November 18, 2009
Statement of Doug Dalbey, Deputy Director of Flight Standards for Field Operations
Before the House Committee on Homeland Security, Subcommittee on Transportation Security and Infrastructure Protection on Security at Foreign Repair Stations
Chairwoman Jackson-Lee, Congressman Dent, Members of the Subcommittee:
Thank you for inviting me here today to discuss the security of foreign repair stations. As you are undoubtedly aware, the Department of Homeland Security (DHS) and the Transportation Security Administration (TSA) have responsibility for ensuring adequate security at repair stations, both foreign and domestic. Vision 100 — Century of Aviation Reauthorization Act required the TSA, in consultation with the Federal Aviation Administration (FAA), to issue a final rule imposing security standards on all repair stations. Although the FAA’s expertise is in aviation safety, not security, we have offered our comments and assistance when requested, and have worked with the TSA to facilitate their ongoing pre-rule site visits. As always, we stand ready to provide any additional aviation safety expertise the TSA may need in its ongoing effort to promulgate a rule that will ensure the highest levels of security.
While the TSA is responsible for security oversight, the FAA is responsible for safety oversight — determining that the work accomplished at the repair station is being performed in accordance with the Federal Aviation Regulations and the air carrier’s approved maintenance program. Previously, our oversight was based largely on inspector knowledge and information that was available as the result of individual inspections. As the business model for aviation maintenance has undergone changes, so has the FAA’s approach to safety oversight — we have added new methods of tracking and identifying safety risks to strengthen our oversight of both air carriers and repair stations.
Instead of relying solely on information from individual inspections, we now perform a sophisticated analysis of anomalies identified and entered into our system. This analysis provides us with trend information that effectively targets our oversight. Specifically, the new Safety Performance Analysis System and Repair Station Analytical Model tools give safety inspectors the basis to evaluate a repair station, prioritize surveillance, and target our resources to the highest risk areas. We recognize that this risk-based approach can be successful only when our data is detailed and accurate. As a result, we are actively working to further refine our inspection and data gathering processes. This approach enables us to recognize important trends and spot potential problems in order to prevent them. The new surveillance system and accompanying analytical tools are not only a better use of FAA resources, they will enhance safety.
In keeping with the subject of today’s hearing and at the request and direction of the Subcommittee’s staff, I will briefly discuss the FAA’s safety oversight of foreign repair stations. Currently, there are over 700 FAA-certificated foreign repair stations. Prior to issuing a certificate to a foreign repair station, the FAA must determine that the facility meets the same exacting performance criteria that apply to domestic repair stations. Specifically, the FAA determines that the repair station possesses the appropriate housing, facilities, equipment and trained personnel to perform repairs according to FAA standards.
In order to ensure comparable safety standards, despite geography, foreign repair stations must submit to periodic recertification which is not required of domestic repair stations. Our current requirements mandate that every foreign repair station undergo at least one comprehensive, in-depth inspection prior to the renewal of its certificate. This inspection encompasses all of the repair station areas of responsibility under 14 CFR part 145, makes certain the original certification requirements continue to be met, and ensures that the station performs maintenance functions in accordance with the air carrier’s FAA-approved program. In the years the FAA does not perform a renewal inspection, the FAA performs annual surveillance according to defined work program guidelines.
Also, foreign repair stations must show they have customers with U.S.-registered aircraft or customers with parts used on U.S.-registered aircraft, for which a FAA certificate is required.
While the standards for inspections at foreign and domestic repair stations remain the same, the promulgation of international agreements has impacted FAA foreign repair station certification and surveillance activities. The Bilateral Aviation Safety Agreement with Maintenance Implementation Procedures (BASA/MIP) is a “country-to-country agreement” with primary focus on the harmonization of maintenance rules and requirements and safety standards for those entities performing maintenance activities. These agreements, which the United States has with France, Germany, and Ireland, remove duplicative efforts by the FAA and the national aviation authority and provide for each authority to perform certification and surveillance activities on behalf of the other, while reserving the right of each country to certificate or renew certification of the 174 relevant repair stations.
In addition to FAA and foreign national aviation authorities, air carriers constitute a third layer of oversight. Ultimately, FAA regulations place responsibility for overseeing all maintenance done on their aircraft by any maintenance provider with the air carrier. Air carriers are required to have a quality management system, which we call the “continuous analysis and surveillance system” (CASS), for monitoring and analyzing the performance and effectiveness of their maintenance programs. If any repair station returns an aircraft to the air carrier with problems or the air carrier had to reject repair work for any reason, then the air carrier’s quality management system would enable the carrier to track the problem and check for similar maintenance errors in its fleet.
While we are confident in the effectiveness of our oversight regime, our efforts to improve oversight are ongoing and we are committed to maximizing our already robust safety oversight system. In 2003, we implemented revised regulations applicable to repair stations including improved equipment requirements, and more detailed criteria for the use of external maintenance providers by repair stations. Our efforts have also included work to address specific areas where the Department of Transportation Office of the Inspector General (IG) has made recommendations. In 2005, we issued guidance to enhance oversight of repair stations based on system safety requirements and risk assessment. In 2006, we developed and implemented software to further enhance our oversight, risk assessment, and risk management processes. We have also improved our Safety Performance Analysis System to provide enhanced information sharing. Additionally, we have strengthened the training requirements for certain repair station personnel.
In September 2008, the IG’s office issued its most recent report on repair stations, along with seven new recommendations. Some of our most recent actions include: (1) implementing procedures to improve information sharing through FAA’s newly integrated Safety Performance Analysis System; (2) modifying existing inspection documentation requirements with foreign aviation authorities to ensure the FAA receives sufficient documentation; (3) developing a process to capture results from foreign aviation authority inspections and FAA sample inspections of foreign repair stations in our Program Tracking and Reporting System; and, (4) modifying procedures for conducting sample inspections. We are committed to enhancing our essential oversight capabilities and will continue looking for ways to do so.
Just as aviation safety is in no way compromised by allowing U.S. carriers to fly aircraft made in Europe, in Brazil, or in Canada, safety is in no way compromised by allowing other countries’ facilities which perform to our safety standards, to conduct repair and maintenance on our aircraft. However, we fully embrace the crucial role oversight must play in ensuring quality maintenance operations — regardless of where they are conducted. I understand and appreciate this Subcommittee’s concerns about the flying public and assure you that we are committed to making advancements and adjustments in our safety oversight to ensure the highest standards of maintenance at foreign repair stations. As always and in every aspect, the FAA is focused on finding ways to improve upon this historically safe period in U.S. aviation. I also understand and appreciate this Subcommittee’s concerns about the security of repair stations abroad. On that point, I reaffirm our willingness to lend our aviation safety expertise to assist the TSA.
Madam Chairwoman, Congressman Dent, Members of the Subcommittee, this concludes my prepared remarks. I would be happy to answer any questions that you might have.