MRO Asia-Pacific 2016 Regulatory Session Presented to: MRO Asia-Pacific 2016 By: Mr. Murray Huling (FAA) Date: September 27, 2016
Topics of Discussion Bilateral Aviation Safety Agreement (BASA) Maintenance Implementation Procedure (MIP) Quality Management System Compliance Philosophy FAA Form 8130-3 Update 2
Introduction to the U.S./Singapore Maintenance Implementation Procedures (MIP) Agreement Between The United States Of America And The Republic Of Singapore On Cooperation In The Regulation Of Civil Aviation Safety 3
The New U.S. / Singapore Maintenance Implementation Procedures (MIP) The Maintenance Implementation Procedures (MIP) was signed on February 16, 2016 between the Republic of Singapore and the US. It is an Agreement of the Promotion of Aviation Safety. The MIP is written as a BINDING international law. It is an Authority to Authority agreement. Entry into force was August 15, 2016. All applications after this date must be completed under the MIP. 2 years from August 2016 the turnover of certificates should be completed. FAA part 145 Singapore based facilities certificated prior to the MIP entry into force date (AUG 2016) may not qualify under the MIP provisions. In these cases, the FAA will not turnover the certificates to the CAAS. (AFS-54 needs to be notified) 4
Understanding the U.S. / Singapore MIP U.S. Singapore Maintenance Agreement Guidance (MAG) Provides guidance on the MIP Objective of the agreement: Enable the reciprocal acceptance of part 145 Repair Station and Approved Maintenance Organization (AMO) Promote a high degree of safety in air transportation Ensure the continuation of the high level of regulatory cooperation and Harmonization. Allow sharing of information 5
General -- MAG Section A Purpose The MIP is a high level document and references the Maintenance Agreement Guidance (MAG) The U.S.-Singapore MAG defines the procedures that are required to comply with the MIP which is broken down into the following sections. Section A (Authority to Authority) Section B (Singapore - U.S. based) Section C (FAA - Singapore based) Section D (Temporary revisions) 6
MAG Section A Cooperation in Quality Assurance Activities FAA Sampling Inspection System A sampling visit schedule is established by the FAA Coordinator (AFS-54). This is communicated to AFS-300 for concurrence. The sampling inspections are designed to verify that the CAAS and AMOs are following the MAG. This is a Safety Management Systems (SMS) approach to Bilateral Agreements. A SIS at an AMO may be conducted based on risk 7
COMPLIANCE PHILOSOPHY 8
Compliance Philosophy Traditional approach: (Reactive) Today s approach: (Proactive) Act after an accident Find, fix, and fly Make more rules Act before an accident Encourage reporting Find, fix, and monitor 9
Today s Safety Tools Traditional approach: Today s approach: Enforcement action Risk-Based Decision-Making Compliance Philosophy Safety Management Systems Focus = assigns blame for what has already occurred Focus = accepts responsibility and looks forward how to prevent recurrence Regulator prescribes fixes; Operator complies Operator / Agency uses proactive risk management; Regulator focuses on safety assurance 10
Using the New Tools Operator must: Operate in accordance with both the letter and spirit of the law Be willing and able to comply Take a proactive approach that considers outcomes and performance Develop and implement risk controls appropriate to the operational environment. Establish procedures that encourage useful reporting. Regulator must: Focus on willingness and ability to comply, not outcome of an event Train workforce to develop a collaborative, transparent relationship with operators Put focus on find, fix, monitor approach to compliance Use interdependence and critical thinking to evaluate means of compliance Open Communication Collaboration Robust Reporting 11
Results Common goal = a safe, efficient aviation system We must all work together to fix the system/problem. Move beyond traditional operator/regulator model to a transparent model. Use new tools to foster an environment of mutual trust and respect so as to promote open communication, collaboration, and cooperation. Culture change is always challenging, but essential to achieving our safety mission. 12
FAA FORM 8130-3 UPDATE ON CHANGES 13
FAA Order 8130.21 Policy Change Policy memo AIR100-16-100-DM04 was issued on June 24, 2016 to FAA field offices. This memo removes the requirement to use statements in Block 12 of Form 8130-3 for export: Export airworthiness approval This engine/propeller/article meets the special requirements of (enter country). Export airworthiness approval. No special import requirements for [enter name of country or jurisdiction] stated at time of issuance. 14
Required Statements Removing these statements does not relieve the exporter from continuing to include any other statements required by FAA Order 8130.21, Advisory Circular 21-2, Appendix 2, and the applicable bilateral agreement. 15
PAH use of FAA Form 8130-3 as ARD ARD Authorized Release Document (ARD) PAH may implement 21.137(o) provided addressed in their Quality System. May select any individual to sign ARD on their behalf. FAA views issuance of ARD under 21.137(o) as an administrative function. PAH may implement without prior MIDO approval. (Changes subject to FAA review) 16
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