When the FAA convenes an aviation rulemaking committee (ARC), it is a call for help. The agency is acknowledging that it needs the industry’s support to resolve a problem. When regulators ask, we must provide honest answers and remain committed to assessing and refining the result.
Remember the grounding of aircraft in 2008 over allegations of airworthiness directive non-compliance? Following the widespread flight cancellations and system disruptions the FAA chartered the Airworthiness Directive Implementation Aviation Rulemaking Committee (AD ARC). Representatives of manufacturers, air carriers, repair stations, the FAA, and other industry groups worked long and hard to develop policies, procedures, and “best practices” to improve the development, implementation, oversight, and enforcement of these important safety rules.
A Good AD
While the ARC’s final report outlining deliverables and implementing actions is focused on air carriers, the issues are not unique to the airlines. Any successful AD will meet four standards:
- Clear requirements.
- Consistent interpretation.
- Compliant incorporation.
- Effective oversight.
By making ADs adhere to these criteria, the industry benefits from clear safety mandates; ensuring confidence in the continued airworthiness of the entire fleet.
Alternatively, the following complications will continue to plague the agency, the industry, and the flying public:
- Ambiguous, overlapping, extraneous, or erroneous AD requirements.
- AD corrections/supersedures/revisions to address ambiguities, errors, and oversights.
- Alternative Methods of Compliance (AMOCs) to address AD/Service Bulletin (SB) ambiguities, errors, corrections, and oversights.
- FAA enforcement actions.
- Operator compliance clarification requests.
- Continuous and increased Aircraft Evaluation Groups (AEG) responses to operator compliance questions from Aviation Safety Inspectors.
- Fleet groundings due to non-compliance findings.
Checking Our Work
The FAA called and the committee participants answered. Now, industry must lend its insight.
AD ARC participants developed a questionnaire to gather information on specific ADs. The data will support a determination as to whether the committee’s deliverables and implementing actions have been effective or need more work. The submitted information will not be used to address the specific instances reported; rather, the data will be used to support AD process improvement recommendations.
While the questionnaire may appear to be aimed at “bad” ADs, it also can and should be used to provide examples of clear, concise and easily understood directives. One questionnaire must be completed for each AD on which you would like to provide feedback; the process shouldn’t take more than 10 minutes.
To access the questionnaire, please visit: http://avmro.arsa.org/adarc.
Completing the questionnaire is making good on our shared commitment to aviation safety, continuous improvement of good business practices and better oversight.
Sarah MacLeod is managing member of Obadal, Filler, MacLeod and Klein, PLC and a founder and executive director of the Aeronautical Repair Station Association. She has advocated for individuals and companies on international aviation safety law, policy and compliance issues for 30 years. Ms. MacLeod obtained a bachelor’s degree from Evergreen State College, Olympia, Washington and a law degree from Catholic University of America, The Columbus School of Law.
