Vertically Speaking (Nov/Dec 2016) — safety issues for rotorcraft pilots

by Gene Trainor, FAA Rotorcraft Directorate

If you’re a helicopter pilot, you likely know the FAA from your communications with air traffic control. If you’re renewing a flight instructor certificate, or adding ratings, you might be working with representatives from the FAA’s Flight Standards Office. Helicopter mechanics working in repair stations frequently interact with FAA inspectors. You will likely know the Aircraft Certification Division (AIR), if you handle Airworthiness Directives, also known as ADs.

For those unfamiliar with ADs, they are legally enforceable regulations typically used to identify an unsafe condition, such as a faulty part or maintenance procedure pertaining to an engine, rotor system, or another part of a helicopter. The AD requires “corrective action” to prevent an accident. This corrective action can involve anything from repairs, to replacements of faulty parts, added safety inspections, or limitations on parts or systems. In certain cases, ADs allow pilots to check a part or a system, when a mechanic is not available, to ensure its condition and usability.

AIR understands there can be more than one way to address a safety concern.

What’s an AMOC?

Helicopter manufacturers, operators, pilots and mechanics can request an AMOC (Alternative Means of Compliance) to meet an AD’s compliance requirements provided it ensures an equivalent level of safety. AMOCs often can be a more cost effective and efficient means of meeting AD requirements. AIR understands that there can be more than one way to address safety concerns, and the FAA’s Rotorcraft Directorate Standards Staff and Aircraft Certification Offices (ACOs) are always on hand to review specific requests for an AMOC. Contact an Aircraft Certification Office or the Rotorcraft Standards Staff directly to request an AMOC.

There are ways to get a more timely decision on your AMOC request. Here are some helpful tips:

  1. For mechanics, discuss your proposed AMOC with your FAA Principal Maintenance Inspector (PMI). Your PMI can provide feedback on your proposal and forward it to the correct office for a timely approval.
  2. Use the AMOC contact address on the AD. Send an email, if an email address is provided, or send your request by regular mail. However, do not address it to the engineer listed on the AD; the office staff will forward your request to an appropriately qualified and available engineer who can help expedite your request. When you use this direct-send method, it also gives FAA managers a heads-up that an AMOC request is in progress, and they can step in and speed up the request.
  3. Clearly state the reason for the AMOC. Include your analysis to show how your proposal ensures an equivalent level of safety compared to the AD’s established requirements, which are contained in the Required Actions section.
  4. Include the Directorate Identifier, and the specific AD number that prompted your request. This step saves AIR engineers time, and confirms they have the correct AD for meeting your request. The AD number is found at the top of an AD. For example, you will typically see: [Docket No. FAA-2016-4280; Directorate Identifier 2016-SW-008-AD; Amendment 39-18429; AD 2016-05-11]. In this case, you would include in your request the Directorate Identifier 2016-SW-008-AD and AD 2016-05-11.
  5. Let the Directorate Standards Staff or ACOs know if the AMOC is for a single helicopter or for a “global” AMOC. A global AMOC would apply to all models of that helicopter. If the AMOC applies to only one helicopter, they will need that helicopter’s tail number and serial number for better identification.

“The more information you put in the AMOC, the faster we can make a determination,” two directorate engineers explained. “If we have to contact you for additional information, then it takes more time to do the evaluation and make a final decision.”

The FAA understands that compliance with an AD can be an added expense, and they consider all AMOC requests with an open perspective. At the end of the day, our first priority is always aviation safety.

Gene Trainor is a technical writer and editor for the Rotorcraft Directorate in Fort Worth.

This article was originally published in the November/December 2016 issue of FAA Safety Briefing magazine.

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