I feel lousy. I just spent three months on the road, staying in hotel rooms with complimentary mildew smells in the carpet and fuzzy black stuff on the bathroom tile that likes to eat soap. Let us not forget that every one of my trips begins and ends with a ride in a jump seat (See September 2005), and every frequent flyer knows that an airplane is a Petri dish with wings. Travel is not fun. Travel is a foretaste of Hell. And when you are on the road a lot the chances of getting sick are always high.
So it was on the last week of my travels in March — despite swallowing lots of aspirins, engaging in frequent hand washing, and gargling with the green stuff every morning and night — that I lost my thumb wrestling contest with Typhoid Mary and I got sick.
Oh, it’s not the “at death’s door” kind of sick, it’s more like, “sitting in a parked car in the street just outside his house,” kind of sick. Just when I thought it could get no worse, my editor called. “We need an article for the next issue,” she said cheerfully. I will not tell you what my reply to her was, but leave it up to your imagination. In my weakened condition, she won the contest of wills. Now, sick and beaten, I had to find something to write about.
In between fighting the fog of congestion and coughing so hard my chest hurt, I had a moment of clarity. You know the kind, it’s just like the moment of clear headiness you have after filling a handful of tissues with a lot of green snot. In that instant, I decided to write a briefing on what is happening in Headquarters. So I made it happen.
The PAMA request to increase the Inspection Authorization (IA) renewal period from one year to two years has been signed off by Flight Standards Service and has gone to the rulemaking committee. The committee will decide whether or not to revise 14 CFR section 65.93 to allow for a two-year renewal period. I wrote the justification in Appendix 1 to the proposed rulemaking document and we have good grounds for a rule change.
First, standardization. The current one-year IA renewal period does not match the two-year renewal periods for Designated Airworthiness Representative, Designated Mechanic Examiner, Designated Engineering Representative, Flight Instructor, etc. This IA renewal period does not follow the standardization of procedures and policy requirement of ISO-9002, and Flight Standards Service recently became an ISO 9002 compliant organization.
Second, economic benefit. It is conservatively estimated that the government would save somewhere in the neighborhood of 7,500 man-hours in processing the applications and $8,000 in postage costs every two years. The economic benefits to the 15,000 IAs are almost impossible to compute because half of the IA population just mails in their applications and the other half either drives a long distance or stays overnight to attend an FAA eight-hour IA renewal meeting. I argued that just cutting these travel costs in half and saving time spent on the application process will save the IA community a bunch of money.
Third, no impact on safety. While the draft rule change will allow for the IA application for renewal to happen every two years instead of ever year, the IA must show that he has done eight annuals, or 16 Form 337s, or two progressive inspections, or completed 16 hours of FAA accepted training at the end of the two-year renewal period. Why? The rulemaking committee had to be satisfied that we were not lowering the standards for IA so the basic yearly requirements for renewal are still in place.
While I am hopeful that this revision will go through I must warn you that all rule making is a crapshoot. There is no such thing as a sure thing in Washington. But we should have a good idea if the rule change is going forward into the formal rulemaking process by the end of May.
By the time you read this article the subject matter experts for the revision of AC 43.13-2A Acceptable Methods, Techniques and Practices, Aircraft Alterations will have already handed me their second draft of their assigned chapters of the AC. This AC is being revised to allow for the “acceptable data” in the AC to be used as “approved data” for an alteration, if the alteration in the AC is “applicable” to the aircraft, “appropriate” for the alteration to be performed, and “not contrary to the manufacturer’s instructions.” These are the same restraints that are found on the signature page of AC 43.13-1B Acceptable Methods, Techniques and Practices, Aircraft Inspection and Repairs that allows the AC data to be used for major repairs.
What all this revision stuff means is the data in the AC can be used as approved data without going through the field approval process.
The schedule for the AC revision is as follows: On June 13, 2006 final draft of AC chapters are due. Then the final draft of the AC goes into FAA coordination that includes all FAA regions and FSDOs. In early August, the draft AC will be published in the Federal Register for a 60-day public comment period. Starting Nov. 1, all comments will be disposed of, which means every last one of them will be reviewed, added, or discarded as necessary. The revised AC will be published in January 2007.
This is important! If you want this AC to work for you and your customers’ advantage, then we need your help in reviewing the AC when it is appears in the Federal Register in August. This document needs a good industry review to make it as close to perfect as any government publication can be. If you do not give me your two cents, then you will get mine. As I told the folks at all the IA meetings that I presented, I am not the brightest bulb in the box. So I need your oversight to keep me focused on the straight and narrow.
I have to tell you that when the AC is published in January 2007, it will only be the completion of the third phase of a four-phase process of revising this AC.
The main goal of this third phase was to get the approval to use the data in the AC 43.13-2A as approved data and include that permission on the signature page of the AC. As a sidebar to the main goal of this revision, we were only going to revise a few chapters of the AC. So the number of “approved” alterations that can be used for major alterations will be relatively small in this phase three revision.
Not to worry. On Sept. 13, 2006, the “Phase 4 team” will meet in Washington and start an 18-month process to look at revising all the chapters in the AC. I am hopeful that when they are done there will be at least 30-plus approved alterations in the Phase 4 revision.
FAA Notice 8300.119 titled: Use of Manufacturer’s Repair or Service Data as FAA-Approved Data for Major Repairs is still not understood by mechanics despite its major impact on the GA community. This notice allows mechanics to use service and repair data (Service Manuals/Bulletins) in accordance with existing regulations, as approved data for major repairs on non-pressurized areas of airplanes that are 12,500 pounds or less maximum certificated takeoff weight, and were originally TC’d before Jan. 1, 1980. So the bottom line is the data in the Cessna 150 service manual is now approved data and you do not need a field approval to use it as such. If you don’t believe me that good things do happen, the notice is found on: faa.gov/library/manuals/examiners_inspectors/8300/notices/media/N8300-119.doc so you can read it for yourself.
Note that when using this data the mechanic must determine if the data meets the same criteria for approval that is found on the signature page of AC 43.13-1B. The repair in the manufacturer’s manual must be “applicable,” “appropriate,” and “not contrary to the other manufacturer’s data.”
Since this notice is good for only one year and will die on July 28, 2006, we will move it before its drop dead date to the FAA Airworthiness Inspector’s Handbook, FAA Order 8300.10, using change 24 to that document which is scheduled to come out in June 2006.
Electronic Form 337 is a work in process. No, it is not going to replace or change the way we will fill out the paper copy of the Form 337. But there is no denying the fact that our industry is moving to an electronic form of record keeping, so the FAA is in the process of evaluating and selecting a vendor to support the electronic copy of the Form 337. I can tell you that the electronic Form 337 will be a web-based format. It will also have a help system and a tutorial and as of today it is scheduled for a late 2006 debut.
While I see this new electronic Form 337 process being easily incorporated into maintenance records of air carriers and large repair stations, there could be a problem or two making it fit with the small repair facilities. How come? First, you need a fairly powerful desktop computer to use this system. The second problem I see is the mechanic using this system must have a digital (electronic) signature to approve the article for return to service. FAA is working on this and information on digital signatures can be found on: www.adobe.com/security/digsig.html. So don’t panic. Remember, the electronic copy is just another way to fill out the 337 forms. Paper forms are going to be around for quite a while.
In my March 2004, AMT article titled: “Crossing over” I described how to become an FAA airworthiness inspector, and in two years time the FAA was going to start hiring. Well, it is now 2006 and the FAA is going to start hiring big time. So a word to the wise is sufficient. I would recommend that if you are interested in working for the U.S. government in the capacity of an FAA airworthiness inspector, you should spend the time and read the article, I just referenced. Next, get off your duff, get on the FAA.Gov web site under jobs and apply.
Oh, for you grey heads out there who think you are too old to run with the young dogs, you’re wrong! You are only too old when the grim reaper wins and they snap the lid shut. We need you. You guys have a wealth of experience. Now is the time to pay back to the profession that put a roof over your heads and food on the table.
Now my friends, the briefing is over, my duty is done. Even though it is 4:10 p.m. in the afternoon, in a couple of minutes, I am looking forward to draining a shot glass of NyQuil and losing myself between the covers so I can start working on moving my parked car to another street.