Say Goodnight, Gracie

When you speak about aircraft maintenance, confusion is best left to the experts when tackling acceptable and approved.


An ICA — like manufacturer’s maintenance manuals (MM) — is only required to be acceptable to the FAA, not approved. (NOTE: Airworthiness Limitations are the exception to this; they require approval.) The ICA information however is written using the technical data that was used to define the configuration and design features of the article, but more often than not, doesn’t contain the actual technical data as defined above.

What about an air carrier’s maintenance training or deice program? They’re approved. Kee-rect, but the burden is on the air carrier to determine how they will train, e.g. computer, stand up class, or OJT. Their fleet dictates the type of deicing they will accomplish and where. These programs are proprietary, but their concepts aren’t as guarded as an engineer’s investment in a design or product.

FAA review to determine which

Why accepted/acceptable? Either the FAA will determine the item to be acceptable for the intended use when and if the FAA reviews it or it will be accepted only after the FAA reviews it. When the item speaks to specific regulation sections, it is ensured the item is acceptable to the FAA.

An ICA for a STC is acceptable data because, again, the approved technical data is proprietary and not made available to the general public; not even the FAA FSDO has access to technical data behind a STC; it’s not necessary.

But let’s go back to the MM example: when a carrier receives the first MM for a brand new aircraft, e.g. the Boeing 7X7, it may receive incomplete manuals; pages might say the procedures are yet to be written. So let’s say the airlines are flying the 7X7 for six months and Boeing produces the procedures for changing a nose gear steering cylinder and they’re entered as a revision. Should the airlines ground the 7X7 until the FAA can review, test, and accept the procedures? No, because Boeing has the approved technical data developed during type certification of the product, it’s written the procedures and published them with oversight by the FAA Aircraft Certification Office.

Let’s look at two other terms:

Administrator and FAA

Acceptable to the Administrator – “items required to be acceptable to the Administrator do not require FAA review prior to a person using it. It is considered acceptable unless shown by the FAA to be unacceptable”; and,

Accepted by the FAA — “if it is a requirement that the FAA accepts items, the applicant must submit them to the FAA prior to use. If the submittal is unacceptable, the Aviation Safety Inspector (ASI) must inform the applicant in writing of the specific deficiencies based upon a regulatory section or paragraph. It is important to keep the applicant advised of the status of their proposal. Make it clear to the applicant/certificate holder that if the ASI takes no action or does not inform the applicant within an agreed time frame, that the submission is either deficient or accepted, the applicant may assume that the FAA has accepted the submission.”

Acceptable to the Administrator is an older version, but the FAA still must prove an item is unacceptable. Acceptable to the Administrator will eventually become Accepted by the FAA in the language; it just makes sense. It’s understood your ASI actually approves your designs or issues Airworthiness Certificates.

Technically, nothing is changing, though the intent of approved, accepted, and acceptable-to will gain more clarity. Because we’ll understand better what is being said in time we’ll put more confusion to bed. Then all that’s left to say is, “Goodnight, Gracie!”

 

Stephen Carbone is an aviation industry veteran of 28 years. He works at the Boston regional office in the Flight Standards Airworthiness Technical Branch. He holds a master’s degree in aviation safety systems.

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