Avionics News November 2012 - 65

uneven implementation of the current regulations.
THEY WHO CAN GIVE UP ESSENTIAL LIBERTY TO OBTAIN A LITTLE TEMPORARY SAFETY DESERVE NEITHER LIBERTY NOR SAFETY.

Remember: the ratings issue is just one of many issues in this proposal. There are a number of elements to this proposal that could reflect radical changes in their own right. And, many of them need your scrutiny and comment. For example, there are proposed changes to the way major repairs would be recorded that would equate the Part 43 Appendix B maintenance release requirements with the approval for return to service requirement under section 43.9 of the regulations. From the context of the administrator’s preamble, it is obvious the administrator wants to conflate these two documents (approval for return to service and maintenance release) in order to minimize burden. But, this is not what the proposed change achieves. Under the proposed change, repair stations would still have an obligation to provide the work order (as Appendix B currently permits), and they would still have an obligation to use the work order to provide the traditional maintenance release language; but the work order would then become the approval for return to service document, as well. This would mean the current industry-standardpractice for documenting component repairs and overhauls, use of the 8130-3 tag, would become inconsis-

tent with the new regulatory requirements, due to the fact that Appendix B would require the approval for return to service to be created using the work order. This is an example of a paperwork change that does not contribute to safety and clearly was not thought well. Instead of providing greater flexibility, it undermines existing documentation practices and makes it difficult for repair stations with dual certification (like EASA and FAA) to engage in maintenance recordkeeping

that meets the standards anticipated under bilateral agreements between the U.S. and its trading partners. These are just a few thoughts on the repair station proposal. Please be sure to read the proposal thoroughly, identify the things you think could be changed and propose ways to improve the rule. This is, after all, the rule that we will all have to live with. Comments on the proposed changes to the repair station rule must be received by the FAA on or before Nov. 19, 2012. q

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Avionics News November 2012

Table of Contents for the Digital Edition of Avionics News November 2012
