Torqued: Choose offshore maintenance site shrewdly
Today it is normal to have maintenance performed on our aircraft or components almost anywhere in the world. With the availability of overnight delivery of almost any aircraft component to any location, it makes sense to seek out the most capable and cost-effective certified repair facility almost without regard for its location.
Many specialized repair facilities actually need a worldwide marketing base because of the narrow range of services they offer. Most of these facilities advertise the fact that they are FAA- or EASA-certified, indicating that they have achieved at least some level of competency.
For many FAA-certified repair stations outside the U.S. the only FAA compliance visit is the initial certification visit. All too often, the next visit coincides with the renewal of the certificate.
Many aviation professionals believe that is simply not enough oversight. Senior leadership from the FAA recently testified before the U.S. House aviation subcommittee on the subject of oversight of certified foreign repair facilities, and their explanations did not impress the committee. Some representatives indicated their displeasure with the FAA’s performance on the aspects of continual oversight through the use of repeated visits by an FAA aviation safety inspector.
Certified airlines are the largest users of these certified repair facilities. For some time there has been a large and growing flow of repair work out of the airlines to these facilities. The airlines protect their interests by providing their own quality-assurance people to monitor the processes used.
Even with this level of monitoring it is still possible to have a problem. Recently some of these quality auditors from U.S. certified airlines have told me that they are occasionally finding repair facilities that have installed component parts within a larger assembly that were not manufactured by the type-certificate holder but by a facility using parts manufacturing approval (PMA) issued by the FAA.
I want to be clear here: there is nothing wrong with parts produced under the PMA process. In fact, Pratt and Whitney is in the process of getting PMA approvals for manufacture of parts for GE engines. However, there is a requirement to list all replaced parts in the record of repair for the assembly. Apparently repair stations do not always follow this recordkeeping requirement, as there are additional hoops–including using the services of a DER–the facility needs to go through before these PMA’d parts are acceptable. The airlines have used their system of quality assurance and quality control audits to protect themselves from being caught in the non-compliance enforcement process.
The problem airline quality-assurance personnel report raises some serious concerns for business aviation. Since the airlines have a much larger organization, they are able to check the repair facilities before any work is performed and monitor the ongoing repair work of the facility.
Given the low flow rates and limited manpower of corporate operations, this level of quality oversight simply is not possible. The opportunity to catch a replacement part being installed in a larger assembly is during reassembly, and likely the only way to catch it is to be there during reassembly. That means being there to validate the paperwork as well as observe the installation. A complete and accurate record of repair is a FAR requirement, and this record must include a list of all the subassembly parts replaced as well as any work performed on or in the final assembly.
This is an area that we need to improve. Reviewing serviceable parts tags, such as 8130, and the work orders from different repair facilities for the same component often will show a considerable difference in what is recorded. Sometimes it is impossible to understand exactly what repairs were made to the component, or even the aircraft, by just reviewing the records available.
There are some things you can do to protect your operations. First, know the repair facility you are using. There is no substitute for having a good working relationship with suppliers. I would add a careful review of all paperwork immediately upon receiving any component from a repair facility. Question anything that you don’t understand, including what work was actually accomplished.
Sometimes you might find yourself in a bind over the turn-around time when needing a repair. This may lead you to shop around other repair facilities that promise a quick turn on a repair. Operators need to be careful when using a new or seldom-used repair facility. A good rule of thumb is to check with other operators to see if any have experience using the facility. Don’t use a repair facility you cannot verify as reliable. A poorly performed repair will cause you considerable grief and won’t save any time or money in the long run.
Finally, a good rule of thumb is to verify everything–over and over if necessary–until you are completely satisfied. There is more to a satisfactory repair than just a completed 8130 serviceable tag.