The Federal Aviation Administration (FAA) is strengthening the procedures used by air carriers, manufacturers, and the FAA to ensure that air carriers comply with Airworthiness Directives (ADs). A team of FAA and industry experts found that the processes for developing, issuing and implementing ADs work well, but uncovered areas where improvements could be made. The agency’s plan, which concludes in 2011, is aimed at maintaining safety and minimizing disruptions to passengers by improving:
- service information and instructions from aerospace manufacturers,
- air carrier management of planning and prototyping how ADs are implemented,
- FAA coordination with the air carriers through the planning and prototyping process.
In addition, FAA processes will be strengthened to assist inspectors when making compliance determinations and using the Alternative Method of Compliance (AMOC) processes.
Each year the FAA issues about 250 ADs requiring air carriers to correct potentially unsafe conditions. Compliance deadlines range from immediate action before further flight, to days, months, or years depending on the severity and complexity of the safety issue. Air carriers are required to fully comply with all of these legally enforceable directives.
On March 6, 2008, the FAA fined Southwest Airlines for operating 46 airplanes without performing mandatory inspections for fuselage fatigue cracking. The agency found that the airline failed to comply with a September 8, 2004 AD. Then, in late March 2008, several air carriers voluntarily cancelled thousands of flights on MD-80 airplanes amid heightened FAA inspections to make sure that they had complied with a wiring AD (2006-15-15).
Since that time, the FAA has been developing short- and long-term actions to improve the clarity and interpretation of ADs.
From March to June 2008, FAA inspectors found an overall compliance rate of 98 percent in more than 5,600 audits of ADs at U.S. air carriers. While the audit gave the agency confidence that the system was safe, the significant flight cancellations related to AD 2006-15-15 during that time prompted the FAA to probe further by establishing an AD Compliance Review Team. The team was comprised of experts from the FAA, manufacturers, air carriers, an airline association, and independent aviation experts.
Five short-term actions by the FAA respond to recommendations from both the Compliance Review Team and the Independent Review Team (IRT). The IRT, of which FAA Administrator Babbitt was a member in his capacity as an aviation expert, issued a report in September 2008 with recommendations on how to improve aviation inspections while minimizing air travel disruptions.
- The FAA defined a 24/7 process for agency engineers to support inspectors who have compliance questions on complex ADs and support them throughout the approval of urgent Alternate Methods of Compliance (AMOCs).
- The FAA has posted AD-related Boeing Service Bulletins to the Electronic Docket Management System. The FAA plans to expand this to include AD-related service bulletins from other manufacturers.
- The FAA provided a 45-day public comment period for foreign manufactured transport airplane ADs. The previous process provided a 30-day comment period.
- The FAA issued a memo to Flight Standards Service employees to re-emphasize the role of Aircraft Evaluation Group.
- The FAA chartered an agency team to develop a proposal regarding expansion of certain AMOC delegations.
The FAA has chartered an Aviation Rulemaking Committee (ARC) to review and address the AD Compliance Review Team and the IRT recommendations on ADs. The ARC will develop and manage an implementation plan. All actions are expected to be completed by the third quarter of 2011. The FAA has begun drafting proposals for the ARC’s consideration.
AD Compliance Review Team Conclusions and Recommendations
The team examined events surrounding suspected AD noncompliance that caused major disruptions to some airline schedules in 2008 as well as the overall AD process. The team’s goal was to recommend ways to improve the AD process to ensure effective implementation by industry.
The team examined last year’s confusion about implementation of the specific AD 2006-15-15 that resulted in thousands of cancelled flights. The team found that problems in service instructions, workmanship, communications within industry and with the FAA, and FAA inconsistencies in determining AD compliance all contributed to the cancellations and service disruptions. It also determined that a highly charged media environment contributed to an overly conservative FAA response to the situation. The review of AD 2006-15-15 influenced development of the team’s broader findings and recommendations on the AD process.
Overall, the team concluded that the AD process works well and maintains safety. While fundamental changes are not needed, enhancements could be made.
- Original Equipment Manufacturers should make user-friendly improvements to service instructions such as: provide clear instructions; use simplified formats; identify critical tasks; provide flexibility, as appropriate, for the use of alternative methods, materials, and practices; reference standard maintenance and modification practices, and ensure that corrective actions are maintained.
- The Air Transport Association, which represents major U.S. air carriers, should update their Lead Airline Process to support development of clear service instructions. This process helps an air carrier evaluate potential corrective actions for an identified safety issue. The process should recognize changes such as the increase in outsourced maintenance and introduction of foreign aircraft models that have occurred since it was first published more than 15 years ago.
AD Compliance Management
- Compliance Planning: The ATA should update the appropriate specification to include elements for air carrier planning.
- FAA Oversight: The FAA and industry should ensure FAA participation in an air carrier’s AD compliance planning and prototyping processes.
- Maintaining Compliance: Air carriers should develop practices to ensure that normal maintenance does not “undo” an AD.
Communication and Coordination
- Compliance determination decision making: FAA should develop guidance to help FAA employees determine noncompliance. The guidance will clarify the roles and responsibilities of engineers and inspectors as well as the use of professional judgment. It will ensure that decisions are consistent and coordinated at the appropriate level.
- The FAA should strengthen the role of the agency’s Aircraft Evaluation Group: This agency group helps determine pilot qualifications, flight crew training, minimum equipment lists and continuing airworthiness requirements. It will be more involved in the AD process, including AMOCs.
- AMOCs: The FAA and industry should develop a means to strengthen the AMOC process by improving coordination, increasing delegation of AMOC approvals, and providing 24/7 support to FAA inspectors.
The AD reports are available at:
http://www.faa.gov/aircraft/air_cert/continued_operation/media/AD Process Report 7-08-09.pdf
http://www.faa.gov/aircraft/air_cert/continued_operation/media/AD 2006-15-15 Report 6-3-09.pdf