As the operational side of aviation safety struggles with NextGen positioning technology, maintenance is struggling with highly complicated and interwoven design standards used to substantiate composite and special coating technologies.
In order to fix a degraded condition, one must understand the certification basis and the impact maintenance actions might have on the original and continued in service condition. The ability to withstand “damage tolerance” can only be “tested” in the field, and then only after potential mistakes have been made in “fixing” damage that instead impacted continued operations.
As the engineering departments in airlines decline and the sophistication of the design standards increase, maintenance of composite structures and articles that have special coatings become more and more the purview of the designer. Unfortunately, designers are not always familiar with operational impact, nor are the regulators — witness the “design changes” required to bring the Dreamliner out of its nightmare. These design changes basically said when the fix is developed, we will let you know; the type certificate holder did develop a fix acceptable to the regulators. Only time will tell if the design change fixed the issue or created another one.
The regulator is on the horns of a dilemma; how does it determine if the applicant met the burden to show compliance with the regulations if it is unfamiliar with the technology being used? How does the certificate holder show compliance when the regulations have not caught up with the technology being used? The number and amount of “special conditions” attached to new aircraft are evidence of gaps in design requirements. If these gaps exist, how do maintenance providers establish their action to return the article (in this case the aircraft) to at least its original condition?
The regulations require the designer to ensure the gaps can be addressed when creating fixes for damage to composites or contemplating replacing special coatings during the maintenance process. The air carrier and its maintenance provider must have an understanding of the design requirements, special conditions, and the technology before creating maintenance or alteration actions of their own. The technology must not outstrip the ability to ensure continued operations; the standards for the new generations of materials (composites) and coatings must be decipherable by airlines and their maintenance providers. AMT
Sarah MacLeod is a managing member at the law firm of Obadal, Filler, MacLeod & Klein, P.L.C. and is engaged in the legal representation of foreign and domestic air carriers, aircraft maintenance and alteration facilities, distributors, pilots, and other individuals and companies in federal court and before federal administrative bodies. She also serves as assistant chair for Air Carrier and General Aviation Maintenance of the FAA’s Aviation Rulemaking Advisory Committee, a post she has held since 1996. A globally recognized expert in aviation regulatory compliance, Ms. MacLeod is a sought-after speaker and has appeared a numerous aviation and MRO events. She is admitted to the bar in Virginia.
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