Aviation Maintenance Magazine Summer 2002
Aviation Maintenance Magazine Summer 2002
Aviation Maintenance Magazine Summer 2002
ENGINE
LEASING
How This Niche Navigated
To The New Normal
Also Inside:
PMA PARTS UPDATE
A FRESH LOOK AT PMA
PARTS AND HOW THEY
HELP SAVE MONEY
DIGITAL TASK
CARDS
STREAMLINING WORKFLOW
ON GUARD
SAFETY EXPERT
JEFF GUZZETTI SHARES
A PERSONAL STORY
ABOUT A B-17
www.mtu.de/en
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SUMMER 2022
Contributing Editors
James Careless Kathryn Creedy
Mark Robins Ian Harbison
Jason Dickstein Dale Smith
COVER STORY Jeff Guzzetti James T. McKenna
into financial gain. The PMA parts industry is aimed towards a DESIGN/PRODUCTION
strong future as they continue to save operators precious money. Lisa Garrison
[email protected]
Embraer's Johann Bordais
24 August marked the fifth anniversary of the launch of Embraer
CLIENT SERVICES
Administration
Services & Support. Ian Harbison caught up with Johann Bordais, Maria Hernanz Reyes
its president and CEO, to get his perspective at this milestone. [email protected]
LIST RENTAL
26 Ray of Hope
A new web-based system from EmbraerX called Beacon offers the
Statistics
Jen Felling
potential for substantially reduced maintenance delays. [email protected]
[email protected]
ENGINES TECHNOLOGY PRODUCTS/ TOOLS SPECIAL REPORT AFTERMARKET
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Back to Normal…
Whatever That Is!
BY JOY FINNEGAN
EDITOR-IN-CHIEF
T
he cyclical nature of our industry has been borne out again manufacturers of these replacement parts. They are more important
with the last two — almost three — years of crisis and than ever with the ongoing supply chain challenges facing the entire
rebound. For those “youngins” who are experiencing their aviation and wider world economy. PMA parts can be a saving grace
first taste of the way aviation works, I say, welcome to the most when parts are needed quickly and with competitive pricing.
interesting industry in the world. It has been impressive to watch “PMA parts, by their nature, are a natural mitigation strategy for
the industry cope with the dire nature of the past years — almost airlines. As a direct replacement for OEM parts, by including PMA
as if they have figured out a few things or remembered what parts in their maintenance programs, airlines are immediately opening
worked in previous crises. up a second FAA-Approved source,” HEICO’s Pat Markham, VP of
The industry survived an almost complete shut down for months Technical Services for HEICO Parts Group, said in the story, specifically
and to me that shows one thing is for sure, aviation will survive referring to airline supply chain challenges.
anything. We have gone from pilot and mechanic shortages and You can learn more from the PMA experts, including the
intense hiring to layoffs and early retirement offers to get those close Modification and Replacement Parts Association (MARPA) president,
to that milestone to leave and now back to worries about shortages in Jason Dickstein, quoted in this feature story starting on page 16. By
the seeming blink of an eye. It’s enough to make your head spin. the way, if your company is not a member of MARPA already, please
For those who took the packages and retired just a bit early, I hope contact them to join ASAP.
you are enjoying your time now and have no regrets. Those offers to We also had a great opportunity recently to speak with Johann
end lifelong careers in aviation early were tempting enough to lure Bordais, president and CEO of Embraer Services and Support. Bordais
thousands of people at all the airlines to leave. 17,000 employees, or is one of those rare eternal optimists who always sees the bright side
20% of its workforce, took buyout packages or early retirement, Delta — a perfect outlook for the leader of Embraer’s efforts to keep their
reported in August of 2020. Thousands also took deals at United and customers in the air and happy. See Ian Harbison’s story resulting from
American. his sit down with this global leader.
Now, we are back to worries about not having enough mechanics That interview also led us to learn more about Beacon. Beacon is the
(not to mention pilot crew shortages that are limiting full recovery EmbraerX (a disruptive innovation subsidiary of the Embraer Group)
schedules at the airlines). As AIA puts it in one of their policy new web-based system that offers the potential for substantially
statements, “A highly skilled and robust aerospace workforce is reduced maintenance delays. The product started out in the executive
essential to our national security and economic prosperity. Yet today aviation sector but is rapidly expanding and has achieved considerable
the industry faces impending retirements and a shortage of trained success with airlines in the last nine months. Learn more from Bordais
technical graduates, which is a situation that is forecasted to worsen and about Beacon in stories starting on page 24 and 26.
within the decade.” There are just no easy answers to the radical One final standout story in this issue is safety expert Jeff Guzzetti’s
impacts to flying like those of the COVID crisis. On Guard series entry. Guzzetti usually highlights an aircraft incident
But now that we are through the worst of it, most folks are vaccinated or accident that has a specific lesson for maintainers. And that holds
and we are moving on as a nation and industry, we wanted to take a true for his latest piece. But in this case, the tale, entitled “The Day
look at a few things that can help and see how some niche areas of our the Nine-O-Nine Died,” has a personal twist that left me hoping the
industry navigated through the troubled waters of the past several years. remaining B-17s of the world continue to survive and filled me with
In our cover story we examine how the engine leasing sector pride for our WWII veterans. Read more starting on page 48.
survived a near shutdown of operations. This crucial sector has a bird’s Finally, we invite you to join us soon for Aerospace Tech Week
eye view of the industry and often sees the impact of the economy Americas which takes place in Atlanta, Georgia on 8-9th November
before others. These folks are eminently able to comment on the 2022. The event provides a unique opportunity for the aerospace
impacts of both the downturns and the recoveries. industry to focus on eight core technology areas like MRO and
We asked engine leasing experts not only how they managed MRO IT, Avionics, Flight Ops IT, Testing and more. There is a main
through these times, but what they are seeing now that times are conference track for each sector which you can mix and match as
better. Tadhg Dillon, chief commercial officer at Shannon Engine well as a free central exhibition. Registration is open now at www.
Support, Patrick Biebel, managing director of MTU Maintenance Lease aerospacetechweek.com/americas/register. The early bird savings on
Services, Oliver James, VP Commercial Trading at AerFin and Anthony the main conferences as well as a 3 for 1 offer make it a great value for
Spaulding, EVP at Magellan Aviation Group gave us an insider look at groups. We are inviting all airlines, military/defense and government to
what happened and where we are headed. In short, Spaulding says the attend for free. Airlines can also can apply for a hosted place including
recovery has been “substantial” and that prices are rebounding. See free accommodation. You can see excerpts from the official pre-show
more in this feature story starting on page 28. guide starting on page 33. We hope to see you there as an attendee,
Next, we got an update about PMA parts from several key sponsor or exhibitor!
FAA’s RGL Has Been Decommissioned, Replaced with Dynamic Regulatory System
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StarterGenerator.com Announces Global Distribution Agreement with Wesco for PMA Parts
StarterGenerator.com has signed a global distributorship agreement with Wesco Manufacturing of Deer Park, New York. The newly
developed and FAA Approved MRO ADVANTAGE Precision Maintenance Kits are now available for ordering. This PMA product is
designed for eligible 150-400 amp Skurka-APC starter generators and features OEM designated expendable hardware items typically
replaced at standard TBO intervals or other repairs. The company says the kit is a combination of value and convenience that make this
product a compelling aftermarket solution – enabling MRO’s to perform a thorough overhaul without having to deal with persistent
supply chain delays, inflationary pricing and multiple source costs.
“We are thrilled to announce a PMA approved and enhanced alternative solution for APC starter generator MRO expendable
hardware. Thank you to everyone involved and for their intense focus to deliver this exciting new product in a timely manner,”
commented Garrett W. Schwarz, president of StarterGenerator.com. “With the inherent convenience and value offered by these kits, and
considering current inflationary pressure and supply chain delays — kits have never made more sense. We are enthusiastic about offering
this new solution to our customers very soon,” continued Schwarz.
APOC has promoted Kevin Wall to take on the role of chief for the business and are fully
commercial officer. Previously senior vice president of business supported by a solid investment
development across the Americas, his new remit will focus on strategy. “I anticipate that with
shaping future growth, consolidating market share and nurturing APOC’s innovative business
a team of success-driven people. “Driving the unique company model and secure financial
culture at APOC and building upon the fresh approach that has status we will be able to not only
seen the business expand exponentially in just seven years is both take advantage of investment
a challenge and an exciting opportunity,” Wall says. opportunities in engines, landing
Wall will be running APOC’s global commercial operations gear and airframe assets, but
from the new Miami office which opened earlier this year. This also to wisely shape our support
expansion has been met with great enthusiasm from APOC’s programs as airlines evolve and
airline and lessor customers throughout the Americas, as well explore new ways to operate.”
as the organization’s MRO business partners and audited Looking ahead over the next year Wall predicts further
workshops throughout the region. “We continue to believe as a changes in the aviation sector. “Mergers & acquisitions are on
truly global player that further expansion into other markets is a the rise. Not just airlines themselves but the aftermarket MRO
logical development,” explains Wall. “Over the next 12 months sector is attracting a lot of interest from investors. The industry
we will be exploring the next direction for APOC’s global continues to consolidate and evolve and APOC will shape our
footprint.” services accordingly. Teamwork and technology are what makes
Alongside many other after-market specialists post-COVID, us different at APOC and our ambition is to provide top-quality
APOC is experiencing an aviation industry on a rapid road to innovative USM solutions where our customers need it and within
recovery. According to Wall, airlines are struggling to meet the their budget. We are seeing a surge in demand as airlines are
increasing demands and supply chains are finding it hard to increasingly turning to USM to effectively stretch maintenance
cope. “The used serviceable material (USM) sector is becoming budgets while preserving operational availability.”
increasingly important to sustain the supply chain and underpin Max Lutje Wooldrik, CEO at APOC, said Wall’s background
flight service as capacity builds. APOC's expertise in providing and expertise are a perfect match for a fast-growing company
USM (Used Serviceable Material) solutions is market leading.” like APOC. “Kevin is a highly respected member of the aviation
In terms of business development over the next 18 months, Wall community with a reputation for team motivation and commercial
says that APOC will be focusing on its program of narrowbody success and we have benefitted from his knowledge over the past
aircraft teardown and on the rapidly expanding leasing and trading year. I know that he will bring the energy and dynamism needed to
of both engines and landing gear. These are key areas of growth take APOC to the next level,” Wooldrik said.
Effective beginning the 1st of July, David Lamoureux has assumed Michael Grootenboer, AFI
the role of chief executive officer at Bonus Tech, an Air France KLM E&M SVP group engines
Industries KLM Engineering & Maintenance joint venture based in product and Bonus Tech Inc.
Miami and an engine teardown expert. Engine teardown facilitates “I want to welcome David
the generation of used serviceable and repairable material from to the Bonus Tech family. I
end-of-life engines and is a key enabler of circularity in engine am fully confident that with
materials, contributing to the drive for sustainability in the aviation his extensive knowledge and
industry. experience he will continue
Lamoureux succeeds Aurélie Kergoat, who in her five years as the development and success
Bonus Tech’s CEO has led its development into the company it of the company.”
is today. Kergoat drove growth in Bonus Tech’s engine portfolio, Lamoureux arrives with
increased turnover and profitability, and launched the development 15 years of experience in
of complementary services for its customers, for example, engine the MRO Engine business at AFI KLM E&M, from dedicated
inspection to be offered through Bonus Tech Engine Services, logistics, asset lifecycle management, engine maintenance
including Part 145 Approval. operations and most recently served as technical sales
“I want to warmly thank and commend Aurélie for the leadership director for CFM56-5 and GE90 Engine maintenance services
she has demonstrated, for her tireless efforts and for the fantastic worldwide. He also brings project and change management
shape in which she hands over Bonus Tech Inc. into David’s hands,” experience as a Six Sigma Black Belt.
European Enquiries:
Call +1 (613) 703-6161 Email [email protected] call +44 (0)1264 316470 Email: [email protected]
www.ccxtechnologies.com www.EvolutionMeasurement.com
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Wencor Announces Extension of Purchase Agreement with ALP Aviation through 2027
Under the General Terms of Agreement (GTA) with Airbus Defence and Space, for the maintenance of the C-295 aircraft, OGMA has
delivered a C-295 aircraft to the Portuguese Air Force. The aircraft carried on an inspection (4Y+2Y+C+6M+600H+300H+SBs), defects
repair and additional maintenance services.
Virgin Galactic announced that former Delta Air Lines executive to safety, quality, and process improvement will be indispensable
Mike Moore has been appointed executive vice president, as we enter this chapter.”
Spaceline Technical Operations, effective August 22. Moore joins the company following a decade-long career at
Moore will lead Virgin Galactic’s technical operations and Delta Air Lines, where he led Delta’s TechOps Services Group.
maintenance team in charge of ensuring the company’s vehicles While at Delta, Moore supported the introduction of two major
are ready for flight. As part of this new position, he will help next-generation engine maintenance partnerships with Rolls-Royce
design and implement the operational model and technical and Pratt & Whitney. After beginning his aviation career as a
infrastructure needed to support high cadence spaceflights during mechanic in the U.S. Air Force, Moore also worked at Chromalloy
commercial service. Moore will report to CEO Michael Colglazier. Georgia, Northwest Airlines and TIMCO Aviation Services, and has
“A major part of delivering the Astronaut experience at Virgin served as a partner to TeamSAI.
Galactic sits with our technical operations team, which ensures “Joining the world’s first commercial spaceline during this
our Spaceflight system is fit and ready to fly,” said Colglazier. “I pivotal period of expansion is an honor,” said Moore. “Virgin
am thrilled that Mike is joining us to lead the expansion of our Galactic is an industry pioneer with a distinctive product and an
talented technical operations team at Spaceport America as we exceptionally talented team. Entering high frequency commercial
develop our capabilities in preparation for commercial service. service will see a step-change in their day-to-day technical needs,
Mike has more than 28 years of experience overseeing daily and I look forward to working with the team to expand, build on
aerospace operations, and his expertise and steadfast dedication their cutting-edge operations and meet their goals.”
CARING
FOR
CLEANER
W AY
T O F LY
Bluetail Launches First Nationwide Onsite Aviation Records Scanning Coverage Via Crowdsourcing
Strong Rebound In Pax Traffic From Korea Boosts Philippines MRO Dornier Technology
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PMA PARTS INDUSTRY
MASTERING COVID FALLOUT
James Careless
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provide to operators.”
PMA parts manufacturer Certex
Aviation is also finding opportunities in the
post-pandemic market, but in a slightly
different way. “Getting raw material has
not been a problem for us, although
prices are climbing,” said Tim Feeney, the
company’s president. The result: “When
the airlines started flying again and demand
increased rapidly, we were able to grow by
manufacturing our competitors' products (for
them, under contract) while investing in new
products for ourselves.”
GLOBAL NETWORK OF
SPECIALISTS IN AEROSPACE
TRANSPORTATION
Contact us now on
www.aln.aero
Helping Customers
By its very nature, the PMA parts industry
is built to help airlines and other aircraft
operators find the parts they need when they
need them. This has always been the case,
even before the global supply chain was
thrown into chaos by the pandemic. It is even
truer today in COVID’s wake.
“Even before COVID, one of the PMA
industry’s chief selling points is always having
FAA-approved aircraft parts on the shelf so
that air carriers and others could get them
quickly whenever they needed them,” said
Dickstein. “During COVID, many PMA parts
companies took special care to make sure
their shelves were fully stocked, because they
anticipated that air carriers would start flying
again and would need those parts fast.”
“That's actually one of the things that
I've heard from air carriers that they really
appreciate about the PMA industry,” he
continued. “Sometimes they go back to
the production certificate holder and say, ‘I
need this part’ and the production certificate
holder quotes a long lead time. Meanwhile,
the PMA companies offer FAA-approved
alternatives that are drop-in replacements
and are available today.”
HEICO's Markham concurs. “Whether it is
providing that FAA-approved replacement
part for today’s AOG, or helping an airline
with long term maintenance cost savings, the
PMA industry is here to help,” said Markham.
“The stress that the pandemic put on airlines
has encouraged them to look beyond their
‘usual solutions’. We have had an abundance
of new customers come to HEICO looking
for tactical and/or strategic solutions through
Jet Parts Engineering says the current ongoing supply alternative parts programs.”
chain challenges have had a positive influence on the and eliminate any surprises.” Solving customer problems is a top
continued acceptance of PMA parts by airlines. Shown
here are an array of PMA parts that company produces. Jet Parts Engineering isn’t alone in priority at Jet Parts Engineering (JPE).
Jet Parts Engineering image. accepting the realities of a COVID-battered During and after the COVID, the company
supply chain and making allowances to cope has been trying to be as communicative as
with it. “Recently Core Parts has reviewed possible with its client base, so that its staff
our entire catalog of parts and generated understands which pain points its customers
re-supply purchase orders from our are experiencing due to their supply chain
manufacturers as much as six months prior issues. With this knowledge, Jet Parts
to when our typical order window would Engineering can step in with useful solutions
otherwise normally be,” said Hinkle. in a fast and timely manner.
Certex Aviation is also adjusting its “Sometimes we’ve solved problems
workflow to account for supply chain delays, quickly by providing a PMA data package
while accepting an increasing number of and part for a new approval for immediate
post-pandemic PMA parts orders. “The use,” said Voeller. “Other times we’ve set up
growth we've seen is not always seamless, long term plans where we schedule blanket
and we do sometimes have challenges with orders over the course of a year, so we can
our promise dates,” Feeney acknowledged. plan for the customer’s known demand.
“However, based on customer feedback, we Where possible, to best serve our customers,
seem to be doing much better than our OEM JPE works to hold excess inventory in stock,
counterparts on lead times. Nevertheless, so not only do our parts reduce maintenance
if there are issues, we manage customer costs on a per part basis but they’re also
expectations as early as possible and stay readily available. It’s these times that being
in constant communication with them with flexible and creative really help.”
respect to our status in filling their orders.” At Certex Aviation, helping customers
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HEICO says they continued to fund R&D and kept
producing more than 400 new PMA parts each year. turbine engine components during regularly areas of the world that were closed to this
Shown above is a PMA part in the process of fit- scheduled overhauls are commonly our option are now beginning to adopt these
testing. HEICO image.
targeted products.” practices and putting resources toward
implementing PMA programs.”
The Time is Always The result? “The PMA market will
Right for PMA Parts continue to grow, both in overall share
There’s another old saying that applies of material being consumed in aircraft
to the PMA parts industry in the wake of maintenance and in the acceptance within
COVID-19: ‘It’s an ill wind that blows no more aircraft systems,” Voeller predicted.
good’. This saying, which alludes to the “Initial PMA programs at airlines who have
winds used by sailing ships to reach their never used PMA will typically start with
destinations, points out that being in the interior parts, then expand into airframe,
worst of situations offer opportunities for components, and engine parts. We’re
some good to arise. When it comes to the seeing new airlines chasing PMA benefits
pandemic, the opportunity for acceptance their competitors may already enjoy
of PMA parts by cash-strapped aviation and jumping in head-first by accepting
customers who avoided them before the any, and all, parts without limitations to
current supply chain crunch hit. specific aircraft systems. This will likely
We have touched on this point continue, which will be a nice tailwind for
throughout this article, but it is of such the PMA market.”
significance that it deserves spotlighting: “Going forward, I think that the market
The aftereffects of COVID-19 have created for PMA is going to be very good,”
very favorable market conditions for MARPA’s Dickstein concluded. “In my
PMA parts manufacturers. “Airline costs experience, when there are troubles in
such as fuel, labor, cost of capital, and aviation and the PMA industry steps
maintenance are increasing rapidly and up and supports the MROs and the
saving money is becoming more and air carriers, the MROs and air carriers
more critical,” said Voeller. “As a result, recognize and remember it. As well, the
PMA is becoming a ‘need’ item, not a fact that the PMA industry has provided
‘nice- to-have’ and we are seeing more that full level of support and customer
airlines factoring PMA into their cost service in the past and is providing it to
reduction strategies. Additionally, while their customers today is something that's
many global markets are more open and going to help them cement relationships
accustomed to using PMA parts, other that will lead to future business.”
24 Aviation Maintenance | avm-mag.com | Summer 2021 AEROSPACE TECH WEEK 3/4 November 2021 | Toulouse, France | www.AerospaceTechWeek.com
August marked the fifth anniversary of the
launch of Embraer Services & Support. Ian
Harbison caught up with Johann Bordais,
Ian Harbison its president and CEO.
J
ohann Bordais says it in the defense,
is all well and good to commercial and support
design, manufacture markets. Bordais
and deliver an aircraft says there are similarities between Bordais says the timing is perfect as the
but it is support for the Embraer and Fokker Services as both e-commerce market is still expanding and
customer afterwards that is the best way are well-known and reputable aerospace the aircraft’s field performance means it
to establish a good reputation in the companies with roots in building aircraft can utilise a range of smaller airports than
industry. He feels that Embraer Services & and supporting aircraft fleets worldwide. larger narrowbody freighters, reducing
Support (ES&S) has achieved this, coming As a result, the MoU the companies delivery times. Feedstock is available
at the top of a number of independent announced, in July, the intention to as many earlier E-Jets that entered
aviation surveys. The company has deepen the collaboration in several service around 10-15 years ago are now
manufactured more than 8,000 aircraft projects, mainly related to the services emerging from long term leases and
and still supports one very early EMB 110 and support fields. The companies being replaced. The conversion should
Bandeirante, now some 45 years old. are looking at aftermarket support extend their life by another 10-15 years.
Following the abortive deal with Boeing, topics, such as aircraft modifications The company sees a requirement for
ES&S has refocused and now works across and customization, program support, 700 aircraft over the next 20 years and is
all divisions of the company – Commercial logistics, repair services. Looking aiming for a 20% market share.
and Executive Aviation, Defense & further in the future, conversion and The initial conversions will be carried
Security and Agricultural Aviation. That completion of Special Mission and out at São José dos Campos. This will
means good ideas from one sector can be Special Transportation aircraft in Defense, include a main deck front cargo door;
quickly adopted and adapted by another including collaboration for the C-390 cargo handling system; floor reinforcement;
to suit its customer base. multi-mission aircraft, whilst for the 9G Rigid Cargo Barrier with access door;
A good example of this intra-company Commercial aviation market, engineering, cargo smoke detection system, including
cooperation is the Sorocaba Service repair, and logistics support will be key Class E extinguishers in the upper cargo
Center, just over 100 miles west of the elements to be explored, in addition to compartment; Air Management System
company’s main facility at São José dos Hydrogen Powered Aircraft development. changes (cooling, pressurization, etc);
Campos. This was established in 2014 Previously, in May, Embraer announced interior removal and provisions for
and has been operated primarily for a multi-year agreement for Fokker hazardous material transportation. The
the Executive Jets division, providing Services to provide MRO services company is currently evaluating the work
maintenance, interior refurbishment, covering 60-part numbers of engine package and looking at where the expertise
hangarage, airport services, stopover line replaceable units (LRUs) enrolled of outside suppliers might offer advantages.
assistance and aircraft preservation. in Embraer’s Pool Program. The Pool The first conversion should take seven
In addition, it has workshops for Program, which supports Embraer’s first- to eight months and be completed and
component overhaul and the capability generation E-Jets aircraft, now covers 700 certified in 2024, but this should reduce to
to perform aircraft modifications, such E170, E175, E190 and E195 aircraft flying three months as production ramps up to
as the conversion of Legacy 450 jets into with more than 50 airlines worldwide. The five a year in 2025 and eventually to 10-12
Praetor 500 jets. latest contract announced was with LOT per year. If there is sufficient demand,
The Center recently doubled its Polish Airlines, which, at Farnborough, further conversion could be added, based
capacity from 20,000 m² to 40,000 m² renewed and added seven E-Jets to on customer location.
and now has four hangars, three of the original contract, with the Pool now The program kicked off in May with an
which are dedicated to MRO services covering a total of 44 aircraft and over agreement with Nordic Aviation Capital
and one to support fixed-base operator 300 components. (NAC) for 10 conversions. At Farnborough,
(FBO) operations. The extra space will A major project for ES&S is the E-Jets in July, NAC announced an MoU to place
not only cater for the expansion of Passenger to Freight (P2F) conversion, the first two E190F conversions with
business aviation in Brazil but can be which was launched in March this year. Astral Aviation, based in Nairobi, Kenya,
used for commercial and defense aviation This will be based on the E190 and the while Embraer signed a firm order for a
customers. E195 and is intended to fill the gap further 10 Embraer conversions with an
Another example is an MoU signed between turboprops and narrowbodies undisclosed customer.
with Fokker Services and Fokker Techniek while replacing less fuel-efficient regional See related story on Embraer's Beacon
in October 2021, to explore opportunities jet freighters. product next page.
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RAY OF HOPE
As Beacon knows how long a repair typically takes, maintenance control can alert flight operations if a significant delay is likely. That avoids potentially costly passenger
compensation and reputational damage. Embraer image.
I
f an aircraft encounters because of duty times, passenger can be tailored to the requirements of
a technical fault, there compensation and airline reputational individual operators. Once a problem
is a complex process to damage. is raised, it is assigned a case number
be followed to ensure its Back in 2016, EmbraerX, the OEM’s and everyone is alerted. In addition,
resolution and a return innovation accelerator, decided to take Beacon looks at maintenance records
to operational service. Unfortunately, a look and see if a new approach could and pulls together the repair procedure
it is so complex that there are systemic be developed, launching a new concept for the mechanic and the parts required
inefficiencies built in. There are so now called Beacon. Starting out in the to complete the work. That drawdown
many different departments involved, executive aviation sector, it has achieved can also be passed to the inventory
along with lack of systemized resources, considerable success with airlines in the management section of the company’s
communication tools and data overload, last nine months. ERP system. Crucially, it also brings
that delays are inevitable. The knock on By applying a human-centric approach up the average repair time. This early
effect of these include delays to scheduled and a web-based solution, Beacon brought warning allows maintenance control to
maintenance, grounded aircraft, the together all the resources and people that contact flight operations if a lengthy
need for spare aircraft, crew rescheduling are necessary to resolve a problem. These delay is likely, allowing them find a
replacement aircraft and avoid all the
crew and passenger issues outlined
above.
The size of the problem, says Marco
Cesarino, director of product, can be
judged from the fact that, in 2019, 24
million flights in the U. S. that were
delayed or cancelled cost the industry
$33 billion. He adds that 80% of the
time needed to resolve a problem in the
traditional way is devoted to coordination
rather than to the actual fix.
In October 2021, EmbraerX signed
a multi-year agreement with Republic
Airways for the use of Beacon, which
Once a problem is raised using Beacon, it is assigned a case number and everyone is alerted. Embraer image. is supporting the airline’s digital
26 Aviation Maintenance | avm-mag.com | Summer 2021 AEROSPACE TECH WEEK 3/4 November 2021 | Toulouse, France | www.AerospaceTechWeek.com
Beacon, a new web-based system
from Embraer X, offers the potential
for substantially reduced maintenance
Ian Harbison delays.
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COVID-CREATED ROLLER COASTER RIDE
FOR ENGINE
LEASING COMPANIES
Ian Harbison
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Experience Gained
For SES, Dillon credits several factors: the
experience gained during the 2009/10
financial crisis; a healthy revenue stream; a
resilient and innovative team of people; strong
customer relationships; and a global customer
presence.
Patrick Biebel, managing director of
MTU Maintenance Lease Services, MTU’s
Amsterdam-based leasing and asset
management arm, says his company
specializes in a wide range of narrowbody and
widebody engines from the CF34 up to the
GE90, primarily focusing on short-term leases
(up to two years) to support maintenance
AerFin says it remains well positioned with a healthy same situation for different reasons. He says events. He agrees that before the pandemic
volume of equipment in its acquisition pipeline to
support the next phase of growth for the business. a lot of the MROs, airlines and suppliers hit, the industry was under strain driven by
AerFin image. let go of a huge number of people during current generation engines approaching their
the pandemic because of their financial shop visit peaks and phase-in challenges of
situation. Replacements are difficult to find new engine equipment. This meant older
and are usually much less experienced than aircraft were staying in service longer than
the previous staff, as well as increasing expected.
turnaround times. Supply chain issues now When COVID hit, MTU Maintenance
involve both new parts from OEMs and used Lease Services relied on its established risk
serviceable material (USM). There is also management strategy with an engine pool
a focus on newer generation engines and made up of three components: owned
resolving their technical problems. engines, long-term lease and short-term lease.
He says that, pre-pandemic, the This approach allowed for a quick response to
competition was usually other lessors or the changes in demand driven by the ongoing
MROs that might have engines available. pandemic situation. At the time, airlines were
That changed as airlines wanted to avoid deferring maintenance and often, when faced
leasing and maintenance costs, seeing it as with a shop visit
negative cash flow. Instead, they would look that might require
at alternatives from a financial perspective, a multi-million-
such as the need to fly the aircraft and, if dollar investment,
they did, the maximum they could pay for would swap
an engine, based on passenger demand. engines from their
They also considered using an engine from parked fleet or opt
another aircraft, using a spare that was on for a lease engine,
the ground, or leasing an aircraft on a power taking advantage
by the hour basis, Additional competition of more favorable
now came from aircraft lessors with aircraft lease rates.
on the ground, airlines that wanted to lease As the drivers Patrick Biebel
MTU Maintenance Lease
an engine to another airline and aircraft part of demand Services
out organizations. are evolving,
It is returning to normal, but the focus the industry is facing new obstacles. The
is still on cost, each deal being done on a MRO supply chain is experiencing capacity
financial basis. He says SES has scale of its shortages, while airlines now need to ramp
operations but also through the provision of up their operations quickly, but are faced with
customised long-term solutions. This could staffing shortages, deferred maintenance
extend out to 10 years, looking at total and a need for lease engines. He says engine
demand and developing a structure with the lessors are positioned to help smooth out the
customer that meets all their spare engine ramp up – he reckons it may take about two
needs. It might also cover fleet transitions – years for the industry to fully recover.
A320ceo Family to neo, Boeing 737NG to The assets most unlikely to recover from
MAX. COVID, he adds, are engines related to
As for the future, interest rates and fuel more niche aircraft, such as the A340 and
prices are challenges as they are costs that A380, although these are not leasing markets
should be passed on, along with the threat served by MTU. In addition, earlier CFM56
of recession. Perhaps the biggest threat and V2500 models also saw significant value
is inflation, as it can have a direct effect pressure, especially for teardown assets.
on passenger sentiment and associated During uncertain times, many market players
demand. focused their maintenance activities on newer
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for the CFM56-7B has since there is an
approximate 4:1 ratio in favor of the 737-
800F over A321F conversions currently.
In addition, the A321 also has an engine
choice – there is a 70/30 split between IAE
and CFM. The SV costs for the V2500 is
higher than the CFM56-5B but the V2500
has the advantage of EGT retention.
However, he thinks it likely that an A321
freighter will bulk out before it grosses
out, which allows operators to derate a bit
more and extend engine life.
It may be a similar acquisition strategy
for the CFM56-5B powered A321s
as happened with the 767 freighter
feedstock, where everyone was trying to
find CF6-powered aircraft for conversion
due to lower SV costs compared to the
PW4000. Additionally, as 737/A321 P2F
feedstock acquisitions are being made,
AerFin says it took a risk managed approach through Green time engines are still an important one of the issues buyers are finding and
the pandemic. The company was selective with
how it managed and deployed capital. Most of its lever for the airlines to manage cash spent dealing with is aircraft that were returned
focus remained on supporting asset owners through on MRO. For example, airlines are finding during the pandemic tend to have one
consignment programs, sale and lease back schemes
and asset remarketing. AerFin image. it difficult to or more engines that is runout or due for
find CFM56-5A an expensive SV. This is helping bolster
engines with values and demand for green time engines,
green time to especially for the CFM56-7B.
defer or replace
an engine due Labor Shortages Will Play
for a shop visit, There is also the issue of extended
On the other turnaround times, narrowbody engine
hand, there is an overhauls now being similar to those
oversupply with previously for widebody engines. Of
the CFM56-5Bs course, this is because of labor shortages
engine type that is Anthony Spaulding and supply chain issues, he makes the
Magellan Aviation Group
depressing lease point that engine piece part repair
rates which makes it favorable for airlines shops are equally affected, adding that
when they need a CFM56-5B. extensive training is required to operate
Airlines with current technology fleets with the specialized machinery needed for
an inhouse MRO function are looking at ways turbine blades, for example. It also affects
to keep the operation running smoothly to Magellan, as spares recovered from tear
avoid SV spend and excessive turnaround downs have to be repaired before they can
times by purchasing engines with a relatively be sold as USM. For the OEMs, he notes
fresh SV. If they can purchase a replacement raw materials, such as precious metals that
engine, park or sell the run-out engine, this are/were sourced from Russia, could also
alleviates unforeseen SV cost escalation become a problem as demand recovers for
and avoids operational disruptions due to new build deliveries.
excessive turnaround times for engines being He too feels that it will take about two
repaired. years, hopefully less, to recover but this
He comments that, thankfully, the days of depends on the labor market, as there are
an ‘all in’ rate have just about disappeared, general shortages in every area of aviation.
that is, airlines only paid a cost per hour when One way for the industry to recover
they flew, a trend that started in early 2021 from this current situation is to make a
with aircraft lessors, as there was no revenue concentrated effort to reach out to young
from parked aircraft. The traditional model of people to bring on a new generation that
rentals and lease fees has returned, although an aviation career will be positive career
the rates are a little soft but recovering – a choice for professional growth with a well-
CFM56-7B26 pre-pandemic was $65-70,000/ paying salary.
month, it is now $45-50,000+ and climbing, On a more positive note, the spending on
while it is even lower for the CFM56-5B due maintenance has definitely picked up in the
to the oversupply. aircraft and engine MRO space that are key
He says the P2F market hasn’t yet customers, which is good news for Magellan
helped the -5B rebound like the demand and the industry as a whole.
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T
he traditional paper trail task cards has been a boon for the MRO procedures have been followed through
associated with MRO industry. Not only are electronic task the use of automated checklists, record
repairs tends to be a cards easy to access, read, and modify inspection signatures, and send data to
long and complicated on the shop floor using workplace tablet the Billing Department when the work is
one, culminating in computers, but the data they hold and done.
a blizzard of task capture can be easily stored and shared This is just some of electronic task cards’
cards that tell MRO across the entire MRO enterprise. Among positive impacts on the MRO industry
technicians what to do and to record what other things, electronic task cards can be and a glimpse at their potential to make
they have done. used to track and document job progress, this business more productive, efficient,
This is why the creation of electronic schedule sub-tasks, ensure that proper and accountable. To gain an in-depth
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electronic task cards has been proven
to improve the operational efficiencies
— not only within the engineering and
technical records functions but across
the downstream maintenance process,”
Rajarajan said.
[email protected]
and technical concerns that have to
be documented and attended to. The
adoption of electronic task cards can go
a long way to streamlining this process,
by making it faster and easier to execute
while at the same time improving
transparency and data sharing for all.
A case in point: “Electronic task cards
can provide a way for engineers and
mechanics to have direct access to work
instructions generated by a Maintenance
and Engineering (M&E) system alongside
all supporting publication excerpts such
as Aircraft Maintenance Manual (AMM)
procedures,” said Steeves. “Once
EmpowerMX digital task card hyperlinks to the AMM and IPC via artificial intelligence. EmpowerMX image. completed in the digital system, task card
compliance data could be automatically
fed into the M&E system to complete
a task. Today, this is a manual process
completed by technical records teams
that takes a lot of time.”
It helps if this functionality is purpose-
built into the system. For example,
“EmpowerMX supports digital non-
routine task cards as a matter of course,”
said Schmidt. “By enabling eTaskCards
on that pre-existing framework, the
electronic task cards are automatically
integrated into an already optimized
workflow without having to take on any
additional integrations or processes.”
Meanwhile, when it comes to precisely
NR material association by adding in material
tab of the eTaskCard. EmpowerMX image. technicians’ productivity through streamlining the integration of third-
electronic task cards is by eliminating the party task cards into an MRO data/task
need for them to go back and forth to a management system, “the first step in
desktop computer to look up manuals. the process is to seamlessly ingest and
“EmpowerMX eTaskCard automatically process SGML/XML based documents
converts manual references for sub-tasks complying to ISPEC 2200 and S1000D
into clickable hyperlinks that show up on standards from the OEMs,” Rajarajan
the electronic task card screen,” Schmidt said. “The ingested task cards are then
explained. “When the technician gets to customized by the MRO through user-
a step with a hyperlink, they just click on friendly screens to add additional texts,
the link and read the sub-task from within warnings, tables, formulas and graphics
the manual reference, all without leaving to the MRO’s own electronic task cards.
their task card app.” Then, whenever the technician finishes
Similarly, an AI-enabled electronic task the job, the complete task card with OEM
card can simplify the ordering of parts and customized instructions are available
during a job. “When our EmpowerMX on the MRO’s Point of Work internal
Materials Module is combined with the website for reference and sign off.”
EmpowerMX eTaskCard, the technician
can simply hyperlink over to the IPC Improving Maintenance
(IIlustrated Parts Catalogue), copy the Tracking
part number, paste the need into their Consistently executed, properly
electronic task card, and order their documented aircraft maintenance is
parts,” he said. “Since it's all being done a must for MROs and their aviation
by this system, there's no need to record customers. This is why proper maintenance
the part information in the electronic task tracking is more essential than ever.
card. That's all done in the background.” Electronic task cards satisfy this need
nicely, improving both the accuracy and
Streamlining the Workflow completeness of maintenance tracking.
The MRO workflow is a complicated, In fact, “electronic task cards can help
often cumbersome process, due to improve maintenance tracking in several
the interplay of customer, compliance, ways,” said Schmidt. In this system, no
Reducing Downtime,
Improving Turnaround Time
Less downtime and faster turnaround
time (TAT) was a priority for MRO
customers – particularly airlines! – before
EmpowerMX's eTaskCard also offers automated material association on removal/install. EmpowerMX image.
COVID-19. In the pandemic’s wake,
achieving both of these goals is more
task cards can be lost since they are important than ever.
digital, and no pages can be scanned By making the MRO process more
incorrectly when being recorded into the integrated, coordinated, faster and
work order. “No steps can be missed far less vulnerable to human errors,
when the AI requires them to be signed electronic task cards can help MROs
for, while parts that are ordered and hit both of these marks. Sometimes the
used for a task do not get forgotten or improvements provided by electronic
incorrectly transcribed,” he explained. task cards are subtle but significant.
“All told, the use of electronic task “For instance, the system could highlight
cards is the most optimal approach to conflicts where tooling or access may
maintenance tracking, making it much be needed by multiple engineers,” said
more accurate and reliable. From a Steeves. By flagging these conflicts
centralized production control booth, before they actually occur, electronic task
a team can see the status of any job card systems allow MROs to better plan
throughout the facility, right down to the their jobs, including the complex, more
last step completed.” demanding major checks of commercial
On a larger scale, analysis of the data aircraft.
within the electronic task card system Taking a Big Picture view of the
can be used as the basis for process problem, Schmidt observed that,
improvement. “And if a technician notices “Downtime/TAT is the byproduct of a
something about the task or the data technician's ability to perform. When
associated with the task, they can flag a technician doesn't need to take time
for the proper support at that moment,” making corrections, or recording part
Schmidt noted. number information, or going back and
Electronic task card systems can also forth to the computer station, they are
aid in tracking the completion of a building efficiencies,” he said. Moving to
scheduled aircraft maintenance check an electronic task card system delivers
in progress, and in keeping an MRO’s all of these benefits, and thus less
maintenance forecasts up to date and downtime/faster TAT.
correct in their M&E system. “Time savings are also found when
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ON GUARD
Jeff Guzzetti
Photo 2: The Nine-O-Nine s a member of B-17s that were produced, over a third
A
B-17G bomber.
the “Greatest of them — 4,735 — were lost during
Generation,” my combat missions. Lucky for me, he
father served his survived the war, moved back to his
country in the hometown of Beaver, Pennsylvania,
U.S. Army Air became an optometrist, met my
Corps during the mom and raised three boys. I was his
latter half of World War II. Dad was a youngest and I was enthralled with his
navigator in the Boeing B-17 bomber aviation adventures. The B-17 became
(see Photo 1, next page). Of the 12,731 my favorite airplane.
Photo 1:
Lt. Albert J. Guzzetti; Army Air Corp, 1943. Navigator.
Photo 3: Former Lt. Albert Guzzetti, in Feb. 1991, nearly 50 years after he served in WWII, posing in front of the
Nine-O-Nine after it had been rebuilt and was preparing to fire its engines for the first time since an accident four
years prior. Photo by Jeff Guzzetti.
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ON GUARD
The Investigation
The NTSB launched a go-team to
Hartford to investigate the accident,
led by Bob Gretz, one of the best
investigators I know (see Photo 6,
Photo 5: The remains of the Nine-O-Nine at the crash site after the fire was extinguished.
lower left). The team was briefed
that the vintage bomber was being
operated by the non-profit Collings
Foundation as a Part 91 “Living History
Flight Experience” (LHFE) sightseeing
flight to allow the public to experience
the significance and history of the
bomber.
The captain was 75-year-old Ernest
“Mac” McCauley. He held a commercial
pilot certificate and a type rating for
the B-17. He also held a valid FAA
medical certificate and reported 14,500
hours of flight time, of which nearly
half was logged in the Flying Fortress.
He was the most experienced living
B-17 pilot in the world. In addition,
he held a mechanic certificate with
airframe and powerplant ratings.
McCauley resided in Arizona, but was
a full-time volunteer pilot and traveled
with the B-17 wherever it went. He
Photo 6: Bob Gretz, NTSB Investigator-in-charge (center) walking with veteran technical investigators, Dr. Dan Bower was also the director of maintenance
and Steve McGladry.
for the Collings Foundation. As the
recovered aircraft logbooks revealed,
treasure that photo, especially since my he would sign off the daily checks and
father died two years later from Lou any routine or non-routine maintenance
Gehrig’s disease. that occurred during the course of
Fast forward 27 years, to October flying. In an interview with the NTSB,
2, 2019. I had recently retired from the surviving crew chief explained that
the FAA and was surfing the web the Nine-O-Nine was the center of
when I read the news that the Nine- McCauley’s life. “I mean, he lived in
O-Nine had crashed again. This time, that thing; cleaned it, worked on it,
the accident occurred at Bradley flew it,” he explained.
International Airport near Hartford, During the accident flight, the Nine-
Connecticut. While landing on O-Nine had flown about eight miles
Inadequate Maintenance
In addition to the McCauley’s improper
actions piloting the Nine-O-Nine, Photo 9: The No. 4 engine, as viewed at the accident site.
his lack of action with maintenance
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ON GUARD
wing-spar inspections and repairs can
cost $100,000.
The Nine-O-Nine was equipped
with four Wright R-1820-97 Cyclone
radial engines, each of which had
nine massive cylinders, or “jugs” as
the mechanics of the day would call
them. The continuous airworthiness
program for the B-17G consists of four
inspections conducted at a 25-hour
interval. Inspections one through four
are performed sequentially each 25
flight hours and then repeated.
Examination by investigators of the
Nos. 3 and 4 engines – both located
on the right wing of the airplane –
revealed maintenance issues that were
not adequately addressed by McCauley
or his team.
For example, the No. 3 engine’s
25-hour inspection — which occurred
less than one month before the
Photo 10: Close-up of the No. 4 engine’s left magneto, showing P-lead pulled out of the fitting and with a single accident — required that the spark
strand of safety wire wrapped around the head. plugs be cleaned, inspected, tested, or
replaced with new plugs, and the gap
between the electrodes should have
been checked. However, the spark
plugs were worn with gaps between
the electrodes that were beyond
the manufacturer’s specifications.
The electrodes were too close
together, which caused them to spark
excessively. Most of the nine piston
heads displayed white coloration that
were consistent with detonation rather
than normal combustion, with the no.
4 cylinder exhibiting the evidence of
significant detonation (see Photo 8,
previous page). Detonation in a piston
engine occurs when the fuel-air mixture
in the cylinder explodes prematurely
instead of being ignited by spark plugs
and burning evenly and smoothly,
as occurs with normal combustion.
Photo 11: Close-up of the No. 4 engine’s right magneto, showing the improper gap between the points. Detonation can damage pistons and
cause a loss of power.
before the flight was also examined. The No. 4 engine (see Photo
As the Collings Foundation’s director 9, previous page) had its 25-hour
of maintenance, he was responsible inspection nine days before the
for performing the Nine-O-Nine’s accident, but the NTSB’s teardown
maintenance while it was on tour. of that engine found a different
Vintage aircraft require a significant problem. The engine’s left magneto
amount of care and feeding. Structure P-lead — the electrical connection
and components are decades old. In between a magneto and the cockpit
fact, for each hour a B-17 spends in the ignition switches – was partially pulled
air, ten hours are spent on the ground out of the magneto housing, and the
in maintenance. An engine overhaul grounding tab was in contact with the
can cost $40,000, and required housing. A single strand of safety wire
AEROSPACE
Tech…
ON GUARD
was observed around the retaining nut the need to bolster surveillance and
(see Photo 10 page 52). A functional oversight of LHFE exemption holders.”
test of the magneto showed that the The notice also instructed inspectors to
contact between the grounding tab and perform an audit of all LHFE operators
the housing resulted in the magneto within their geographic jurisdiction.
being shorted to ground and unable to The day the Nine-O-Nine died three
function. The right magneto’s P-lead years ago brought back shades of the
was also partially engaged in its fitting, sadness I felt the day my father died
and the grounding tab did not contact 30 years ago. Dad remains enshrined
the magneto housing. Perhaps this in my memory, as does the legendary
damage was due to impact, but not airplane type that he once guided
likely, said the NTSB. Additionally, the during a critical time in our nation. With
right magneto’s gap between the points only nine airworthy B-17s left, and the
was 0.004 inch, which was less than the steady decrease of the population of
minimum gap (0.008 to 0.010 inch) that WWII vintage airplanes of all types,
the manufacturer required (see Photo the operators of these magnificent
11 page 52). When the magneto was machines must ensure that meticulous
tested, the ignition leads for the no. maintenance is performed on them to
8 cylinder did not spark; the ignition preserve our nation’s history.
leads for the other eight cylinders did
produce sparks, but they were weak
and intermittent. These discrepancies
likely added to the loss of power on the
No. 4 engine.
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LEGAL SPIN
By Jason Dickstein
T
he FAA plans to issue a Safety Management Systems rules that it has identified as a special conditions, and that
(SMS) proposed rule in September. This is something US-based EASA 145 repair stations must follow even though
that every repair station will want to examine, because the US rules do not include such requirements.
the rule is expected to mandate SMS for repair stations. The FAA and EASA have not yet identified EASA’s SMS
rule as a part of the special conditions, so US-based repair
Global SMS stations should not be required to comply with the EASA
This SMS rule is not unexpected. The International Civil 145 SMS until (and unless) they are added to the special
Aviation Organization (ICAO) had originally called for repair conditions. Because the FAA is publishing its own SMS rules,
station SMS rules to be published by 2007. Clearly, most of it is quite possible that the EASA SMS rules will never be
the world missed that deadline. listed as a special condition.
Some countries have had SMS regulations in place for
many years. For example, Japan applied SMS regulations FAA SMS Rules
to repair stations years ago, and has been a leader in SMS The FAA is in their “blackout” period and cannot answer
implementation. questions about the SMS rule, but we can make a number of
Other nations spent time studying SMS and running pilot educated guesses about what the rule will look like.
programs to learn more about what SMS can do (and what It is likely that the FAA rules will follow the ICAO model.
it cannot do). The European Union and the United States If you’ve been reading my articles, then you know that this
followed this model. In the United States, I was privileged to means that there will be four major components of the SMS
participate in two different rulemaking committees designed rules:
to investigate SMS and make proposals. These efforts have
resulted in both regulatory language and also supporting • Safety Policy
statutory language that is meant to support safety data • Safety Risk Management
processes. • Safety Assurance
The world has been slowly moving forward with SMS • Safety Promotion
regulations. An important part of this is having a robust
State Safety Program (SSP) that establishes national metrics It is also likely that the FAA will try to rely on the SMS
and standards for the SMS. The SSP has an opportunity to rules that have already been published for air carriers
serve as a clearing-house for data to support effective SMS (Part 5). The FAA’s air carrier SMS rules address these
programs. four components but also include a fifth component: SMS
documentation and recordkeeping. This fifth component
EASA SMS Rules simply requires the formalization of the SMS program. U.S.
The European Union published an SMS Notice of Proposed law requires documentation requirements to be approved by
Amendment (NPA) in 2013, and finally published the the White House Office of Management and Budget (OMB)
final EASA 145 rules for SMS last November. EASA 145 and as a practical matter this generally means that they
repair stations are required to develop and implement need to be published as rules. The FAA’s documentation
SMS programs by December 2, 2022. That deadline is and rulemaking provisions will require the repair station to
coming up fast, so if you are running a repair station that produce records that the FAA employees can use for their
is directly subject to the EASA 145 regulations, you should own oversight.
be developing your SMS program NOW. If you don’t know The FAA is planning on issuing the proposed SMS rule in
where to start, then you should start by reviewing the SMS September.
articles that I have published in this magazine.
What if you are a US-based repair station with EASA 145 Review the Rule
privileges? In such a case your certificate is subject to the If you are managing a repair station (or just working in
Maintenance Annex of the U. S.-EU bilateral agreement, and one) then this rule could be the most significant change
the related Maintenance Annex Guidance. U. S.-based repair to the repair station community in the past 20 years. We
stations must comply with the FAA repair station rules plus recommend that everyone in the community look at the
they must also comply with the special conditions from the proposed SMS rule and consider commenting on it. This is
EASA rules that have been identified by the FAA and EASA your opportunity to make the rule better:
(this is a gross oversimplification, but it works for purposes
of this article). Each jurisdiction’s special conditions reflect a • If you see language that is unclear in the SMS proposal,
list of requirements that (1) are not duplicated in the other then you should highlight it and offer language that is
jurisdiction’s system and (2) are important enough that they clearer.
reflect additional requirements over-and-above what the • If you do not understand how your repair station will
local rules require. For example, EASA has documentation comply with the SMS proposal, then state this in your
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