In 1982, I began working for Federal Express; it had brand new 727 aircraft to build up its domestic service. Within 30 months it’s using those 727 aircraft for European flights before transitioning to DC-10s. FedEx, like many others, was expanding internationally. By 1992, you could count on one hand the major airlines that stuck strictly to domestic routes.
But the effects of international aviation weren’t limited to airlines; Boeing, Cessna, and Bell began sharing the stage with international competition. As U.S. manufacturers brought in work to their fixed-wing and rotorcraft products, so did repair stations specializing in component repair both here for foreign manufactured components and across the borders and oceans for U.S. manufactured components; Part 145 repair stations that provided anything from brake assembly overhauls to instrumentation repairs were breaking from the mom-and-pop repair stations of the past.
As international travel expanded it became more efficient to perform phase checks on foreign soil; an aircraft committed to an overseas route could receive scheduled checks across the pond rather than drag the aircraft back home, thus eating up flight hours and cycles. In these foreign markets, repair stations provided a market for U.S. operated businesses by opening in foreign countries and becoming a new source of convenience providing phase checks, repairs, alterations, modifications, and on-site component overhaul. No matter where one stands on the issue of maintenance accomplished overseas, it’s here to stay.
Maintenance implementation procedures
Let’s speak about maintenance implementation procedures (MIP) under the bilateral aviation safety agreements (BASA) provisions; we’ll reference FAA Order 8000.85A, which speaks to establishing a MIP. According to Advisory Circular 21-23B, a BASA is “a government to government agreement, consisting of one executive agreement and one or more maintenance implementation procedure, to facilitate the recognition of procedures for the mutual acceptance of” different approvals related to environmental, airworthiness, and/or operations; they replace bilateral airworthiness agreements. Simply, the BASA is the handshake between two countries agreeing to Part 145 repair stations being allowed to operate in the other’s country.
The BASA specifically provides for joint participation in the inspection of civil aviation authorities and undertakings, for cooperation and assistance in any investigation or enforcement proceeding, and on the exchange of safety data, including data on accidents and incidents. BASA also foresees mutual recognition of aviation safety certificates obtained through shortened product approval procedures and joint acceptance of product tests.
No country gives free rein to another to act with impunity on its regulated stuff. A MIP is “the procedural document authorized by the BASA executive agreement related to the performance of maintenance, alterations, and modifications on civil aeronautical products.” A technical implementation agreement between the FAA and a country’s national aviation authority (NAA), the MIP defines procedures to accept each authority’s recommendations for repair stations surveillance. Aircraft certification also has implementation procedures with its own set of procedures for e.g. recognition of manufacturing certification. To clarify: MIPs are written arrangements two countries have to assure rules compliance; both countries agree on how to keep an eye on repair stations.
National aviation authority
A national aviation authority is a country’s regulatory agency, as the FAA regulates for the United States; NAAs are specific to each country, e.g. for the United Kingdom, it’s the Civil Aviation Authority. Also, the FAA recognizes that certain sections of the maintenance rules are international standards; since the FAA belongs to the International Civil Aviation Organization (ICAO), it requires, per ICAO, to have: appropriate tooling, equipment, technical data, and both trained and qualified personnel.
Part 2: Regulatory oversight of domestic vs. foreign repair stations
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