PAMA Direct - November 2007

 PAMA Direct is our monthly guide to government issues related to maintenance.  In this issue:

• New Opportunities in Contract Maintenance

• Some Static Parts to be Life Limited

• Proposed Guidelines for Pressurized Engine Parts

• New HIRF Standards Released

• IATA to Develop MRO Safety Audit

   

New Opportunities in Contract Maintenance

Figures compiled by the Bureau of Transportation Statistics indicate that air carriers are continuing to increase their reliance on contract maintenance. This ongoing trend opens up new opportunities in the third-party maintenance provider world for businesses and individuals alike.

Although a few airlines have maintained a steady percentage of contract maintenance, the industry as a whole has increased the proportion of its maintenance dollars spent on outside vendors. The industry-wide percentage of air carrier contract maintenance (as a percentage of total maintenance expenses) rose from 44 percent in 2000, to 51 percent in 2003, to 64 percent in 2006.

Most individual airlines are reporting increased use of outsourced maintenance. Since the dip in total contract maintenance spending following September 11, major carriers have generally continued a steady upward trend of increased use of outside providers.

While this growth in the MRO market has sparked safety concerns, it also opens up new opportunities for well-trained mechanics at facilities that are taking on an increased share of airlines’ maintenance burden.

Some Static Parts to Become Life Limited

Certain non-moving engine parts not previously considered life-limited may be considered life-limited in future engines due to a new FAA final rule that goes into effect November 5. The regulation introduces a new airworthiness standard as section 33.70 in the Federal Aviation Regulations, replacing the previous guidance on life-limited engine parts in section 33.14.

The new standard continues to mandate cycle limits for life-limited parts, but it expands the definition of life-limited parts to include static parts. Under the new rule, life-limited parts will be “rotor and major static structural parts whose primary failure is likely to result in a hazardous engine effect.” The term ‘hazardous engine effects’ is described in 14 C.F.R. § 33.75 and include those effects that would cause the engine to catch fire, burst, generate excessive loads, or lose the ability to shut down.
Although the FAA previously limited the regulatory requirements for life-limited parts to rotating parts, some engine manufacturers have already designated certain static engine parts as life-limited. This includes some high-pressure casings and non-redundant mount components. In some cases, the manufacturers have voluntarily placed limits on static parts due to accident findings or other safety concerns; in many cases, though, manufacturers have placed life-limits on static engine parts because the European (EASA) regulations already require such limits, so they are necessary to gain European type certification on an engine.

While the rule applies directly to certification applications made after November 5, the industry will have to remember that applications for STC and PMA made after that date will also be subject to the new rules, so STCs and PMAs on engine parts may have to impose life-limits on some static parts where the OEM has not designated life-limits.

All individuals and entities performing maintenance on such engine parts should be aware that certain components certificated after November 5 may be classified as life-limited, though similar parts approved prior to that date are not. Always check the airworthiness limitations section of the manual(s) if you are unsure of whether a component is a life-limited part.

The full contents of the rule can be seen at http://a257.g.akamaitech.net/7/257/2422/01jan20071800/edocket.access.gpo.gov/2007/pdf/E7-17369.pdf.

Proposed Guidelines for Pressurized Engine Parts

The FAA has proposed a rule that would require structural performance criteria for pressurized engine parts, in an attempt to further harmonize FAA and EASA airworthiness standards. For mechanics, this could mean seeing redesigned pressurized components on newly certificated engines or components to comply with the proposed regulation.

While the FAA currently provides little regulatory guidance on certification of pressurized static engine parts, EASA’s Certification Specifications for Engines (CS-E) sets specific standards for such components, including compressor cases or hydraulic system components. The proposed rule would put similar requirements in a new section of part 33 of the FARs.

The suggested language would require that “all static parts subject to significant gas or liquid pressure loads for a stabilized period of one minute” will not distort beyond serviceable limits or exhibit leakage that could create a hazardous condition when exposed to certain higher-than-normal pressures. Such parts must also not “fracture or burst” when subjected to certain other higher-than-normal pressures.
The FAA says that most engines are already designed to EASA standards, and that the proposed rule would have a minimal impact, including slightly higher certification costs. Nonetheless, mechanics wishing to comment on the proposal have until December 5, 2007 to submit comments. The NPRM can be seen at http://a257.g.akamaitech.net/7/257/2422/01jan20071800/edocket.access.gpo.gov/2007/pdf/E7-17626.pdf.

New HIRF Standards Released

New FAA standards regarding high intensity radiated fields, or HIRF, have taken effect this month, requiring that certain aircraft electric equipment must be able to effectively operate under varying levels of electromagnetic radiation. Any individual or entity performing aircraft maintenance will need to ensure that repairs return any aircraft or component certificated under the new rules to the conditions spelled out by the standards.

The HIRF environment results from electromagnetic emissions from radio antennas, TV towers, and other sources and is capable of interfering with critical airplane electronics. The new standards require that flight-critical electronic systems not be adversely affected by certain HIRF environments and regain normal function after exposure. Other electric systems important to safe flight must also not be adversely affected by such radiation.

Any new certification or approval before September 5, 2007 would not be affected, however equipment certified after this date must comply with HIRF testing guidelines in the new standards. Following a repair or alteration, the mechanic or repair facility must ensure that the repaired component remains compliant with these testing guidelines and is able to perform in the HIRF environments listed in the rulemaking.

The sole exception written into the standard is for equipment certificated under existing special conditions before December 1, 2007. Such components need not comply with the new standards. Special conditions were the previous method for approving electronic components to function in high-radiation environments, however since releasing a final rule spelling out the standards, the FAA has stopped issuing special conditions.
To see the new standards and the testing requirements for airplane electronic equipment, please visit: http://a257.g.akamaitech.net/7/257/2422/01jan20071800/edocket.access.gpo.gov/2007/pdf/E7-15195.pdf.

IATA to Develop MRO Safety Audit

Having undertaken development of an audit program for ground operations, the International Air Transport Association (IATA) announced that it is will soon begin developing a universal audit program for the aircraft repair and maintenance industry. News of the MRO audit program was announced at the FAA/ATA Human Factors Maintenance and Ramp Safety conference, according to Aviation Week.
Mike O’Brien, IATA’s Director of Program Implementation/Auditing, said that the group “has some money put aside to start the development phase,” of the audit standard and plans to hold a formation meeting before the end of the year. IATA already oversees the IATA Operational Safety Audit (IOSA), which assesses an airline’s operational management and control systems.

The IOSA program has served as a foundation for the agency’s IATA Safety Audit for Ground Operations (ISAGO) program, according to Aviation Week, and may also provide a guide to the future MRO audit program. While the maintenance audit may be in its extremely early stages, it may develop quickly – the ISAGO program has been in development for less than a year, and the first audits are scheduled for early 2008.

Comments

[Simon Norton]

HIRF Environments - to what extent do these environments impact Human " electrical " systems ?
On all warships there are marked warning zones around radio and electromagnetic transmission antenna, to indicate a danger zone.

How intense are HIRF Environments ? is there a measure to define an HIRF Environment as such a zone?
Can aircraft maintenance personnel measure radiation intensity in order to define an HIRF zone ?
S V Norton
Chemdetect CT SA