New Guidance on the 8130-3: Block 12 Language and Blank Spaces

The Airline Suppliers AssociationVolume 6, Issue 10<strong>New</strong> <strong>Guidance</strong> on the 8130-3:Block 12 Language and Blank SpacesThe FAA has released a policy memothat makes a variety of changes inOrder 8130.21B, which is the FAAorder describing the procedures forcompleting the airworthiness approvalform designated as Form 8130-3.While most of the changes addressminor grammatical or procedural issues,some of the changes are importantto anyone that handles an 8130-3.Acceptable Status/WorkThe memo establishes a list of permissibleterms that may be used in block12 of the 8130-3 (the "status/work"block). These terms are all taken fromdescriptions found in the Federal aviationregulations (FARs):• <strong>New</strong> (for newly manufacturedparts and products)• Overhauled (for items not yetplaced in service since overhaul)• Inspected• Repaired• Rebuilt• Altered• ModifiedThe memo specifically discouragesthe use of the terms "<strong>New</strong> Surplus" or"OHV" because they are not termsfound in the regulations.Incomplete FormsIn addition to making changes in theorder, the memo also addresses someadditional issues arising out of the8130-3 form. The original Orderstates that all applicable blocks of theform must contain entries for the documentto be considered valid. Thememo explains that this directive islimited only to the blocks that aregenuinely applicable - it is thereforeNOT necessary that every single blockbe completed in every case.Since the completion requirement onlyapplies to "applicable" blocks, an incompleteform need not be automaticallyrejected. The key question iswhether the blocks that are not completedare necessary to the recipient.The recipient of the form should makehis own determination at the time ofreceipt based upon the recipient'sneeds. A form should only be rejectedfor incompleteness if the incompleteblocks are deemed to be necessary bythe recipient.It is also important to note that anincomplete form, without anythingmore, does not necessarily make thepart a "suspected unapproved part."For example, an 8130-3 form thatproperly identifies the part, states itwas overhauled according to the appropriatemanufacturer's manual instructionsand specifications, and(Continued on page 116)October 1998Inside this Issue:Annual Conference a Success ..... 111Aging Aircraft Initiative ............. 112Congressional Aviation Focus .... 113Supreme Court Cases ................. 114Boeing Sees Cargo Increases ...... 114ARAC’s Delegations Rule .......... 115Gov’t Invites FQA Comments ..... 117Insulation Blanket Alert ............. 117FAA Promotes McSweeny .......... 118Oxygen Mask AD ....................... 118Congratulations to:Pacific Air IndustriesSanta Monica, CAAmerican Aircarriers Support, Inc.Fort Mill, SCfor their accreditation to theAirline Suppliers Association’sAccreditation Program.Keep monitoring,http://www.airlinesuppliers.comfor a growing list ofFAA accredited distributors.109 ASA-The Update Report October 1998

A Message from ASA’s PresidentBy any measure, the AnnualConference was a success. Theinformation was relevant, theworkshops were informative and thesocial functions were enjoyable. Thisyear's annual conference wasespecially memorable because themembership was together and we werefinally able to properly honor andthank our past President, EdGlueckler.In early 1993 by a group ofdistributors that wanted properrepresentation in Washington DC andin the industry approached Ed. Inresponse, Ed developed the strategicplan for the Association. Ed alwayssaid that first and foremost, in order tohave a strong voice, you must have astrong membership, and under Ed’sleadership the Association grew from3 to 180 members.ASA members wanted representationin the development of the FAAAccreditation Program. Ed foughttirelessly to ensure that ASA-100 wasan approved standard. Now, over70% of the accredited distributorschoose ASA-100.ASA accomplishments under Ed’sleadership would be too long to list,but as a result of his effortsdistributors are recognized as strongprofessional companies that are anintegral part of the aviationcommunity.In honor and recognition of hiscontributions, the ASA Board ofDirectors has established the EdwardJ. Glueckler Award. This Awardwill be presented at ASA AnnualConference to the person thatexemplifies the dedication,commitment and contribution that Edprovided to the Association and theaviation industry. Each year, ASAwill ask the membership to nominatecandidates two months prior to theannual conference. The Board ofDirectors will select the recipient andthe award will be presented at theannual conference.Ed always said that the strength of theAssociation is in the membership.We only felt it right to name the awardhonoring a member after Ed.Ed’s professionalism, work ethic andgood humor made him an excellentboss and teacher. Ed’s tireless workof promoting distributors andeducating the industry has lead to asafer aviation community.Best RegardsMichele SchweitzerBoard Of Directors:Karen Borgnes 253-395-9535Pacific Aero Tech, Inc.John Butler 818-768-7000Time Aviation Services, Inc.Bill Cote 561-998-9330The AGES GroupFred Gaunt 310-829-4345Pacific Air IndustriesPaula Sparks 954-431-2359AVTEAMMike Molli 847-836-3100Scandinavian Airlines SystemMitch Weinberg 305-685-5511International Aircraft AssociatesOfficers:Karen Borgnes 425-395-9535Corporate TreasurerMichele Schweitzer 202-216-9140President, Corporate SecretaryThe Update Reportis a monthly newsletter of theAirline Suppliers Association.Questions/comments should beaddressed to the Editor:Jason Dickstein, Vice PresidentAirline Suppliers Association636 Eye Street, NW, Suite 301Washington, DC 20001voice: 202-216-9142fax: 202-216-9227email:jason@airlinesuppliers.comThe Update Reportprovides timely information tohelp Association members andreaders keep abreast of thechanges within the aviationsupply industry.The Update Reportis just one of the many benefitsthat the Airline SuppliersAssociation offers members. Forinformation on ASA-100, theASA Accreditation Program,Conferences, Workshops, FAAguidance like Advisory Circulars,Industry Memos, or services andbenefits, contact the Association.The Update ReportFor information on specialpackage rates for advertising,contact the Association at 202-216-9140. Subscription cost is$120.00 US per year.Copyright © 1993 - 1998, TheAirline Suppliers Association.All rights reserved.110 ASA-The Update Report October 1998

YOUR ASSOCIATION IN ACTIONASA Annual Conference a Sweeping SuccessASA members who failed to attendthis year's annual conference missedone of the best educational conferencesin the industry.The program started with a keynotepanel of FAA experts, starting withContinuous Airworthiness MaintenanceDivision Manager Ava Mims,who lauded ASA's efforts to promotedistributor accreditation. She presentedthe Association with a plaqueto formally recognize our efforts (in1998, ASA officers promoted AC 00-56 in over twenty speeches and publicaddresses, and also assisted the FAAby briefing key personnel on the stateof the program). Mims was joined onthe keynote panel by National ResourceSpecialist Al Michaels, SUPSProgram Manager Ken Reilly, andPMA Program Manager Bruce Kaplan.These are four of the FAA'sbrightest and most dynamic personalities,and ASA members took advantageof this significant FAA presenceto get the answers they needed to severalof the burning questions that affectthe industry.The rest of the morning maintained thesame high intensity started by thekeynote panel. Transportation consultantSpencer Lin discussed the economicforecasts for the industry, andASA's own Jason Dickstein drew uponhis legal background and aviation experienceto lead the conferees througha program for addressing parts documentationconcerns that arise.Perhaps the only negative commentoffered to ASA after the conferencefocussed on the break-out workshopsMonday afternoon. Members complainedthat the workshops were sogood, they had problems choosingonly two to attend! ASA owes a debtof gratitude to Frank Abagnale,Allyson Cate, John Gilbert, AlMichaels, Ken Reilly, Roy Resto andFred Workley for their excellent workshoppresentations.After the members-only breakfast, daytwo of the conference began with ASAPresident Michele Schweitzer reviewingthe state of the industry, and therecent changes in the rules and lawsthat affect the industry. She was followedby attorney Paul Lange, whodescribed the common areas of legalliability for distributors, and discussedways to avoid liability.After having addressed the recent pastand the present, the morning turned tothe future, as Richard Levin chaired aASA President Michele Schweitzerand FAA Continuous AirworthinessMaintenance Manager Ava Mimspanel on electronic commerce in the21st century. The panel featured ILSPresident Bruce Langsen discussingelectronic commerce and the internet,Westbrook Technologies PresidentSean Donnegan, who spoke on electronicdocumentation managementsystems, Lisa Johnson of Boeing andher presentation on developing technologiesin part marking, and attorneyChris McGuire of Crowell & Moring,who discussed the hidden Y2K problemsthat most companies just don'tnotice.The afternoon session finished withtwo important sessions for strategicplanners. First, Boeing's Peter Gal-limore provided an update on the rulesthat are being proposed to the FAA bythe ARAC advisory committee, andhow those rules will affect distributors.Gallimore chairs the ARACworking group that wrote the proposedrevisions to the aircraft manufacturingrules. After Gallimore, Terry Pearsallof the Aircraft Electronics Associationand ASA's Jason Dickstein took thestage to discuss the finer points ofdoing business with foreign customers,and the effects that harmonizationand other initiatives could have onour European business.The program seems like quite a lotwhen you fit it into just a few shortcolumns of the newsletter, but ask anyof the attendees and they'll tell youthey wouldn't have missed it for theworld. Suppliers walked away with agood education in a relaxing environment- just right for conducting a littlebusiness on the side during the breaks!One QA Manager called to say that hiscompany was so impressed with hisreport on the conference that they'replanning on sending their sales forcenext year (the QA Manager alsoopened the door to two new customers).Air carrier personnel whoattended have been calling to ask howthey can help with next year's conference.So mark next year's conference onyour calendar today: July 18-20, 1999at the Marco Island Marriott in MarcoIsland, FL. You won't want to miss it.111 ASA-The Update Report October 1998

REGULATORY UPDATERecent concerns over aging Kaptonwiring and other systems subject topossible deterioration have promptedthe FAA to develop a plan to enhancesafety of aging aircraft systems. TheFAA unveiled just such a system onOctober 1. Under this aging aircraftplan, the FAA will work with air carriersand manufacturers to identify areasof concern. The FAA plans to issueguidance and directives to assure thatthe identified areas of concern are appropriatelyaddressed. This couldmean big business for supplier sellingthe parts that air carriers need to remediatetheir aging aircraft.The FAA has already undertaken substantialresearch into aging aircraft.This current initiative should involveone year of extensive type-specific research.Past research into aging aircrafthas taught the FAA that currentmaintenance practices for systems aretoo general. At the same time, there isa need to standardize the repair practicesfor particular types.Having determined that they needtype-specific data, the FAA has founda partner in this endeavor. The FAA isworking with the Air Transport Asso-Aging Aircraft Initiative Could Signal Future Markets Opportuniciation(ATA) as well as the aircraftmanufacturers. The ATA Program isbased upon air carrier inspections thatwill identify potential problems withaging systems in the entire commercialfleet. Teams of experts will studyeach specific aircraft model and producemodel-specific aging systems actions.Chairing the review will beKent Hollinger, Vice President forQuality Assurance and Engineering atAmerica West Airlines.The FAA has announced five longtermgoals for its aging aircraft initiative:• Enhance airplane maintenance tobetter address aging airplane systems;• Improve wiring installation drawingsand instructions for continuingairworthiness;• Evaluate the need for additionalmaintenance of transport airplanefuel system wiring and addressany unsafe conditions;• Add aging systems tasks to theaging airplane research program;and• Improve reporting of accident/incidentand maintenance actionsinvolving wiring system components.This aging aircraft program will requirethe FAA to prescribe regulationsthat ensure the structural airworthinessof aging aircraft. The focus will be ondefining requirements for maintainingaircraft through improved inspectionsand repair practices. Past investigationhas shown that as airplanes age,requirements change for inspections,repairs, and parts replacement. Accordingto the FAA, the requirementsfor part replacement may even increaseas aircraft types continue toage. This means that the aging aircraftprogram could act as a weathervane,pointing out the direction in whichnew business demand may develop.advertisement112 ASA-The Update Report October 1998

ON THE HILL - CONGRESSIONAL NEWSWatch out, because members ofCongress have informally dubbed nextyear "the year of aviation." After ahectic year finishing surface transportationlegislation, Congressmenlike Transportation and InfrastructureCommittee Chairman Bud Shuster (R-PA) have pledged to turn their attentionsto aviation issues next year. Thiscould be a mixed blessing if it encouragesmembers of Congress to proposeideas that may not work in your industry.The late Summer and early Fall inWashington, DC were characterizedby a flurry of aviation activity onCapitol Hill. Radical improvementideas were on everybody's lips, fromincreasing the money available to theAirport Improvement Program (AIP)to providing additional job protectionto aviation whistleblowers and SUPsreporters. Not all of these ideas werebeneficial to the industry, though. Alot of the best-intentioned proposalscould have meant serious costs to theindustry with very little safety benefit.This meant full-time employment forregiments of aviation lobbyists. ASAwas asked to provide Congress withopinions on several issues important todistributors.Part MarkingThe Year of Aviation is Upon Us!man) was interested in a law thatwould require air carriers to scrap alllife-limited parts upon removal fromthe aircraft, regardless of remainingtime-in-service!Manufacturers expressed an interest inseeing segregation made available asan alternative (manufacturers segregateused critical parts that are to betested to verify or extend life limits).The manufacturers wanted to be ableto choose marking OR segregation.Soon, a proposal was made to requireboth marking AND segregation ofparts. This segregation aspect couldhave shut down the ability to buy orsell critical parts regardless of the documentationassociated with them!ASA joined several other trade associationsin discussing these proposalswith Congress, and explaining howthey would hurt, rather than help, theindustry. ASA joined other aspects ofthe industry in proposing an alternativethat would require certain informationabout cycles/time in service tobe inscribed on a life-limited part uponremoval (if feasible) in order to providea record of this information.Even if the documentation is lost beforethe part makes it to the installer,the inscribed data would still give theinstaller the information he needsabout the current state of the lifelimitedpart.Significant <strong>New</strong> Laws PostponedCongressional decision-makers hadjust begun to get a grasp on the problemsand the solutions, when the currentsession of Congress was over.Too much time had been spent onother priorities, like impeachment discussionsand appropriations bills, topermit the House and Senate to fullyand finally address the important issuessurrounding aviation. CongressThe August issue of The Update Reportreminded members with an interestin the Part 66 rule (mechanics andrepairmen) to send comments to theFAA before the deadline. The FAAhas extended the comment period forresponding on the Part 66 proposal:the new deadline is Jan. 8, 1999.One of the most important issues thatwould affect distributors is a partmarkingproposal. The proposal wasintended to provide installers withgreater information about the state of aused part at the time of installation.Although the original draft would havemerely required that critical parts bemarked in some way upon removalfrom the aircraft, internal drafts anddiscussions on Capitol Hill quicklyturned to more draconian measures.One Congressional staff member admittedthat her boss (the Congresspassedan Omnibus AppropriationsBill which included all of the flotsamand jetsam that needed to become lawbefore Congress could adjourn. Thenext day, Washington, DC was aghost-town, as everyone fled back totheir home districts to campaign furiouslyfor the November election.The Omnibus Appropriations Bill includedjust enough to keep the FAAgoing for the next year. It did notsolve any of the tough issues and it didnot authorize any additional aviationspending beyond next year. Membersof Congress agreed that all of thetough aviation issues would be heldover until 1999, but that Congresswould address these issues early inthat Congressional session.Look out for 1999. It's going to be aturbulent trip for the entire industry asCongress debates the future of theFAA as well as the future of the industry.Like many transportation issues,the most important discussions willnever be televised on C-SPAN, theCongressional cable station that televisescommittee hearings and floordebate. The most important discussionswill take place in drafty meetingrooms in the Rayburn House OfficeBuilding, where trade association andindustry executives will discuss, educateand negotiate the issues that arecritical to the future of the aviationindustry.113 ASA-The Update Report October 1998

LEGAL EYESupreme Court Could Impact DistributorsAt least three of the cases before theUnited States Supreme Court this yearhave the potential to impact the businessinterests of ASA members.These cases address exclusive purchasingagreements, arbitrationclauses affecting employee disputes,and terminating employees whose legalinterests are adverse to the company'sbusiness interests.In Discon, Inc. v. NYNEX Corp., theCourt will address a situation where acustomer enters into an exclusive purchasingagreement with Supplier Athat precludes purchase from SupplierB. There is a general American legalprinciple that permits a company to dobusiness with whomever it chooses todo business, so this sort of arrangementis usually legal. The SupremeCourt will examine whether there aresituations where this sort of conductwould not be legal - particularly whereit might be characterized as a groupboycott or an attempt at monopoly.All distributors could be affected bythis ruling - it will either bolster thecurrent state of the law that permitssuch relationships, or it could throwcurrent business relationships in disarray.The lower court's decision in thiscase can be found at 93 F.3d 1055 (2dCir. 1996). Oral argument before theSupreme Court was held on October 5.An appellate court recently examineda general arbitration clause in a collectivebargaining contract. An employeewho was subject to the arbitrationclause had a discrimination grievanceagainst the company. The court heldthat the arbitration clause prohibitedthe employees from filing his owndiscrimination lawsuits - he was requiredto pursue his remedies throughunion arbitration. Cesar Wright, theaggrieved person, claimed that thisdecision contradicts the holdings inseveral other lower courts, creating alegal controversy. Wright has askedthe Supreme Court to review this decisionbarring him from filing his ownlawsuit. The lower court decision inthis case, Wright v. Universal MaritimeService Corp., 121 F.3d 702(4th Cir. 1997), is unpublished. Adecision in favor of Wright could havefar-reaching consequences if it makessome arbitration clauses meaningless.Oral argument in this case was held onOctober 7.This case examines a potential violationof the Civil Rights Act [CRA]. Itis a violation of the CRA for people toconspire to deter someone from beinga witness in a court. The same provisionof law makes it illegal to injuresomeone in retribution for such testimony.An illegal injury can be aninjury to the person or an injury to anyproperty interest. In Haddle v. Garrison,132 F.3d 46 (11th Cir. 1997), theCourt will examine whether firing anemployee in retribution for that employee'stestimony (or threatening todo so to prevent testimony) is a violationof the CRA. The legal issue at thecore of this analysis is whether the jobrepresents a property interest despitethe fact that the fired-person was an"at-will" employee who could be firedat any time for any reason. If theCourt decides in the employee's favor,then employers could be precludedfrom terminating employees with adverselegal interests! Of course, thiscase will not address whistleblowerstatutes or other provisions of law thatcould be applicable. Oral argument inthis case is scheduled for November10.Decisions in each of these casesshould be issued during the first halfof 1999.MARKET OUTLOOKBoeing Expects AirCargo Fleet toDouble by 2017Where do tomorrow's markets lay?Perhaps they lay among the cargo carriers:the biennial Boeing World AirCargo Forecast predicts a neardoublingof the world's jet freighterfleet by 2017.There are currently 1434 jet-poweredcargo freighters in the world's fleet.Boeing predicts that number to growby more than 1000 in the next 20 years(based on expected annual growth of6.4 percent in the world's air cargofleet). The Report predicts that about70 percent of the growth will bethrough conversions of passenger aircraftto cargo configurations. Theremaining 30% will be aircraft that aremanufactured in a cargo configuration.Report Predicts Boom in AsiaDespite the recent financial problemsin Asia, the Boeing Report predictsthat the intra-Asia freight markets willhave the fastest long-term air cargogrowth, estimated at an average 8.2percent per year. Not surprisingly, thereport also expects air freight betweenAsia and each other market to exceedthe world average of 6.4 percent annualgrowth. It quotes Bruce Dennis,Boeing Commercial Airplanes VicePresident - Marketing, who explainsthat "although the world economy isadjusting to the Asian market, thereare strong sales opportunities for thefuture."The conclusions of the Boeing Reportunderscore the proposition that Asiacould still prove to be the unusuallyrich market of the future that manypredicted. Businesses interested inAsia should exercise diligence and(Continued on page 115)114 ASA-The Update Report October 1998

ARAC NEWSDelegation Rule Proposal Sent to the FAAFAA may soon engage in a wholesalerestructuring of the way that it delegatesauthority to organizations. Agroup of industry and FAA representativeshave been working together todevelop a new, improved delegationssystem that could provide some additionalprivilege for some distributors.Under current law, the FAA is permittedto delegate some of its authority toprivate parties that are qualified towield that power. The private partieswield governmental authority underFAA supervision, and bear the powerto sign documents as if they were theFAA. Delegations are often thoughtof as falling into two categories: individual(AME, DAMI, DAR, DER,DME, PE) and organizational (DAS,DMIR, DOA, ODAR, SFAR 36).The FAA is only permitted to delegatepowers related to certification and issuesthat arise pursuant to certification,but this represents a wide varietyof powers. For example, while theFAA would not be permitted to delegatethe issuance of an AD (that is arulemaking function), the FAA wouldbe permitted to delegate the approvalof design data used to support theissuance of a type certificate. Manydistributors are familiar with designatedairworthiness representatives(DARs), who hold the delegated authorityto issue airworthiness approvals(which support the aircraft'sairworthiness certificate).The FAA has deposited rules governingdelegations all over the code offederal regulations. This sometimesmakes it difficult to administer thedelegations programs in a uniformmanner. As a consequence, the FAAasked the Aviation Rulemaking AdvisoryCommittee (ARAC) to developharmonized rules to cover all organizationaldelegations.The Working Group that has donemuch of the work in developing thisproject is chaired by Web Heath ofBoeing. Heath's Working Group hasdeveloped a regulatory proposal tomerge all organizational delegationsunder one umbrella: OrganizationalDelegation Authority (ODA). On October22, Heath submitted the group'scompleted ODA proposal to ARACfor a final vote, and ARAC voted torecommend the proposal to the FAA.The next step is for the FAA to reviewthe rulemaking proposal and decidewhether it has sufficient merit to becomean FAA task. Since the FAAsubmitted this task to ARAC, and theauthority for several of the delegationoptions is expiring, it is likely that theFAA will choose to implement a rulefollowing the ARAC model. The nextstep after that will be to determine towhat extent the ARAC proposal mustbe revised before being published as aNotice of Proposed Rulemaking.For a distributor, the most importantchange in the rule will be in the eligibility.Current organizational delegationsrequire the applicant to possessan FAA-issued certificate as a conditionof eligibility. The new rule willfocus more on capability. This meansthat a certificate holder will not automaticallybe eligible for ODA - hemust also prove capability to carry outthe delegated FAA functions. It alsomeans that a non-certificate holderwith appropriate capabilities may beeligible for a delegation when this newrule is promulgated. The capabilityrequirements will be quite high, butthe possibility remains for properlyqualified distributors. A distributorwith ODA could sign its own 8130-3forms under appropriate circumstances.(Continued from page 114)caution in developing new Asian customers.While the potential hazardsremain substantial, the Asian marketstill holds the same promise of untoldriches that it held out to Marco Polo.On September 10 Boeing CommercialAirplane Group and Federal Expresslaunched "Boeing Express," an additionaldelivery option for aircraftspare parts customers. Boeing Expressoffers spare parts delivery usingthe global FedEx distribution network,which features speed, reliability,and on-line traceability.Delta Air Lines announced on October 23 that the fifteen 757-200 aircraft currentlyon order with Boeing will be powered by Pratt & Whitney PW2037 engines.When the fifteenth new aircraft is delivered in April, 2000, Delta will havea fleet of 110 Boeing 757-200 aircraft: all powered by the PW2037 engine.Companies that do not currently holddelegations and that are not eligiblefor ODA will not lose any existingprivileges.The rule still has a long way to gobefore it gets published for publiccomment, but it does signal a futureopportunity for suppliers with highquality operations to be recognizedwith additional privileges.115 ASA-The Update Report October 1998

REGULATORY UPDATE8130-3 <strong>Guidance</strong>(Continued from page 109)bears a signature that approves the partfor return to service may represent anadequate record under the recordkeepingrule at 14 C.F.R. § 43.9. If the sameform omits the work order number, thenit may be deemed unacceptable to arecipient for commercial reasons butthat does not make the part an"unapproved part."Examining another example, an 8130-3form that indicates in the "Status/Work"block (block 12) that the part was repaired,but fails to explain the scope ofthat repair in the "Remarks" block, mayrepresent a form that is insufficient onits face. Under such circumstances, it isoften wise to contact the party that sentthe part to determine whether additionaldocumentation is available to remedythis apparent failing. For example, ifthe form already references a work ordernumber (block 5), then attaching acopy of the work order may be sufficientto describe the scope of the workcompleted.Those suppliers who keep copies of theFAA Order 8130.21B in their officesshould be sure to obtain a copy of thisFAA memo and file it will the Order.This will give them the latest word onhow to read the 8130-3 forms that entertheir facilities. The memo is describedas AIR-200 Policy Memo # 98-07,Clarification to Order 8130.21B (June22, 1998). This document was distributedto everyone who attended theASA Annual Conference. The memomay be available from the local FAAoffice; and of course the memo is availablethrough ASA's website. Memberswho are unable to get it through otherchannels should fax their request for acopy to the association.Missed the ASA Annual Conference?You don’t have to miss out on the Annual Conference Binder!Extra binders with copies of all distributed conference materials areavailable while supplies last... just send $75 to:Airline Suppliers Association636 Eye Street, NW, Suite 301Washington, DC 2000-13736ILS brings youthe world ofaviation buyers!ILS gives you access to a market of active buyers thatincludes:♦ Over 170 of the world’s airlines♦ 550 repair facilities♦ 75 major FBOs♦ 40 U. S. Government agencies♦ 25,000 accesses each business day♦ 3,000 subscribers in 65 countriesDon’t just find a buyer. Reach the aviation world.Inventory Locator Service, LP3965 Mendenhall Road • Memphis, TN 38115 – U.S.A.1-901-794-5000 • Fax 1-901-794-1760London44-1293-562011 • Fax 44-1293-562066Hong Kong852-2543-7735 • Fax 852-2541-5908116 ASA-The Update Report October 1998

FASTENER QUALITY ACTSound-Off AboutInsulation Blanket BingoINDUSTRY LEADSDo you have strong feelings about theFastener Quality Act [FQA]? Love it?Hate it? Think it could be made better?Here's your chance to sound off!The Department of Commerce is solicitingcomments on the FQA.Four months ago, ASA predicted thatthe FQA would be postponed byCongress (6 The Update Report 63)and two months ago we reported that ithad been (6 The Update Report 87).As a part of the postponement,Congress demanded a report analyzingwhether the FQA should be changed.This report is due by February 1,1999.The Department of Commerce is responsiblefor preparing the report.Commerce has asked for informationon how fastener manufacturing processeshave changed since the enactmentof the Fastener Quality Act andon other regulatory programs that regulatethe various categories of fasteners.Commerce has identified fivebroad topics on which it particularlyrequests public comments:• Basis of the Act: When FQA waspassed in 1990, Congress based iton a number of findings. Are thosefindings still valid today? If not,how have they changed and why?• Coverage of the Act: FQA defines"fasteners." Is this definition appropriate?• Testing and Certification: Are thereaspects of current manufacturingtechnology where sampling, testing,and issuing a laboratory report withan original signature is not feasible?Sale of Fasteners: Is it appropriate forFQA to require fasteners of foreignorigin be accompanied by a manufacturers'certificate and an originalAir carriers may soon find themselvesbuying large quantities of insulationmaterials to replace existing thermaland acoustic insulation material.Insulation installed in aircraft mustmeet regulatory flammability requirements.Engineers use tests like exposureto a bunsen burner for a specifiedperiod (i.e. 12 to 60 seconds) to verifythat the materials are sufficiently resistantto flammability. Recent findingshave suggested that insulation blanketsthat pass FAA burn-tests may nonethelessbe insufficiently flame resistant.Because of inconsistencies in the waythat burn tests are performed in somecases, materials may have passed theburn tests without really meeting thesafety requirements of the aviationregulations.Recognizing that better tests are desirable,the FAA announced on October14 that it will develop a new test specificationfor insulation that will resultin increased fire safety on aircraft.After the new test standard is developed,the FAA plans to publish a proposedrule that requires the use ofimproved insulation.laboratory report when purchasedand imported?• Record Keeping : Are FQA'srecordkeeping and reporting requirementsappropriate?Persons interested in commenting onthe issues outlined above, or any othertopics related to the FQA, should submittheir comments in writing to theDepartment of Commerce. The fulltext of this notice, as well as completeinformation on submitting comments,is available through ASA's web page.Not a single fatality nor injury has everbeen attributed to an insulation blanketfire. Nonetheless, the FAA is interestedin acting quickly to help assurethat this statistic never changes. TheFAA has already performed a preliminaryidentification of two materialsthat could provide a substantial increasein fire resistance: fiberglass anda material known as Curlon. Whenused for insulation blanket purposes,each is wrapped in a polyimide film(for heat resistance).The FAA is urging major airframemanufacturers and air carriers to worktogether to begin upgrading existinginsulation materials during scheduledmaintenance activities. Boeing hasalready responded with a press releaseof its own that pledges to support theFAA's efforts. There is also talk ofissuing service bulletins (from manufacturers)and airworthiness directives(from the FAA) to advise owners andoperators of the need to replace existingthermal and acoustic insulationwith more flame-resistant alternatives.The FAA has announced that when itdevelops its new test (expected withinthe next six months) then it will requireinsulation materials to pass thistest. The FAA has pledged to"grandfather" any aircraft retrofittedwith fiberglass or Curlon, which providesan incentive for the industry toadopt this retrofit now.Suppliers holding inventories of insulationblankets should review the materialsfrom which they are constructedto determine their future salability inthe United States aviation market.Those handling appropriate materialsshould gauge their customers' needsand be prepared to service thoseneeds.117 ASA-The Update Report October 1998

AT 800 INDEPENDENCE - FAA HQ NEWSMcSweeny Is <strong>New</strong> FAA Assoc. Admin’rThose of you who saw him on 60Minutes a few weeks ago might notrealize this, but Tom McSweeny ismore than just a pretty face.McSweeny was recently featured in ainterview on the popular televisionnews program 60 Minutes. He wasasked to comment on the recent findingsconcerning deterioration amongthe wiring on transport category aircraft(Kapton wiring). Those whowatched his smooth performancemight have thought he was an actorpaid to represent the FAA in their TVappearances, but Tom McSweenydoes more than just "play an engineeron TV."At the time of the interview he wasDirector of the FAA's Aircraft CertificationService [ACS]. As ACS Director,he oversaw the airworthiness andsafety of all U.S. commercial aircraftdesign and production. One of Mc-Sweeny's employees, Bruce Kaplan,likes to quip "we're in the approvedparts business" because approving designsand production systems is thejob of the ACS.Very shortly after the television interview,though, FAA Administrator JaneGarvey completed the process of promotinghim to the job of AssociateAdministrator for Regulation and Certification.As Associate Administrator, Mc-Sweeny will be responsible for morethan just the certification and productionapproval. He will also be responsiblefor the continued airworthinessof aircraft; certification of pilots, mechanics,and others in safety-relatedpositions; certification of all operationaland maintenance enterprises indomestic civil aviation; developmentof regulations; civil flight operations;and the certification and safety oversightof some 7,300 U.S. commercialairlines and air operators. He willoversee a work force of approximately4,300 employees and a budget in excessof 500 million dollars.The FAA Administrator seems quitepleased with her choice, lauding Mc-Sweeny as a "proven leader," and explainingthat "His outstanding managementskills, expertise, and extensiveaviation knowledge will benefitthe aviation community and the Americanpublic."McSweeny joined the FAA in April1974 as a certification engineer in LosAngeles. At the time, he held a mastersdegree in aeronautical engineering,and had worked for Northrop Aircraftin the areas of acoustics, vibrationand flutter.He came to the FAA's WashingtonHeadquarters in 1979 and served inseveral capacities in the Office of Regulationand Certification. He servedas manager of the Engineering Divisionin the Aircraft Certification Service[ACS] from December 1982 untilJuly 1989, when he was named ACSdeputy director. He became the ACSdirector in 1993.REGULATORY UPDATEAirworthiness Directive: Oxygen Mask AlertAlthough Airworthiness Directives(ADs) apply against aircraft owner /operators and not against those whohold inventory, most distributors liketo track ADs in order to provide avalue-added service to the customersthat need to comply with the ADs.Most ADs are issued against products(aircraft, engines, and propellers);however, some ADs are issued againstparts. Because of the way ADs arecatalogued, ADs that are issuedagainst parts (as opposed to products)may be overlooked.The FAA has recently issued an ADagainst parts. The FAA is proposingactions to be taken against Puritan-Bennett Aero Systems CompanyC351-2000 series passenger oxygenmasks and portable oxygen masks.These masks are commonly installedon a wide variety of aircraft. Theproposed AD would require owner /operators to inspect the oxygen maskface for tears. If a tear is found, theproposed AD directs the inspector toreplace or repair the oxygen mask.The AD focuses on masks with elastomercure dates between September1993 and March 1997. Where a replacementis required under the AD,the replacement mask must have acure date later than March 1997.Suppliers with inventories of thesemasks should review the AD to determinewhether their inventory may beadversely affected. Among suppliersthat perform AD research to supportthe end user's requirements, this couldaffect some inventories.This AD has not yet become law, andthe FAA is receiving comments on it.Comments should be submitted in triplicateto the FAA, Central Region,Office of the Regional Counsel, Attention:Rules Docket No. 98-CE-29-AD,Room 1558, 601 E. 12th Street,Kansas City, MO 64106. The commentdeadline is Nov. 26, 1998.118 ASA-The Update Report October 1998

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Find Source Documents on the InternetInterested in one of the subjects addressed in this issue? Want to find out more? The source documents underlying many of thearticles in this issue are available on the internet. Just set your browser for http://www.airlinesuppliers.com/6tur.html#10. Thisaddress features an index to the articles which will bring you to the original documents on the world wide web just by clicking onthe description.UPCOMING EVENTS* = ASA will be speaking there1998Nov. 4-5 * Airline Inventory, Component management & Overhaul Conference, London, UK. Call AircraftIndustry Conferences in England for more information: +44 171931 7072.Nov. 5-6 SPEC 2000 Forum, Adams Mark Hotel, San Antonio, TX. Contact Teresa Friend at (202) 626-4039.Dec. 2-3 * Aircraft Heavy Maintenance & Upgrades Conference, Miami, FL. Call Aircraft Industry Conferencesin England for more information: +44 171931 7072.1999First QtrJuly 18-20* ASA One-Day Workshops, Coming to your home town soon! Watch for more details next month.* ASA Annual Conference, Marco Island, FL. More details will be available in future issues.* events with asterisks will feature presentations by ASA personnel636 Eye Street, NW, Suite 301Washington, DC 20001-3736Telephone: (202) 216-9140Facsimile: (202) 216-9227ASA Will Be Conducting Its Annual Workshops All Over the Country EarlyNext Year. Watch for More Details in the Next Issue of The Update ReportAirline Suppliers Association120 ASA-The Update Report October 1998