Avionics News November 2012 - 64

LEGAL EASE

Continued from page 63

A related problem that would be resolved is the repair station that is 100 percent qualified to perform work (they have the right housing, tooling, equipment, data, personnel and training), but finds it has inadvertently violated its rating because the ratings were not updated to reflect the new scope of work. I have seen this arise even where the FAA approved manual changes

that supported the expansion of the business capabilities. By doing away with ratings, repair stations would not have to worry about modifying multiple documents when they add capabilities – so the documentation burden associated with business practice changes would be minimized without an adverse effect on safety. Under current regulations, repair stations are allowed to create a system under which they can change their own capabilities lists follow-

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ing an internal audit that verifies the repair station is capable of competently undertaking the work. In order to make a ratings-less system really work, the FAA should strengthen the policy surrounding this process and provide better guidance on the sort of audits and documentation necessary to support a change to the capabilities lists. In some cases, repair station manuals have been approved by the FAA that prevent the repair station from adding a new capability to a capabilities list until an FAA inspector has signed-off on the change. The regulations do not require this step, and where the prior FAA approval is interposed, it unnecessarily inhibits the business’ ability to flexibly add repair capabilities. More importantly, it creates an uneven playing field, where some repair stations can change their capabilities lists at will (following verification of capability), while others must wait (sometimes for months) in order to get FAA approval of the change. Instead of providing better standards and stronger examples to support equal protection, the proposed rule seeks to make the unlevel playing field a permanent feature, by requiring all repair stations to get FAA approval of capabilities list changes, and then permitting the FAA to exercise unfettered discretion to permit favorites to escape the system with a delegated ability to approve their own capabilities list changes. This is institutionalizing the parts of the process that are broken, making it harder to fix, instead of finding a way to repair obviously

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Avionics News November 2012

Table of Contents for the Digital Edition of Avionics News November 2012
