Work in Progress: AC 43.13-2A

Because of the importance of approved data in repairs and alterations, Bill O’Brien is heading a committee to write a new AC on the subject. He lists who is involved and the deadlines, so if you have something to contribute you can.

Up until now the structural repair manual (usually Chapter 5) in the airplane maintenance manual had to be approved separately by the FAA. Now, that is not the case, because Notice 8300.119 changed all of that. The Notice will become part of FAA Order 8300.10 Airworthiness Inspector’s Handbook when the next change is issued around January 2006. You can read the Notice for yourself by pulling up the Regulatory and Guidance section at the FAA.GOV web site.

What About Alterations?

OK FAA, you did good with repairs but what about alterations? I am working on that. In June of 2004 I put in a notice of comment in the Federal Register and explained that I wanted industry comments on how to change AC 43.13-2A Alterations. I especially wanted comments on creating new policy to allow the “acceptable” alterations in the AC to be used as “approved data.” The comment period ran for one year.

A year is a very long time for the public to comment on proposed policy changes and I was asked over and over again “Why so long?” by my management and the folks in the Federal Register. I told them that I knew mechanics, and most are less than responsive to the Federal Register notices for comments unless money was involved. Plus, I argued, the longer time period allowed me to get the word out, both at the 40 IA seminars I conduct every year and write a heads up about the new policy in an article in this magazine. Despite a year to comment, and me running around the nation shooting my big mouth off, I got a total of 14 written comments and about 13 phone calls. Personal disappointment aside, I do want to thank those who did comment especially the JAARS organization in North Carolina for their support.

Committee to Help Write New AC

So with the low number of industry comments, is the project dead? No, it is alive and well due to the support of Dave Cann, AFS-300 division manager, I got the money to pull in eight FAA subject matter experts (SME) to help write the new AC. We met out by Dulles Airport on Sept. 13 and 14, 2005.

Prior to the meeting, I picked the best applicants for the SME positions from the individual responses to a FAA nationwide announcement. A total of eight SME were selected to form a committee to work on this project. I prefer using the term “committee” vs. the over-used word “team.” In the team concept everyone helps everyone else and the “team” is responsible for the final product. In my committee model, each individual committee member works solo, and is totally responsible for his or her work. One of the SME asked me what level of performance should the committee shoot for. I told him I am easily satisfied with excellence.

In the first hour of the SME meeting I explained that AC 43.13-2A was last revised in 1977 and was long overdue for change. Next, I defined the purpose of the project which is to set up procedures and delegate tasks in order to revise AC 43.13-2A Aircraft Alterations format to the latest GPO standard, create procedures in which the data in the revised AC can be used as approved data, and provide simple, noncomplex, generic alteration data for nonpressurized areas of general aviation aircraft of 12,500 pounds maximum gross weight or less.

I then explained the AC revision process is divided into four phases. Phase 1 was the public comment period and getting the old AC electronically scanned into Microsoft Word so the good stuff can be used if needed. I then added that Phase I was already accomplished.

Phase II is to rewrite the signature page to say the data within can be used as approved data. While this appears to be simple process, it takes a lot of coordination with Aircraft Certification and FAA General Council that must be done before this dream becomes reality. Since I was the resident bureaucrat, Phase II fell on my shoulders.

Phase III is the rewrite/overhaul of the current chapters of the AC and adding a couple new ones as necessary. Phase IV is making the AC bigger and better. This SME committee is assigned only to do the Phase III revision. Phase IV revision is for another time.

What follows is a list of the SME, and what they are working on, and their email address if you want to send them something worthwhile that would help them get the job done. However, please don’t bother them if you have nothing to contribute, or just want an ear for your pet peeve. I gave everyone a year to speak their mind and now these SME have been given an important job to do and a short timeline to do it in. Everyone will have a second chance to comment on SME’s work when I publish the draft AC in the Federal Register in August 2006.

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