FCBS/FCAS handling 1

[ABXLiaison]

I would like to see how others in the MRO world are handling FCBS items. With each customer developing different methods of recording repair data and some not providing this detail to the MRO. Have any of you included additional worksteps in your repair document to record damage and repair detail? As an organization are you taking the approach that this is an operator requirement only? If the customer doesn't specify how the recording is too happen are you providing static analysis only and letting the customer decide how to handle the followup DTE requirements?

 

[rb1957]

in my experience FCBS is readily defined (as structure with a mandatory inspection program, re 25.571). the big guys (boeing, airbus, ..., ie FAR25) should have this already defined; the smaller guys (cessna, piper, ..., ie FAR23) this is probably harder to define and maybe this is where you are.

but if you're designing a repair you Cannot only do static analysis, you Must consider DTA. it maybe be a single statement ("not primary structure") and you might get by without expressly stating this (it's obvious that this is not primary structure, and there is no programed inspection for it ...), but i think you'd be better writing down your logic. as for not getting OEM data, well it's always been that way and you're left with conservative assumptions that you can defend.

Most often DTA gets into repairs 'cause you have load transfer into a repair doubler (ie stress concentration) and usually you are preventing the OEM inspection (external doubler prevents external visual inspection of the pressure shell) and so you have to provide a new inspection task.

 

[ABXLiaison]

Thank you for your response. I'm more interested in how MROs are handling repairs to these items. The responsibility for recording repair/damage details and obtaining the DTA falls to the opertor. There is no specific FAR language requiring MROs to obtain DTA unless it is agreed upon with the customer. MROs still have the ability to approve a repair with static analysis only. However, the DTA requirement for this repair would be due in 12 months. I'm wondering if MROs are doing mostly static repair or mostly DTA repairs? If DTA how do they handle this internally with each operator requiring different methods of recording.

 

[rb1957]

are you using the SRM to substantiate your repair ?

if you're creating your own RDC/RDA to substantiate your repair and it's a FAR25 plane then you Have to consider DTA.

If you're in the states (and i think you are, as you're using FAR26 terms) then you have to also consider FAR26 which clearly states "repairs".

IMHO, I don't think it's the operators responsibility to obtain the DTA. The MRO is approving the repair. If you're aren't delegated DTA (and who is, outside of the OEMs) the you have to get this approved by your local office. Again, IMHO the 12 months is intended to give the modifier time to complete the DTA without impacting servicability of the plane ... the static analysis shows that the repair should have sufficient durability and cracks are not expected inside of a year (or the threshold inspection is expected to exceed 1 year).

 

[ABXLiaison]

The requirements we're discussing are operator only requirements FAR Part 121.1109 and 129.109. There is no language concerning FCBS in Part 145. As far as Part 26 Subpart E the language defines type certificate and STC holders only. The FAA appears to have mandated the responsibility on operators, TC and STC holders but not repair stations. Let's use a specific example; Mom and Pop MRO accomplishes a static approved repair to a flap (FCBS item) and provides the customer with an 8130. The MRO has no responsibility for DTE followup. Your thoughts?

 

[rb1957]

i think the operator is responsible to record and effect the required inspections (ICAs).

i think whoever is approving the repair is responsible to substantiate the repair and to define the ICAs, ie DTA. Ma and Pa (Kettle?) won't be delegated for 571, so they'll have to get the analysis approved by their local office.

just my 2c ...

 

[Benbarca7]

I agree with rb1957

FCBS Items are subjected to far 25.571 so if a MRO does a repair on a FCBS location they have to satisfy the regulation, meaning providing the Dam Tol Analysis.

It is operator's responsability to make sure that the DTA for repairs on FCBS location done by the MRO. And no one can ignore the law.


Ben
Nacelle Stress Engineer (repair on Civil Aircraft)