Communication and the 24/7 Alternative Methods of Compliance Process

Presented to:

By:

Date:

Federal AviationAdministrationCommunication

and the 24/7 Alternative Methods of

Compliance Process

Flight Standards Part 121 PI’s

AVS/AFS/AIR

June 2010

Federal AviationAdministration

Communications and 24/7 AMOC Process

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Jim Ballough - Senior Advisor to the Associate Administrator for Aviation Safety

Steve Douglas - Deputy Division Manager, AFS-301A,

Aircraft Maintenance Division

Ken Kerzner - Manager, Air Carrier Branch, AFS-330,

Aircraft Maintenance Division

Phil Forde - Manager, Airframe Branch, ANM-120S, Seattle Aircraft Certification Office

Scott Fung - Senior Engineer, Airframe Branch, ANM-120S, Seattle Aircraft Certification Office

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V 7.03

Introduction

• Background• Communication• AEG Roles and Responsibilities• Alternate Method Of Compliance (AMOC)• “24/7 AMOC Process”• Risk Management Process (RMP)



V 7.04

Purpose

This briefing is about early Communications, AMOCs, and the implementation of the Transport Airplane Directorate’s “24/7” AMOC process; and the Flight Standards Principal Inspectors (PI’s) timeliness in responding to urgent requests for Alternative Methods of Compliance, (AMOCs) for Airworthiness Directives (ADs) during non-duty hours.



V 7.05

Background

• In April 3, 2008, the House Committee on Transportation and Infrastructure conducted a Hearing regarding safety issues at the FAA.

• In March 2008, the FAA initiated an AD audit.– Indicated a 98% compliance rate.– Identified a compliance issue with AD (2006-15-15).

• Resulted in flight cancellations for a large portion of MD-80 fleet.

• The FAA established an AD Compliance Review Team (CRT) to review events that caused a disruption to some airline schedules.



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• Independent Review Team (IRT) established by Secretary of DOT.– Team consisted of 5 aviation industry safety

experts – Tasked to evaluate and make recommendations to

improve• FAA’s implementation of the aviation safety system• FAA’s culture of safety

• The IRT issued their report on September 2, 2008– Identified 13 recommendations related to:

• ADs, Voluntary Disclosure Program, Culture of FAA, Safety Management Systems, Air Transportation Oversight System and the role of FAA Inspectors.


Background



V 7.07

• The AD CRT Reports were formally released in September 2009.– Task 1 Report: AD 2006-15-15 (dated June 3, 2009)

• 5 findings and 4 recommendations

– Task 2 Report: AD process (dated July 8, 2009)• 12 findings and recommendations

• The Reports conclude:– AD processes have worked well.– Technical collaboration between the FAA and industry enhances

ADs and safety.– Fundamental changes are not needed, but there are

opportunities for improvements.


Background



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• The AD CRT findings and recommendations focus on:

– Service Instructions; – Compliance Determinations; – Lead Airline Process (ATA Specification 111); – AD process, compliance planning and implementation; – Mandatory Continuing Airworthiness Information; – Alternative Methods of Compliance (AMOCs); – Crisis communication; – Part 39 regulations; and,– Industry training programs.


Background

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Summary of Recommendations

IRT and AD CRT Recommendations

------- Double Click to Open

Copy included in handouts

Background

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Aviation Rulemaking Committee ARC Sponsor

AVS-1, Peggy Gilligan

ARC Committee

FAA; Original Equipment Manufacturers; Air Carriers; Relevant Industry Associations (e.g. AIA, ATA, etc.)

Service Information

Working Group

AD Development

Working Group

AD Implementation

Working Group

FAA Organization/

Procedures

Working Group

10

Background



V 7.011

Background

Our briefing focuses primarily on two of the recommendations from the AD CRT findings:

• Strengthen the role of the AEG (Communication)– AD CRT, Rec. No 2 & 8

• Alternative Methods of Compliance (AMOCs) – AD CRT, Rec. No 2 & 8



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Communications

AFS/AIR

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Communication

Finding 2:• The AEGs were not playing a significant role in either

the AD review process or the operational suitability determinations

Recommendation 2:• Strengthen the role of the AEG in developing and

implementing ADs• Ensure ASIs know the AEG is a resource in the AD

process• AEGs act as the liaison between CMOs/CHDOs for AD

implementation issues



V 7.014

Finding No 8:• FAA administration of the AMOC process was reported to

be inconsistent and sound technical judgment did not always govern decisions

Recommendation 8:• FAA policymakers must ensure individuals responsible for

the control of the AMOC processes are fully aware of the scope of their responsibilities. Educating individuals will help ensure proper and prompt technical resolution of the problems.

• Staff availability--24/7 basis--(ACOs, AEGs, and CMOs)

Communication



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Communication

Who are the Stakeholders?

• Principal Inspectors (PIs) at the CHDOs

• Aviation Safety Inspectors (ASIs) at the AEGs

• Aviation Safety Engineers (ASEs) at the ACOs

• Managers and Supervisors



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CommunicationAFS-1 Memo, dated March 20, 2009

• The purpose of the memo was to address communications among the Aircraft Evaluation Groups (AEGs), Flight Standards Service (AFS), and the Aircraft Certification Service (AIR)

• The memo clarified, as a member of AFS, the AEGs are responsible for:– Providing guidance to Flight

Standards field offices– Serving as a collection point for

technical information, and – Acting as a liaison with the Aircraft

Certification Service.



V 7.017

CommunicationAFS-1 & AIR-1 Memo,

dated Jan 27, 2010

• The purpose of the memo announced the implementation of TAD 24/7 process to assist AFS PIs responding to urgent requests for alternative methods of compliance, (AMOC)

• When AMOC support is needed to avoid significant commercial air transportation disruptions– Affects 10 or more aircraft– Not for individual or small

numbers of aircraft



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Seattle Aircraft Certification Office Memo dated 2/5 /2010.

• Purpose of this Memo was to response to a request from Air Transport Association (ATA).

• The memo Implemented a new procedure to shorten response times for an AMOC

• AMOC can be transmitted via electronic mailbox

Communication

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Organizational Influence

Unsafe Supervision

Preconditions for unsafe actions

Unsafe Acts

1 Differences of opinion between the ACOs and AEGs affect safety.

2 AEGs breakdown of communications with the field offices

3 ACOs not effective in ensuring continued airworthiness in the areas of ADs CMRs, ICAs and field approval

Communication

Optional corrective action

Negligible benefit as a result of action

Will mostly be eliminated by

the process

Safety improvement range

(SAIB or other optional corrective

action)

AD range

Increasing risk

value

AD guideline

Airworthiness directive

1. ACO and AFS personnel are not informed about AEG’s RR&Is.

2. A lack of awareness by ACO and AFS personnel of existing policy and requirements for implementation.

1 Communications between AEGs, ACOs and AFS impair the effective interfaces required to coordinate activities.

2 ACOs and AEGs, have differences in opinion

1. AFS field offices do not understand AD requirements.

2. ACO may not review ADs in enough detail to address concerns or questions that maintenance personnel may have when attempting compliance.

3.

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V 7.020

Aircraft Evaluation Group

Roles and Responsibilities



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AEG Roles and Responsibilities

Flight Standards Service

Aircraft Certification Service

ACE Region

ASW Region

ANM Region

AEA Region

Kansas City AEG

Seattle AEG

Long Beach AEG

Boston AEG

Fort Worth AEG

Aircraft Certification Offices (ACOs)

Headquarters Divisions:

· Air Transportation

· Aircraft Maintenance

· General Aviation and Commercial

Directorates:

· Transport Airplane· Small Airplane· Rotorcraft· Engine and Propeller

AEG Organizational Overview

202 AEG Liaison

302 AEG Liaison

Indicates policy making authority

Legend:



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AEGs are a Communication Link

Flight Standards Service (AFS)

AEGs are located with

ACOs

AEGs are located with

ACOs

AEGs

AEGs communicate directly with

ACOs

AEGs communicate directly with

ACOs

Aircraft Certification

Office (ACOs)

FlightStandards

District Offices (FSDOs)

Air carriers, Operators

Domestic and foreign

manufacturers

Regulatory authorities i.e. CAAC, EASA,

CTA, JAA

The public i.e.

ALPA, ATA, others




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• AEGs serve as liaison between AFS PIs & AIR, ASEs• They are subject matter experts in reviewing and

determining operational suitability for operations and airworthiness

• They provide consultation, coordination, and assistance to Aviation Safety Engineers (ASEs) in AD development

• AEGs assist the ACOs and manufacturers in the evaluation process so they are aware of any operating rules that might impact design

• Participation in the function, reliability and/or service during flight tests, as necessary, to evaluate new or modified aircraft types for compatibility pertaining to all Federal Regulations, e.g., FAR Parts 43, 61, 63, 91, 97, 121, 125, 129, and 135



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• Provide assistance to Directorates and/or Headquarters in the development of draft Advisory Circulars, Air Carrier Operation Bulletins, Maintenance Bulletins and NTSB Recommendations

• Provide Technical assistance to Regional Offices, FSDOs, CHDOs/CMOs Personnel



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• Coordinate with the National Simulator Evaluation Team regarding the evaluation of data packages for aircraft simulator design, acceptance, and approval

• Serve as liaison between manufacturers and field offices for distribution of service bulletins, all operator letters, and maintenance alerts

• Review and concur with ICAs and intervals associated with FAR 23.1529, 25.1529, 27.1529, and 29.1529 requirements



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• AEGs have responsibilities to the various technical boards based on the aircraft assigned to the certification directorate and the amount of activity generated by the aircraft manufacturers and operators: – (a) Flight Operations Evaluation Boards (FOEB)– (b) Maintenance Review Boards (MRB)– (c) Flight Standardization Boards (FSB)– (d) Type Certification Boards (TCB) - member– (e) Flight Manual Review Boards (FMRB) - member



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AD Responsibilities: • Participate in development of ADs related to

operations and/or maintenance• Provide technical consultation to the FAA

Certificate Holding District Offices (CHDOs)• Liaison with the Aircraft Certification Office• Act as an intermediary between the Original

Equipment Manufacturers (OEMs) and CHDOs distributing service instructions and other forms of alerts, (Example, All Operator Letters and Maintenance Alerts)



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AD Complexity• Category 1, ADs would result in outreach

communications to the Flight Standards Aviation Safety Inspectors (ASIs) whose air carrier operates the affected aircraft. Describe “key elements” and background information regarding the need for the AD. This outreach would be conducted by the assigned AEG specialist and assisted by the ACO engineer. This would be accomplished, (prior to the release of the AD) by either telecon or polycom.




V 7.02929

AD complexity (cont’d)

• ADs that have multiple service bulletins, options,configurations, and sequencing.

• Apply ADs that cross product lines. • Overlapping ADs are ones that have the potential of

affecting other ADs in the same area of the aircraft. • ADs applicable to a single component or system that

is affected by other previously issued ADs. • ADs vulnerable to errors due to maintenance and/or

operational human factors. • Emergency ADs




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AMOC Responsibilities: • AEGs assist ASEs in evaluating any unique fleet or

operational characteristics regarding AMOC requests

• AEGs coordinate with the ASEs by contacting and/or resolving issues with the CHDOs



V 7.031

AEG Contacts

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•https://avssharepoint.faa.gov/afs/AEG/default.aspx


AEG Assignments

•https://avssharepoint.faa.gov/afs/AEG/default.aspx



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Roles in the AMOC Process

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• Air Carrier (Operators)• Principal Inspectors (PIs) at the CHDOs• Aviation Safety Inspectors (ASIs) at the AEGs• Aviation Safety Engineers (ASEs) at the ACOs• Managers and Supervisors

AMOC Process

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Operators Role:• § 39.19 May I address the unsafe condition in a way

other than that set out in the airworthiness directive?

Yes, anyone may propose to FAA an alternative method of compliance or a change in the compliance time, if the proposal provides an acceptable level of safety. Unless FAA authorizes otherwise, send your proposal to your principal inspector. Include the specific actions you are proposing to address the unsafe condition. The principal inspector may add comments and will send your request to the manager of the office identified in the airworthiness directive (manager). You may send a copy to the manager at the same time you send it to the principal inspector.

AMOC Process

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Revision: FAA Order IR-M-8040.1C (Just published May 17, 2010, cancels version “B”)

• Removes general discussion related to alternative method of compliance.

• Information on AMOCs will be contained within the AMOC Order 8110.103

The AD Manual provides policy and guidance for the drafting, issuance, and distribution of ADs. It is inteded to explain the laws that apply to ADs, procedures for writing an AD, and policies on key AD-related issues.

AMOC Process

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V 7.036

PIs Role: (Con’t)

• FAA Order 8110.103, Alternative Methods of Compliance

• Item 6, Who Approves AMOCs?– (c) PIs can’t approve an AMOC request, (for most

ADs); however, they may comment on an AMOC proposal (such as pointing out the unique characteristics of the requester’s fleet and operations) before forwarding it to the manager of the FAA office identified in the AD.

AMOC Process



V 7.03737

AEGs Role:• Provides a strong communication network among

the CMOs, and ACOs• Subject-Matter-Expert for technical assistance when

the need for a complex AMOC first arises• Liaison communicating with the ACOs and

Headquarters for complex issues with AMOCs

AMOC Process



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Engineers Role:• Identify whether an AMOC is needed• Coordinate with AEGs, if needed; (Reference AIR-ANM-

029-WI) for AEG coordination criteria • Identify if the PI supports the request• Evaluate the AMOC request to establish whether

request provides an acceptable level of safety• Coordinate the draft response with the PMIs, and AEGs

if needed• Issue an AMOC response

AMOC Process

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V 7.039

Engineers Role: (cont’d)

• FAA Order 8110.103, Alternative Methods of Compliance

• Item 7b, Approving an AMOC– (3) The assigned engineer must ensure that the proposal

provides an acceptable level of safety. When reviewing an AMOC proposal, the FAA engineer should review the comments received from the requester’s PI. If there is no comment or concurrence from the PI, the engineer should contact the PI, FSDO, AEG or other appropriate flight standards service personnel for help evaluating any unique fleet or operational characteristics.

AMOC Process



V 7.040

Roles of Managers and Supervisors in the AMOC & “24/7 Process”

• Communication

• Engagement

• Escalation

AMOC Process



V 7.041

What is the AMOC “24/7” Process?

When and How do I Use it?



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24/7 Work Instruction:• The Work Instruction (WI) provides support from the

Aircraft Certification Service, (AIR) to the Flight Standards Service, (AFS) when there is an urgent need for an Alternative Method of Compliance (AMOC) that impacts transport category airplanes.

1. AMOC support is needed after normal business hours and in order to support the Flight Standards Principal Inspectors (PIs)

2. AMOC support is needed to avoid significant commercial air transportation disruptions (i.e. approx. 10 or more aircraft). This is not intended to be used for AMOCs applicable to individual or small numbers of aircraft.

“24/7” AMOC Process

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AMOC Process:• Compliance with regulatory requirements

– Boilerplate AD AMOC paragraph, and – 14 CFR 39.19

• Standard AMOC process follows Transport Airplane Directorate (TAD) Work Instruction, (WI) AIR-ANM-029-W1

• 24/7 AMOC Process follows companion TAD WI AIR-ANM-029-W2


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Boilerplate AD AMOC Paragraph: Alternative Methods of Compliance

(i)(1) The Manager, Seattle Aircraft Certification Office (ACO), FAA, has the authority to approve AMOCs for this AD, if requested using the procedures found in 14 CFR 39.19. Send information to ATTN: Binh V. Tran, Aerospace Engineer, Systems and Equipment Branch, ANM-130S, FAA, Seattle Aircraft Certification Office, 1601 Lind Avenue, SW., Renton, Washington 98057-3356; telephone (425) 917-6485; fax (425) 917-6590; e-mail information to 9-ANM- [email protected].

(2) To request a different method of compliance or a different compliance time for this AD, follow the procedures in 14 CFR 39.19. Before using any approved AMOC on any airplane to which the AMOC applies, notify your principal maintenance inspector (PMI) or principal avionics inspector (PAI), as appropriate, or lacking a principal inspector, your local Flight Standards District Office. The AMOC approval letter must specifically reference this AD.


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Standard AMOC process WI


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“24/7” AMOC Process24/7 AMOC WI

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Features of the 24/7 Process

• Sharepoint with contact numbers for AFS use

• TAD Managers contacted by cell phone

• Evaluate request to determine:

– Tech staff availability?

– AMOC decision obvious if tech staff not available?

• Are airplanes in a condition for safe operation for some short interval

(i.e.10 days) until a final resolution can be determined?

– Coordinate with PIs, and AEGs (as needed)

• Use FAA letters or email to respond with AMOC


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When is “24/7” Utilized?As a guideline, the “24/7” process may be utilized when there is

an urgent need for an AMOC which impacts transport airplanes, and:

– AMOC support is needed after normal business hours and in order to support Flight Standards PIs; and

– AMOC support is needed to avoid significant commercial air transportation disruptions (as a guideline the AMOC affects approximately 10 or more aircraft).

– The 24/7 program is not intended to be used for AMOCs applicable to individual or small numbers of aircraft.


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Appropriate Use of 24/7:

• Operator determination that aircraft are out

of AD compliance

– Configuration issues with ADs that have been

complied with or are terminated

– Accidental misinterpretation of AD requirements

• Significant fleet disruption is possible (i.e.

10 or more airplanes)


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Undesired Use of 24/7 Process• Repair station audit findings

– If communications among repair stations, Air Carrier CMOs, and

ACOs occurs early, the 24/7 process not needed

• Suspected unapproved parts

– Follow unapproved parts process

• Stuff left until Friday at 6 pm, that has been known since a

week ago last Tuesday

– Let’s not make panics out of situations by coordinating early


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Key Points of “24/7”:Provides support and outreach to the CMOs– Involve the AEGs and ACOs early in the process– Establish a strong communication network among the

CMOs, AEGs, and ACOs– Utilize the AEGs as a subject-matter-expert for

technical assistance when the need for an AMOC first arises

– Use the AEGs as a liaison for communicating with the ACOs


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Statistics for 24/7• We have been providing 24/7 support for about

two years now, although the Work Instruction, (WI) was approved only late last year

• We have used the process about 12 times in the past two years.


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Who do I contact for 24/7 Support• Hotline numbers• Work Instruction• Sharepoint site

• For more information on the 24/7 process, please see the Transport Airplane 24/7 Flight Standards AMOC Request Support Work Instruction in the Aviation Safety Quality Management System (QPM # AIR-ANM-029-W2), and

• For information on how to prepare an AMOC request, please see Transport Airplane Alternative Method of Compliance (AMOC) Letters (AIR-ANM-029-W1 )

• FAA personnel are encouraged to remind operators that AMOC requests must be submitted in accordance with 14 CFR 39.19


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Early Communications:• Involving the AEGs and the ACOs early in the

process and building a strong communication network mitigates the risk of sending an unclear message to the air carriers

• Bringing the right parties to the table (when the possible need for an AMOC first arises) will reduce disruptions to the air carriers


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Risk Management

Process

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Risk Management Process

Air Transportation Oversight System• Risk Management Process, contained in Flight

Standards Information Management System (FSIMS), Volume 10, Chapter 3

• Five Major Steps:– Identify the hazard– Analyze and assess the risk– Make a decision– Implement the decision and– Validate the effectiveness of the decision



V 7.057



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Aviation data, in a standard taxonomy, is collected by automation, provided by certificate holders or captured by other methods.

Aviation data is filtered, using automation and/or manually, to identify event data likely to identify safety issues.

Senior COS ASE conducts qualitative assessment to filter the data or issues quick disposition (Emergency ADs, Final rule; request for comments and obvious non-issues).

ASE conducts quantitative risk analysis to identify safety issues for corrective action.

Risk of eventrecurrenceis reduced

Acquire data

Conduct hazard criteria

analysis

Perform preliminary

risk assessment

Aviation data

triggers MSAD

Perform risk

analysis

ASE identifies causes that contributed to the event. ASE identifies candidate product/part solutions and passes non-product/part cause information to applicable parties.

Identify causes

ASE works with other AIR and AVS experts to identify and evaluate candidate corrective actions to reduce risk of recurrence. May lead to the initiation of an AD or non-mandatory corrective action.

Select corrective

action

Monitor and validate corrective actions

Risk Management Process

FAA Order 8110.107 - Monitor Safety/Analyze Data

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V 7.059

Summary

• Involving all parties early in the process and building a strong communication network mitigates the risk of sending an unclear message to the air carrier

• Bringing the right parties to the table (when the possible need for an AMOC first arises) will reduce disruptions to the air carriers



V 7.060

Reference MaterialReference Documents:• FAA Order 8900.1 Flight Standards Information Management System

• FAA Order 8110.107 Monitor Safety/Analyze Data

• FAA Order 8110.103 Alternative Methods of Compliance (AMOC)

• FAA Order 8040.1 Airworthiness Directives

• FAA Order IR-M 8040.1 Airworthiness Directives Manual

• Title 14 Code of Federal Regulations, part 39

• AIR QMS Documents:

https://intranet.faa.gov/faaemployees/org/linebusiness/avs/offices/air/qms/doc/master_index/media/AIR-ANM-029-W2.pdf

• AIR-ANM-029-W2 Transport Airplane 24/7 Flight Standards AMOC Request Support Work Instruction

https://intranet.faa.gov/faaemployees/org/linebusiness/avs/offices/air/qms/doc/master_index/media/AIR-ANM-029-W1.pdf



V 7.061

Questions

Communication and the 24/7 Alternative Methods of Compliance Process

Documents

Transcript of Communication and the 24/7 Alternative Methods of Compliance Process