Technical Workshop 2011 DER Repairs & RS-DER PRESENTED BY DOMINICK P. DACOSTA FAA DER-T Chart A – Structures Chart B – Powerplant Chart C1 – Mechanical Systems Chart E – Engines Spl Delegations: Major Repairs Multi Use /Major Alterations RS-DER Gorham Technologies San Diego March 29, 2011
FAA DER DISCLAIMER • The Federal Aviation Administration is not in any way responsible for the data, or the opinions presented in this presentation. • The opinions and data presented herein are the those of the presenter. • The audience is responsible to confirm all data, relative to FAR’s, Orders, and Advisories for accuracy and being the current revisions. • The FAA Delegate’s that function as a DER is defined in FAR 183, and FAA Orders 8100.8C & 8110.37D • FAA data may be obtained on Fed world, at www.fedworld.gov
About your Instructor • Dominick P. DaCosta • FAA DER-T Engines Chart E, Powerplant Chart B, Systems Chart C1, Structures Chart A ~ PMA ID Findings Authority & Major Repair/Alterations Multiple Use Authority • FAA DAR-F ~ Class I, II, and III Parts . • 28 years Aerospace Manufacturing Engineering • 15 years Engine/APU Maintenance & Repair Engineering • Worked with GE, P&W, Textron/Lycoming, Rolls Royce, Honeywell APU, Garrett Engine, Bendix Fuel Cntrls/Brake/LG, CTL Inc., United Airlines, CRT, American Airlines, Exotic Metals, Soundair, Lufthansa, MTU, Alitalia, Air France FedEx, Iberia, ITT, Hamilton Std., Parker, ACS, Eaton, Rexnord, SR Technics,SW Airlines and others. • ASNT Level III Since 1976~2010 • Licensed FAA A&P Mechanic • Certified by National Institute for the Certification of Technologist [NICET~NSPE] • Senior Welding Engineering Technologist ~ 1979 ~ 2011 • Indiana University - BGS • Ohio State University - Welding Engineering Certification Program • Massachusetts Institute of Technology - Micro Mechanics Program • Kings Aeronautical Institute of Technology – Powerplant Technology
WORKSHOP AGENDA • What is a DER? • What can a DER Approve? • Who delegates a DER? • Can All DER’s Approve Major Repairs? • What Special Delegations are required for Multiple use? • What is the recommended data format for a Major Repair? • When is a “Test Plan” required for a Major Repair/ • Why & Which branches of the FAA must concur with a Major Repair Approval? • What kinds of data are acceptable to support a Major Repair? • What procedure is needed to get foreign CAA/NAA’s to accept a DER repair design. • Can a DER repair include locally fabricated parts as part of the approval without a PMA or STC? • What FAA National Policies would be applicable for Major Repairs? • What existing Bi-laterals allow DER repair acceptance? • Does the EASA accept FAA DER repair approvals? • What is the difference between a RS-DER and a DER with Major Repair authority. • Can a Repair station still use a DER with Major Repair Authority and what is the impact? • What is the FSDO/IFO interactions with the RS-DER? • Review N8110.111 RS-DER
What is a DER? • A DER is the acronym for Designated Engineering Representative [DER]. • There are now two (2) types of DER’s • DER-T; a consultant DER who is independent • DER-Y; a company DER who works for a specific company, [i.e. GE, Pratt, or Boeing] • __________________________________________ • *A new delegation area has been authorized, a RS-DER [Repair Specification]; This is a special delegation from one of the above basic delegations. [Ref N8110.111] “Draft 8110.37E” to approve repair processes specifications for maintenance operators multiple use repairs.
What is a DER “Cont” • ALL DER’s are representatives of the FAA administrator under 14 CFR 183.29 • They are appointed by the geographic Aircraft Certification Office where they work or reside. • The must meet the requirements of FAA Order 8100.8C, and the restrictions in Order 8110.37D, and for RS-DER appointments N8110.111. • The appointing ACO must have a need, and must be able to manage the designee. • The DER’s are renewed annually at the discretion of the appointing ACO. • All DER activities are tracked on a form 8110-29 [now SAR electronically]. • DER’s can only approve such items they have been delegated by their appointment letter and DIN [Form 8110-25] to the items and limitations noted in Order 8110.37D charts functions and areas. • DER’s can NOT approve LIFE LIMITED PARTS repairs, or Critical or AD/SAIB related articles. [Ref 8110.37D]
What can a DER Approve? According to 8100.8C and 8110.37D, the DER can approve design data on behalf of the FAA ACO [Engineering Branch] for items NOT exclusively retained for the FAA only, and within the charts noted in 8110.37D, here two examples. Ref: 8110.37D Section 2-5. DER Designations. a. Structural DERs may prepare and/or approve, within the limits of their appointment, the following items that comply with pertinent regulation(s): (1) Engineering reports, (2) Drawings, (3) Material and process specifications used in structural applications, and (4) Other data relating to structural considerations. e. Engine DER may prepare and/or approve, within the limits of their appointment, the following items that comply with pertinent regulation(s): (1) Engineering reports, (2) Drawings, and (3) Other data relating to durability, materials, and processes employed in engine design, operation, and maintenance.
Special Functions Area What can a DER Approve [Cont]? Authorized Areas & Delegated Functions
To approve Welding Processes the DER should have Function I 2 d on their DIN LODA
Who Delegates the DER? • The FAA Aircraft Certification Office Appoints FAA DER Designees in accordance with 14 CFR Part 183.29. • The DER’s Management is defined in 8100.8C, 8110.37D, and for RS-DER delegations N8110.111. • There are basically two (2) types of DER’s: • A Company DER-Y • A Pvt. Consultant DER-T • A New Delegation/Function Area is now authorized a RS-DER is definitions and requirements are defined in N8110.111. FAA authorizes the RS-DER to manage ALL aspects of a Multiple Use, Repair Specification Project. • NOTE: This a special delegation/function under the existing DER areas.
Is there a Special Authorization Required for Multiple Use Repair Approvals? According to Order 8110.37D, Section 4-12c2, Yes, only DER’s with Multiple Use Authority can approve these type of repetitive repairs! 8110.37D, Section 4-12, 2c c. Authorization. A DER must obtain authorization from the managing ACO before he initiates data approvals for major repairs or major alterations. The ACO’s authorization may be verbal and confirmed in writing or by an authorization letter. See a sample authorization letter in appendix 3, figure 6. A DER to whom we grant this special authorization may approve technical data for major repairs and major alterations without first notifying the project ACO, except when the part is critical or life limited, or if the work will be done outside the country. For guidance concerning operating outside the United States, see Order 8100.8. For critical or life limited parts, the DER must contact the project ACO for guidance. (1) Aircraft Repairs and Alterations. Authorization for major repairs or major alterations applicable to aircraft, and engines and propellers installed on aircraft, are limited to the approval of a specific repair or alteration to specific serial number aircraft. A DER must coordinate with his managing ACO for authorization to approve data for multiple use repairs without specific aircraft serial number effectivity. (2) Component Repairs and Alterations. A DER authorized to work on major repairs or major alterations of parts, components, engines, or propellers not installed on aircraft is limited to approving data for a specific repair or alteration to specific serial number parts, components, engines, or propellers, or to a specific work order for parts or components that are not serialized. A DER must coordinate with his managing ACO for authorization to approve data for multiple use repairs, repair schemes, or establishment of repair limits for multiple use repairs to components.
RS-DER & DER Interactions • According to FAA N8110.111 These two delegation areas have distinct functions within a Major Repair Multiple Use Repair Specification Project. • Generally Defined Responsibilities are: • DER Multiple Repair Authority • Review and Approve the “TECHNICAL ASPECTS” of the design data, as they relate to show compliance to specific design airworthiness requirements. [ie. Mechanical Properties, Durability, Etc.]
RS-DER & DER Interactions [Cont] • RS-DER “Repair Specification DER” • Review and Approve the “Process in which the repair will be executed and accomplished, in order to meet the definition and intent of “Improperly Done” [Performed]
FAA NOTICE N8110.111 RS-DER FAA ORDER 8110.37E [draft]
What Branches of the FAA must concur with a Major Repair or Major Alteration Data • For the “DESIGN ASPECTS” of the Modification [Repair/Alteration] ACO • They are the Engineering Branch of the FAA responsible for design aspects • For the “PERFORMANCE” conforming aspects of the Modification the FSDO • They are responsible for the Certificated Maintenance operator having the necessary 1. Facilities, 2. Trained Staff, 3. Equipment, 4. Tooling, 5. Data, to perform the repair design per 14 CFR Part 1.1 “Properly Done” vs “Improperly done” • For any “Substantive” Supplemental ICA changes the AEG • They are responsible to see that the “Supplemental ICA” meet Order 8110.54, 8300.13, and AC 20-114. • NOTE: The compliance check list, and certification plan should address the need to coordinate with any of these FAA branches regarding the repair project.
Can A DER Major Repair include Fabricated Components without a PMA? • According to FAA Advisory 43-18 chg 1 “YES” • The Fabricated Components Design must be also approved by the FAA or DER. • The Fabricated components MUST be consumed within the repair. • The fabricated component cannot be sold seperately. • The Repaired assembly must be “Additionally” marked per AC 43-18.
What kind’s of data are acceptable to use in support of Major Repairs? • THE FAA IS LOOKING FOR APPLICANTS TO SHOW EQUIVALENT SAFETY IN THE REPAIR DESIGN! • TC, STC, TSO, OR PMA Published ICA’s or other Accepted or Approved data. • ESM, AMM, CMM, SRM, SB, and SIL’s • Reversed Engineering Data [ Material Testing, Mechanical Tests] • FAA DATA • Airworthiness Directives • Orders, Advisory Circulars, SAIB’s, and Policy memo’s • INDUSTRY DATA • AMS, AN, ASTM, ASME, ANSI, ASM • Military Specifications & Data
What FAA National Policies give guidance for Major Repairs • In last five (5) years the FAA has released the following guidance to assist those preparing and gathering substantiation data for Major Repairs. [Note: some have been obsolete or superceded ] This NOT exhaustive some have already been deleted or Obsoleted! • Current guidance: Orders; 8110.4C, 8110.37D, 8110.42B, 8150.1B, 8300.13, 8300.14, 8110.54, 8100.14a, & 8900.1 • Advisory Circulars: 20-114, 43-18, 120-77, 20-107a, 20-142, 21-101, 25-19, 25-571, 25-613, 25-735, 25-775, 25-783 23-1309, 25-1309, 25-1435, 25-1529, 33-2B, 33-3, 33-4, 33-5, 33-6, 33-19, 33-27, 33-90 , 39-8, 43-13-1B, 43-13-2A, 43-210, 120-73, 121-22, 145-6, 20-62D • AC 33.9
What Existing Bi-laterals Allow DER repair acceptance • For European Community “EASA” has isued several Executive Decisions “ED 2004-04 CF as amended by ED 2007-01-CF • The FAA has also issued an Interim agreement 8100.14a • For other countries check AIR 40 website “International Airworthiness Agreements” • Ask your local ACO/FSDO for assistance to determine any special requirements.
Does EASA accept FAA DER approved Repairs? • According to EASA ED 2004-04-CF as amended by ED 2007-01-CF “ For FAA DER approved repairs of “Products where the S.O.D. is USA on non-life limited parts and the repair is done in a US repair station, YES, EASA will accept the DER approval. ED 2007-01-CF
EASA vs FAA Classifications Major vs MinorType Change & Repairs Cl 1-Major Type Change Amended TC Complex STC Major Type Change Amended TC All STC Cl 2 – Major Type Change Simple STC Major Repairs Minor Repairs Major Repairs
What is the difference between a RS-DER & a DER with Major Repair Authority? • A FAA DER with Major Repair and Multiple Use Authority can approve the same repair data in accordance with 8110.37D Sect 4-12 • A FAA RS-DER can approve Major Repairs, and Multiple use for repair stations that the repair will be added to their OPS, the appointment comes from the ACO under 8110.37D, and N8110.111 • Therefore a Repair station can use either DER per the existing guidance and the CRS is required to obtain FSDO approve for its application and use.
FAA AC 33.9 Recommended Repair Templates
One Example of a DER Repair A Non-book repair of a Combustor • A Nozzle SPAD is locally produced, by the repair facility. • The damaged area is cut out • The new SPAD is welded in place • The SPAD & weld is blended • The weld repair is NDT Inspected • The new SPAD is laser drilled for air cooling holes. • The Combustor dome is air flowed and re-inspected to OEM Stds. • Repair data is FAA DER approved. SPAD REPAIR
CMM, SRM, SB SERVICE HISTORY INDUSTRY SPECS FAA GUIDANCE SIMILARITY DESIGN TESTING FAA ACCEPTABLE DATA ACCEPTABLE DATA
Example Formats Major Repair Methodology Major Mod Template
When did we start? Study complete Industry input Develop policy… • FAA’s Repair, Alteration and Fabrication Study Team Schedule: • Current Status: • Draft report presented to FAA management late 2007 • Presented results to Industry in late 2007 and early 2008 • Report to FAA Management and a Proposed Action Plan completed April 2008 • AC 33.9 by 1st Qtr 2010 February 07 End 07 1ST Qtr. 08
How is FAA responding? • Chartered an AVS team* to review all regulations and policy related to repair, alteration, and fabrication during maintenance • Identify any gaps and recommend possible solutions: • Training • Policy changes • Rule changes • * Flight Standards and Aircraft Certification
What Will the Team’s Report Contain? • Research Documentation • Drivers and Issues • Conclusions and Recommendations • Proposed Plan to close gaps identified by the study to ensure: • A joint AVS & Industry strategy • Consistency of definitions, interpretations and application of requirements • Identify which rules or policy need revision
Who is responsible for the airworthiness of the product? • Standard Certificate of Airworthiness (C of A) is issued under 14 CFR 21.183 • Aircraft must conform to type design (TC) • Must be in condition for safe operation • Standard C of A remains in effect as long as the aircraft is maintained and altered in accordance with Parts 43 and 91 (21.181) • This means that the operator is responsible for the validity of C of A and for the continued compliance with the appropriate airworthiness standards
Fabrication of Parts and Sub-parts • Fabrication of parts using FAA approved or accepted data during the conduct of maintenance is permitted by today’s rules: • 14 CFR 43.13(b): “…will do work in such a manner and use materials of such a quality,…” such that condition after maintenance/alteration will be equal to the product’s original or properly altered condition • 14 CFR 21.305(d): Any other manner approved by the Administrator • Fabricate their own (owner/produced parts) • Fabricate during maintenance (repair or alteration) • Guidance for fabrication is provided in AC 43-18
Repairs • Extensive repairs are allowed by current rules and policy: • FAA’s concern is with safety and compliance • Not with percent of part repaired (sliver repairs) • Not with economics of a repair • Maintenance providers should not do extensive repairs with the intent of circumventing PMA requirements or 14 CFR 21.303
Part Marking • Production Part Marking is covered adequately in CFRs 21 and 45. • Re-marking parts that have a major alteration performed will be addressed in the next change to CFRs 21 and 45. • Part Marking for fabrication during maintenance is contained in AC 43-18. • Part Marking of extensive major repairs and alterations is not covered and is under review by FAA. • Part Marking of owner produced parts is not covered and is under review by FAA.
Repair or Alteration Process Proposed Repair or Alteration MINOR MAJOR Major / Minor Part 43 Effect on MINOR MAJOR Product Design 21.113 Approved Data not required – Obtain use acceptable Approved Data data ( DER , 337 block 3 , etc .) Amend TC or Obtain STC per Order 8110 . 4 Perform Repair or Alteration per Approved Data Return to Service per Part 43
Actions that FAA is considering: • Review DER authorization categories and limitations and make appropriate changes to better delegate DERs in these areas • We will also look at our DER training, DER seminars, etc. to ensure that our DERs are continually updated with our policies • Develop better guidance to help with major/minor design change decisions and issue policy that will ensure standard application
Actions that FAA is considering: • Clarify policy on “critical parts” consistent with the definition developed under the pending U.S.-EU bilateral agreement as those parts identified by the TC holder during the safety assessments required for type certification and validation • Clarify how critical parts lists and management plans are documented, transmitted, and used. • Look at existing guidance such as AC 120-77 and revise to make applicable to repair stations • Develop new guidance for repairs with templates and other information that will ensure consideration of appropriate airworthiness standards
Actions that FAA is considering: • Leverage Industry owner/operators and maintenance providers to gather best practices of how they determine Major/Minor repair and alteration classification under CFR 43. • Implement through the AVS SMS initiative.
DERS GROUP wants to acknowledge FAA AVS Repair, Alteration and Fabrication Team (RAFT) for the slides related to RAFT Team investigation and those results
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