FAA’s Word on Bonded Repair Size Limits – Final Policy
On Nov. 24, the FAA issued a final policy (PS-AIR-100-14-130-001) regarding bonded repair size limits. ARSA’s regulatory team is currently reviewing…Stay tuned.
Previously from ARSA…
ARSA’s Word on Bonded Repair Size Limits Draft Policy
October 16, 2014
On Thursday, Oct. 16, 2014, the Aeronautical Repair Station Association (ARSA) submitted comments to the Federal Aviation Administration (FAA) requesting the withdrawal of Draft Policy PS-AIR-20(xxx)xx-xx: Bonded Repair Size Limits.
Your Word is Your Bond – Bonded Repair Size Limits Draft Policy
October 2, 2014
A member has alerted ARSA to a draft policy from the FAA regarding Bonded Repair Size Limits that would require design approval holder (DAH) substantiation on any repairs developed by owners, operators, repair stations, Designated Engineering Representatives (DER), or engineering firms.
ARSA urges anyone affected by such a change to submit comments to the FAA before the October 10, 2014 deadline.
The FAA cites unexpected failures of bonded repairs to non-critical structures as the impetus for the draft policy. The agency, without providing regulatory, engineering, technical or statistical references, “concludes that bonded repair of critical structure is a potential safety threat.” The draft includes further presumptions that there are no available non-destructive inspection (NDI) techniques that assure that viability of a bonded repair. The FAA has deemed that such uncertainty necessitates a limit to the size of bonded repairs for critical structures. Through comments, ARSA members have the opportunity to ensure the agency ensures its policy is grounded in the regulations and to produce documented proof and objective data to corroborate its assumptions.
Under the draft policy, the size limitations of the bonded repairs are based on the inherent constraints of the specific designs and those associated with the substantiating data used to meet relevant regulations under 14 Code of Federal Regulations (CFR) parts 21, 23, 25, 27, 43. The policy will impact the capabilities of owners, operators and repair stations to develop repairs on critical structures by creating reliance on substantiation data only from the DAH for specifying tolerances and size limitations.
The resulting uncertainty imposes unknown cost on industry members without additional benefit to safety. There are additional concerns that dependence only on the DAHfor repair substantiation—many of whom may not have sufficient maintenance experience—will drive the use of new, more costly parts in lieu of properly established repairs.
Examine whether this issue may affect your business. Stay informed, ask questions, and submit your comments to the docket. Repair station involvement on these issues – which seem small but can have broad impact on the maintenance community – is essential to ensuring the government appropriately balances its responsibilities with the industry’s.