George Burn’s and Gracie Allen’s genius in comedy was in their routines, where neither one understood the track the other’s conversation was going; nothing is funnier than listening to a confusing discussion going in two different directions. But no matter how exasperating it got, George would take a puff of his cigar and gesture toward the audience with the sign-off, “Say goodnight, Gracie.”
Misinterpretation isn’t always funny
George and Gracie were comedy legends; they were experts at sleight of tongue and employing verbal deception was their bread and butter. But in our field misinterpretation isn’t always so funny; when you speak about aircraft maintenance, confusion is best left to the experts. In my article, Submitted for Your Approval, I stated that regulations were being reviewed for future updating; that house cleaning initiative may be communicated through notices and orders, which may get adopted into policy. This will ensure the FAA is addressing the public’s concerns.
The ‘acceptable to’, ‘accepted by’, ‘approved’, and ‘approved by’ ambiguity issue stands out as a very popular head-slapper. In April 2011, the FAA published in its Flight Standards Information Management System (FSIMS) under Volume Six, Chapter Fourteen, policies on Technical Data. Following close behind that, the FAA is circulating the final draft of a Notice out for comment; it provides guidance on applying the four terms listed above correctly. A notice, like an order, is a “directive that the FAA uses to issue policy, instructions, and work information to its own people and designees.”
AFS-300 tackling the terms
AFS-300, the Aircraft Maintenance Division has chosen to tackle these terms, which have been irregularly employed, e.g. acceptable-to is missing from guidance but is used commonly in the regulations. By use of this Notice, AFS-300 expects to streamline the application of the expressions. Let’s look at these terms and use the interpretations agreed upon for the language being reviewed.
Acceptable To — “any item (data, methods, techniques and practices) that does not require specific FAA review and acceptance/approval before use.”
Accepted/Accepted By — “any item (data, methods, techniques and practices) not requiring specific FAA acceptance/approval but that is required to be submitted to the FAA for review prior to use.”
Approved (Approved By) — “the item (data, methods, techniques and practices) is required to be and has been reviewed and formally approved by the FAA (or appropriate civil aviation authority [CAA], or national aviation authority [NAA]). Approvals are granted only by letter, by a stamp of approval, or by other official means.”
Why it’s an issue
What isn’t clear to many is why approved and accepted are even an issue. A Thesaurus suggests that approve and accept are synonyms, or mean the same. But approved is more selective in its use; in the FARs it applies only to operational issues as found in 14 CFR 65, 91, 121, and 135. Acceptable or accepted are limited to documents like AC 43.13A where the methods, techniques, and practices used are acceptable-to the Administrator in the absence of manufacturer’s repair or maintenance instructions for continued airworthiness (ICA), which is, for the most part, acceptable data anyway.
(This is where George Burns would deadpan for the camera.) My critics would say I just contradicted myself. But what exactly is approved data? Approved technical data is composed of, but not limited to: test information, analyses, dimensions, material specifications, allowable damage, etc; approved technical data is also proprietary. That’s why you’ll only see the methods, techniques, and practices for, e.g. a Supplemental Type Certificate (STC), because the manufacturer is generally reluctant to give out the technical aspects of the approved data; they make money off it. It’s like giving away your award winning secret barbeque sauce; Sacrilege!
Instructions for Continued Airworthiness By Brian Whitehead September 2001 Things used to be so straightforward. We had the manufacturer’s maintenance manual, and that was that. Now we...
AMT contributor Bill O'Brien gets the message out on ICA.
The FAA has issued a special bulletin reminding the industry that PMA parts are perfectly valid for use, and that competitors’ rhetoric questioning FAA-approved PMA parts is contrary to FAA...
In Part 2 of my tome on field approvals, we will cover current field approval policy found in Change 16 to FAA Order 8300.10.