ARSA Executive Vice President Christian A. Klein returned from Cologne on Dec. 2 after participating in the annual Maintenance Management Team (MMT) meeting. Through the MMT, four of the leading aviation authorities – the FAA, the European Union Aviation Safety Agency (EASA), Transport Canada Civil Aviation, and Brazil’s Agência Nacional de Aviação Civil (ANAC) – meet and coordinate bilateral and multilateral activities. The meeting, which includes an industry day, provides an opportunity for stakeholders to raise issues to regulators and learn more about the status of bilateral negotiations.

Two topics were front and center at this year’s meeting: digitalization and Safety Management Systems (SMS). Klein presented the results of a survey conducted by ARSA and other MMT participants including the Aircraft Electronics Association (AEA) and the General Aviation Manufacturers Association (GAMA) about the use of digital technology in the global maintenance industry. Among other things, Klein reported that outdated policies and inconsistent interpretations are slowing digitalization, particularly in the areas of records and signatures.

Other conclusions of the survey:

• Technology is evolving more quickly than regulatory standards.
• Paper recordkeeping requirements inhibit safety improvement (data gathering, trend analysis, etc.)
• Industry is embracing digitalization when agency rules do not inhibit doing so.
• The lack of performance-based standards, regulations, guidance and policy is an impediment to adopting new and more efficient technologies.

The MMT Digitalization Working Group urged that future bilateral agreements allow for new formats for parts documentation to pave the way for unique identification of each part via RFID, Blockchain, and other technologies. Regulators were also urged to agree on maintenance data standards based on lessons learned from the sharing of operational data, to enhance data availability, and to facilitate the acceptance of multilateral releases for return to service.

AEA Vice President for Government and Industry Affairs Ric Peri led the SMS discussion. He reviewed the various authorities’ current SMS requirements for repair stations. Of particular note, effective Dec. 2, 2024, all EASA Part-145 approved maintenance organizations (i.e., those with certificates directly from EASA, not via a bilateral) must have implemented an SMS. While the FAA has foregone requiring SMS for repair stations, a future revision to the Maintenance Annex Guidance (MAG) for the FAA-EASA bilateral will extend the requirement to U.S. repair stations with EASA approval. (Note: ARSA members have access to AEA’s SMS resources. For more information, click here.)

Industry asked that regulators continue to accept the industry’s SMS standard as a means of compliance with existing regulations, coordinate to assure compatibility and alignment with future regulation, support approved maintenance organization (AMO) voluntarily adoption of the industry standard, and wait to implement SMS requirements via MAGs until after EASA Part 145 SMS requirements are fully implemented (i.e., post December 2024), allowing other repair stations to benefit from lessons learned during the implementation process.

Other important takeaways from the meeting:

• The FAA expects to sign new Maintenance Implementation Procedures (MIP) with TCCA in the second quarter of 2024 and expects to sign an updated MAG (Rev. 9) with EASA next year.
• TCCA and ANAC plan to ink a new Technical Arrangement – Maintenance (TA-M) in January 2024; it will only require supplement approvals for organizations performing maintenance on products (aircraft, engines, and propellors).
• FAA and ANAC signed a MIP in 2018 and a MAG in 2023. Publication is expected early next year.
• EASA and TCCA are on track to sign a revised Annex B providing in the first quarter of 2024.
• A revision to Annex B of the EASA-ANAC bilateral went into effect in March 2023.

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