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Aviation Rulemaking Committee (ARC) Completes Work

In 2008, the FAA and industry were hit with flight cancellations due to suspected compliance issues regarding airworthiness directives (ADs). Two “teams” (the Independent Review Team (IRT)) and Airworthiness Directive Compliance Review Team (AD CRT) were chartered and issued reports that discussed recommendations.

In 2009, the FAA Administrator chartered an ARC “to evaluate and address the recommendations of the IRT and AD CRT relating to ADs.” The ARC completed its tasks and issued its final report on August 20, 2011; ARSA played an important role on the committee and Executive Director Sarah MacLeod served on its AD Implementation Working Group.

The root cause of concerns over compliance centers on the FAA’s system for correcting unsafe conditions in rulemaking but not completely following through with the design approval holder’s changes to type design for future maintenance activities. In other words, the type certificate holder normally changes it design well ahead of an AD mandating action be taken on the operating fleet. Indeed, most ADs require compliance with a service bulletin that may have been issued years before the rule. When the “mandatory” design change for an operator is not matched to the maintenance information provided by the design approval holder, it creates a potential for the “unsafe condition:” to be “reintroduced” by “normal maintenance.”

During the two years of deliberations on potential solutions, the agency, manufacturers, airlines and maintenance providers attempted to synchronize the design, production and maintenance regulations with the realities of incorporating and maintaining hundreds and sometimes thousands of ADs on a particular make and model of product.

The full history and results of the committee’s work can be found here.

~~~ posted 9/13/11 ~~~



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