so that you can make a confident decision. We would love to see you there. For more information go to http://www.avmain- mag/pma-summit.

One last thought before I close. Recently, while attending the MRO show in April, I heard one of the keynote speakers make a comment that struck me as just plain wrong. The speaker, a noted expert, said that the aviation maintenance business is moving away from “relationship-based business” and towards “performance-based business.”

Now, I can certainly understand that businesses must make decisions based on performance. That is undisputed. But I completely disagree that this business, the aviation maintenance industry, will ever disregard relationships when considering where to take their business. There is one thing that lies at the very foundation of all of aviation, and in particular the maintenance world, and that one thing is relationships. One bad experience with a service provider is enough to convince a client to never bring their aircraft to that particular provider or location again. That will never go away.

The businesses that have worked hard to build relationships with their clients, who know their clients needs and concerns and address them regularly, will always come out on top. Those will be the companies that survive the cyclical, and sometimes volatile, business cycles that aviation is known for and has experienced recently. If aviation maintenance businesses ignore their relationships and follow on the expert’s advice to focus solely on performance, I predict those businesses won’t do nearly as well. Those that think having the lowest price or shortest turnaround time, regardless of quality, safety and reliability, will bring them out on top, will be sorely mistaken. Having trust in your maintenance provider is crucial. If the provider calls and says your aircraft is ready, but you show up and find the cowlings on the hangar floor, or fly away only to have the same warning light glaring in the cockpit, the “performance” issue goes out the door. Relationships and trust are the very core of this business. It is one of the reasons I am so happy to be back covering it. MORE ONLINE

This month we introduce a new column by the new president of the Professional Aviation Maintenance Association, Dale Forton. — Ed.

DALE FORTON has worked in aviation for more than 32 years and as a licensed A&P Technician has been an active PAMA member for more than 26 of those years. For the past seven years he has served on the PAMA Board of Directors as vice chairman of the Board of Directors, Great Lakes Regional Director, Membership Committee Chairman, Governance Committee Chairman, and Strategic Planning Committee Chairman. Formerly a director of maintenance for 135,145, and 147 operations, he has also held positions as service manager, parts manager, technician, and director of product support. Dale has owned his own businesses as well.

BY DALE FORTON

I am honored to have been recently appointed as president of the Professional Aviation Maintenance Association (PAMA). As a member of PAMA for over 25 years I have watched the organization go through some pains in the past. There are those in the industry who have not heard from PAMA recently, is not for the lack of growth. It is that PAMA has been refining its message. I, as the spokesperson, have been directed to deliver it to the industry. Following I want to address some of the past history as well as the future direction of PAMA and how you can be a part of it. As the only non-profit organization representing aviation maintenance technicians at present, you can help your industry and profession continue to grow.

Another big item on PAMA’s agenda is the upcoming annual Symposium, the Great Lakes Aviation Symposium, which will be held at the birthplace of aviation, Dayton Ohio on September 29th and 30th. This symposium follows up our very successful symposium last fall with the theme of professional development. The symposium is constructed to educate AMT’s from a management perspective enabling the individual AMT to enhance their career. In addition to the professional development classes offered at our regional symposiums, remember to watch for our chapter’s IA renewals in your area. More information and registration for the upcoming symposium can be found at www.PAMA.org.

A top priority of mine is to increase communication to our members, chapters, and the industry. Under this initiative we have completed a new chapter handbook to allow formation of more chapters as well as a social media presence on Facebook, Linkedin, and Twitter to allow for more direct communication on industry issues. Our technical committee has been actively utilizing these resources for their discussions on current industry topics, for example, duty time.

In addition to our technical committee, several of our other committees are marching onward with new PAMA initiatives as well like our education, membership, and awards committees. If you have an interest in joining the many others who work with PAMA please contact me. As the only non-profit organization representing AMTs, we long ago set up the only Professional Aviation Maintenance Foundation (PAMF) to handle any scholarship donations we receive. The PAMF has several scholarships available for students and AMTs to start or enhance their careers.

Finally I would like to thank Aviation Maintenance and Joy Finnegan for their constant support of PAMA and its members for many years! For all the AMTs out there looking for a resource, an advocate, and a promoter of your industry, join forces with the many others who look to PAMA as an association who will help you in all you do to keep the lives you are responsible for safe!  MORE ONLINE

By Jason Dickstein

Welcome to a bold new era of aerospace transactions between Europe and the United States. The United States and the European Community (EC) have signed a new Bilateral Aviation Safety Agreement (BASA) that replaces existing agreements between the U.S. and certain European nations and replaces it with an agreement that spans the entire European Community. Prior to the new agreement, the U.S. had several agreements with EC member nations, and other nations accepted U.S. -sourced aircraft parts as if they were also parties to those agreements. This new BASA clarifies the legal status of transactions that occur between the majority of the EC and the United States.

In some cases, the new agreement will make no changes to the status quo. For some categories, it may reflect some minor changes in the way that companies do business. Purchasers in both the U.S. and in Europe need to be aware of the requirements mandated by the new agreement. Before installing any part that was imported from the U.S. or Europe, installers need to confirm that the part complies with the rules established by the agreement, as well as the domestic airworthiness rules that apply to the aircraft based on country of registry.

Requirements for Parts Imported Into the U. S. What should you expect if you are located in the U.S. and buying parts made under European production authority? You should expect to see an EASA Form One with the part or product. In some cases, where an EASA Form One is mentioned, it is also possible to see a JAA Form One if the article was tagged before the change-over to EASA Form One. Previously, the U.S. had not agreed to accept EASA Form Ones issued in any nation other than the six original BASA nations in Europe, although normal practice dictated that other EASA Form Ones would be accepted for airworthiness certification when issued elsewhere. The new standard extends privileges across the European Community, although it is important to look at the details because different European nations may have subtly different requirements. For example, Romania has authority to export sail planes and very light aircraft to the U.S. (and the U.S. would accept the EASA certifications for such aircraft) but not to export transport category aircraft to the U.S. (that is, the U.S. would not be obliged to accept the airworthiness documentation for such an airplane from Romania).

Where the U.S. accepts an EASA Form One, it will also usually accept a JAA Form One that was issued before September 28, 2005. For any new aircraft there will be an EASA Form 27 certificate for the aircraft. For any new aircraft engine or propeller there will be an EASA Form One certificate on the engine or propeller. This certificate verifies conformity to approved design as well as verifying that the product is in a condition for safe operation (including compliance with all airworthiness directives).  All new aircraft engines and propellers shall have an EASA Form One attached with the following statement: “The [INSERT Aircraft Engine or Propeller Model] covered by this certificate conforms to the type designs approved under U.S. Type Certificate Number [INSERT TYPE CERTIFICATE NUMBER and REVISION LEVEL], is found to be in a condition for safe operation and has undergone a final operational check.” MORE ONLINE

BY STAFF SGT. JOE ARMAS 1ST ACB, 1ST CAV. DIV. PAO
CAMP MARMAL, Afghanistan

It’s full speed ahead for the soldiers of the 1st Air Cavalry Brigade, 1st Cavalry Division as the brigade’s aircraft roll into theater. It is the duty of the brigade’s aircraft maintainers and maintenance test pilots to ensure the aircraft are fully mission capable and safe for the pilots who will take the machines into combat. The process started late last month, as the first batch of helicopters began arriving in country. “It [the maintenance buildup process] starts from the time the aircraft is downloaded and transported to the area where the majority of the initial maintenance is conducted,” says Chief Warrant Officer 5 Cliff Mead, the brigade’s aviation maintenance officer, originally from Redding, Calif. “Then, an initial assessment of the aircraft is made, and the build crews proceed with the initial maintenance,” says Mead. Extra precautions while moving the aircraft are a must otherwise damage to the aircraft or injury to personnel is possible. Depending on the aircraft, the maintenance can be relatively simple or in the case of the CH-47F Chinook helicopter, it can require extensive time and effort. The rigging process on a Chinook, for example, can be complex and time consuming. As for the maintainers, they each have military occupation specialties that normally bind them to one specific airframe, whether that airframe is a CH-47F Chinook, UH-60L Black Hawk, or an AH-64D Apache, according to Staff Sgt. James Wilson, section sergeant, Company B, 615th Aviation Support Battalion, 1st ACB, originally from Yorba Linda, Calif. With a time crunch that is mission critical, the maintainers have taken a flexible approach to their tasking. They’ve come together as a team to assemble and perform scheduled and unscheduled aircraft maintenance regardless of airframe affiliation. “It’s one team, one fight at this point,” said Wilson. “The goal is for the ground commanders to never notice any transition,” said Mead. “The same level of support they get today from the 4th Combat Aviation

Brigade [the outgoing unit] should be the same that they receive tomorrow from the 1st ACB.” Wilson points out that the less-experienced soldiers in the brigade reap the benefits of being part of the build teams. “We have a lot of young soldiers out here who are relatively new to the Army and they have been doing an outstanding job to this point,” he said. “Everyone is constantly learning and improving their craft.” One of those young soldiers is Pfc. Abraham Xiong, assigned to Company D, Task Force Lobos, 1st ACB, originally from Minneapolis. Xiong, who is an AH-64D Apache helicopter mechanic, said that he relishes the opportunity to work on different airframes and expand his knowledge about overall aircraft maintenance. “Everyone seems to have a positive attitude out here,” he said. “It’s been great working with different people and learning about the different airframes in our brigade,” he said. As the maintainers conclude their initial tasks, the baton is then passed to the maintenance test pilots, who take to the skies to ensure proper functionality of the aircraft prior to releasing the aircraft back to their assigned line units within the brigade. Xiong, who is on his first deployment, touched on what he sees as the overall big picture in reference to the work he has done along with his fellow maintainers. “When these aircraft come back from missions, to see what they do…saving lives and taking the fight to the enemy, it feels good to know that we’ll contribute in some form to their overall success,” he said. MORE ONLINE

BY: DAVID SCHOBER

When the FAA enacted the “Light Sport Rule” in September of 2004, they established rules for new aircraft definitions. While the Light Sport rule breaks down these new aircraft into category and classes, this article will break them into “Special” and “Experimental” and the impact on mechanics and the limitations imposed on maintainers. The maintenance that can be performed, and the level of certification and training of the individual performing that maintenance, is controlled by the Aircraft Manufacturer and the Operating Limitations issued with these airworthiness certificate.

The Light Sport rule allows for “Special Light Sport Aircraft” (SLSA) , and “Experimental Light Sport Aircraft” (ELSA). The “Experimental Light Sport” has the least restrictive maintenance provisions. As with some of the other types of experimental certificates, 14 CFR 43 doesn’t apply. Within the experimental versions of light sport aircraft, pretty much anything goes and all that needs to be done is an annual condition inspection (with the exception of those being used for flight training). The condition inspections may be performed by an appropriately rated mechanic or a repairman with a light sport inspection rating. If being operated for hire (only applicable to aircraft converted from “heavy ultralights”), the inspections must be made by an A&P mechanic, repair station with appropriate ratings, or a repairman with a light sport maintenance rating.

For the “Special Light Sport,” maintenance is much more restrictive. Like above, the SLSA is required to have an annual condition inspection, and if being used for hire, a 100-hour inspection. The primary difference is contained in Item Number 6 of their operating limitations. These limitations can be found in FAA Order 8130.2G Item 6 states “Noncompliance with these operating limitations will render the airworthiness certificate invalid. Any change, alteration, or repair not in accordance with the manufacturer’s instruction and approval will render the airworthiness certificate invalid, and the owner of the aircraft must apply for a new airworthiness certificate under the provisions of § 21.191 with appropriate operating limitations before further flight.”

In short, if it isn’t in the aircraft maintenance manual or other approved documents from the AIRCRAFT manufacturer, you can’t do it! This includes repairs and alterations. Remember that there are no FAA Form 337s for these aircraft. When these regulations were being developed, consideration was given to those who would be repairing and inspecting them. The least common denominator is the LSA repairman. A repairman for light sport aircraft with maintenance rating is only required to attend a 120 hour course. As a result, the maintenance items approved for these aircraft are limited to the scope that someone with only 120 hours of training can perform. Some of the manuals have significantly more items listed, but the manual limits the certification level and training required to perform them. §65.85 and §65.87 were amended to say that for SLSA, major repairs and alterations can only be performed and returned to service if the manufacturer authorizes these repairs and alterations. It also eliminates the ability to supervise someone else performing these functions. Keep in mind that the aircraft manufacturer controls the design and who can maintain it. FAA merely accepts this.

Some of the new LSA aircraft being developed are equipped with type certified engines or propellers. This brings about an interesting regulatory dilemma. Airworthiness Directives are not issued against light sport aircraft, yet TC’d products may be installed in them. If an AD is issued against the engine installed in an SLSA, we as mechanics aren’t authorized to perform
the tasks or inspections required by the AD until the aircraft manufacturer adds the content of the AD to the maintenance documentation, yet operation of aircraft with the TC’d product not in compliance with an AD is a violation of Part 39. MORE ONLINE