Currency of Technical Data - FAA Part 145 Repair Station

[p1stonbroke]

Hi.

I was hoping that somone might be able to clarify a point of law relating to the European Aerospace Laws ((EC) No 216/2008) and Regulation 1702/2003

Working as a 145 repair station, we need to ensure that the technical data supplied to us by our customers (operators) is up-to-date. The Operators have been shown in the past to sometimes not keep us up to date with the technical data.
Ideally we'd like to go to the OEMs for the parts which we repair and maintain for the technical data, however my understanding is that they have no legal obligation to provide this information to a subcontractor (i.e. us), only to the operator.

These two together mean that there is a high risk of repairing or maintaining parts/applicances using superseded information, or missing SB’s

What I am looking for is leverage, anything which would permit, under law to request that the OEM provides conformation of the current revision of the technical data,– the logic being that as this data is to be used in the maintenance of aircraft parts and appliances, withholding this information when asked could potentially make them liable should out-of-date information be used?

Has anyone tackled this particular conundrum themselves? any suggestions?

 

[Marc]

A quick "Bump". My Thanks in advance to anyone who can help with this one.

 

[Rolfieh]

There is no requirement for the OEM to supply the CMM beyond the requirememnts of the contract with their Tier 1 customer. The data in a CMM is proprietary to the OEM. There are current attempts by third parties to have the FAA define the CMM as instructions for continued airworthiness and therefore required for continued safe operation of the aircraft. As an OEM we have to bear the burden of $X million development costs for a new project that we are then paid minimal and often negative margins on the OE equipment to then lose the aftermarket work to third parties who have considerablly small costs and overhead burdens. I do not see why we should give the CMMs to third parties.

 

[maozetung]

Goodmorning,

It is not clear to me if your Maintenance Organization is approved to maintain aircraft, components or both of them. Anyway I can confirm you that the TCH/OEM has no obligation to provide you with maintenance data unless you subscribe to such data, in short, to have the data, you have to make an agreement for the supply of the service. I.e. Airbus has a wonderful portal called airbusworld where you can find almost everything. If you don't want to subscribe, as an alternative you should ask to the Operator to provide you with the login and password of its account to get access to the data.
If you maintain components you have to demonstrate to the OEM that you're a repair station approved to repair this and that P/Ns and apply for a subscription.
Anyway I can't understand how you could be approved to carry out such maintenance without having previously demonstrated to the Authority to have access to the maintenance data relevant to your organization’s approval class rating.

With regards to IR 1702/2003 it concerns initial airworthiness of products thus, as a maintenance organization, you're not affected by, conversely to maintain EU registered aircrafts or components intended for fitment to EU registered aircrafts you should give a look to IR 2042/2003 Annex II which concern continuing airworthiness of products.

Your organization shall establish a procedure to ensure that maintenance data you control is kept up to date. In the case of operator/customer controlled and provided maintenance data, your organization shall be able to show that either you have written confirmation from the operator/customer that all such maintenance data is up to date or you have work orders specifying the amendment status of the maintenance data to be used or you can show that you are on the operator/customer maintenance data amendment list.


Regards

 

[p1stonbroke]

Chairman Mao,

Thanks for your reply, it backs up that we're doing as much as we can to make sure the tech data we have is up to date.

Yes the organsiation has aerospace maintenance approvals, but at C-Rating Level - meaning maintenance of components.
As I stated in my initial question, the reason I was trying to find out if there was any legal obligation, was becasue we've sometimes found out that the operators data is actually out of date, through the very same portal you mention, or the other main one Boeing online.
You're right, I got mixed up with my IRs - we're a 21G, 145 and 21J approved organisation, and often the maintenance work requires a mod which means design and manufacturing of new parts for installation as part of the maintenance process.

Very many of our customers do permit us access to roam through their technical data, but the issue stands that if they give us out of date information, we can potentionally work to it, and as such a requirement on te OEM to provide data would have been good
However, I've been pursuing this line, and many OEMs will provide current revision and date of issue when requested, which gives us the opportunity to return to the operator to request that they get the new version.... so it kinds of works in a round about way.

Adding a caveat that our customer specifies the revision/date of the tech data to be used is a good idea - I like it.