Navigating FAA Rules and Regulations

Overpromising and underdelivering in industries with strict compliance directives and regulations are potential pitfalls.

FREMONT, CA: As part of its mission to keep everyone focused on that task, the Federal Aviation Administration (FAA) issues and enforces various regulations. A certified repair station, also called an MRO, knows that FAA rules are important for all aircraft whose registration is in the US. Repair stations must include FAA guidance when appropriate. That is where things can become complicated and costly. As guidance is not a rule, MROs, including those with whom airlines contract maintenance, may unwittingly open the door to compliance violations and fines if they fail to fully consider the business impact of adopting guidance as practice - in addition to complying with the FAA's hard-and-fast rules.

MROs who add procedures to their quality manuals or repair station manuals, whether as FAA guidance or to satisfy customers and attract more business, make the promise that the FAA will follow those procedures.

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Repair Station Leaders 'Must Know Their Limits': This is not to say that MROs ought to avoid adopting FAA guidance or other best practices. Stepping up to do more than the minimum often benefits the business and its reputation for ensuring safety. For example, customers may expect certificated repair stations to exceed FAA requirements when performing procedures important to their businesses. In the aviation maintenance industry, the minimum standards in repair station regulations vastly differ from the elements required for success.

Disagreements: ARIA inspectors often insist that MROs follow FAA guidance – which, again, is not a rule – which can be a compliance quagmire for MROs. In communication, Brett Levanto, vice president of ARSA, says training is a common example. FAA guidance states certificate holders must receive 'human factors' training to optimize human performance and reduce human error as part of their overall training program to succeed. A repair station owner is likely to comply if an inspector warns them they won't approve their certificate unless they have instituted that training, as failing to do so would be more expensive for them. However, some businesses cannot comply with FAA guidance and find it impossible — especially for the smallest repair shops. The Flight Standards District Office (FSDO) should be responsible when a significant compliance disagreement arises with an inspector. Suppose the repair station owner decides to pursue the matter further after conducting thorough research. In that case, the next step is to contact the supervisor of the local inspector at the FAA's field office. The repair station may take the appeal to the FSDO office manager if the supervisor does not respond.

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