GFR Continued Airworthiness Brief Props Ind Day.pdf

Government Flight Representative (GFR)Government Flight Representative (GFR)

Continuing Airworthiness (Industry Day)

Introduction

• Wilson Gilliam – Government Flight Representative (PMA-226)

• Contact information is posted at the end of this presentation.

• Feel free to ask questions anytime today or beyond.

• Purpose of this fifteen-minute presentation is to provide general information about how contractors handle continued airworthiness during contract performance.

Contents and Abbreviations

• Commercial Aircraft Operations (CAO) and Public Aircraft Operations (PAO)

• Getting started and continuing timeline for airworthiness

• The IFC: Interim Flight Clearance: Replaces the FAA A/W certificate for PAO ops

• PAO Declaration Letter: Government communication identifying which flight operations are PAO.

• DCMA INST 8210.1C, Change 1 Compliance: The “rule book” for PAO flights

• GFR (Government Flight Representative): “Responsible for surveillance of those contractor flight and ground operations where the contractor is required to comply with this contract” (8210.1C).

• Safe for Flight (SFF)

– New Contract, New Aircraft Type, New Mission Type, New Facility

• Aviation Maintenance Management Team (AMMT)

– Every 2 Years

• Focused Inspection Areas

• Putting Everything Together

• Contact Information

CAO and PAO

What types of flying will you do on contract flights?

• There are two main types of flying for contract missions:

Commercial Aircraft Operations (CAO) and Public Aircraft Operations (PAO). Flying missions may involve CAO only, a mix of PAO/CAO or PAO only.

• The easiest one to talk about: CAO only missions for the entire contract: No GFR oversight is required because the 8210.1C is not applicable. Contractors will handle airworthiness under existing FAA Airworthiness Certificates and FAA rules (Parts 91, 135, 133 etc.). Referred to as “14 CFR” rules.

• Both CAO and PAO missions OR PAO only: Require conformance with 8210.1C before any contract flights are initiated.

CAO and PAO

Type of flying?

CAO

ONLY

No GFR oversight, no

8210.1C.

Contractor maintains FAA A/W

Mixed

CAO/PAO PAO ONLY

REQUIRED Airworthiness Process

Interim Flight Clearance (IFC) Compliance with 8210.1C

Safe for Flight Inspection (SFF) Aviation Maintenance Management Team

(AMMT)

Then…

Timeline for Pre- PAO Ops

PAO

Declaration Letter from

PMA-226

Contractor submits Flight and Ground Ops Procedures

(FGOPs) to GFR

ICW 8210.1C

and gets them approved.

GFR visits contractor operational facility to verify compliance w/approved FGOPs.

Safe for Flight Inspection (SFF) is scheduled.

AMMT

inspection within 24 months.

These steps are

REQUIRED

before any contract flights begin.

Contractor works with NAVAIR engineers for Interim Flight

Clearance (IFC).

IFC issuance marks beginning of the GFR’s job.

Example Timeline for PAO Ops

Once PAO ops begin…

GFR-Approved Contractor Flight and Ground Procedures (FGOPs) incorporate requirements of IFC, contract and 8210.1C.

Continued Airworthiness involves contractor compliance with FGOPs:

Submits flights to GFR for approval.

Adheres to pilot / mission training and maintenance requirements.

Submits flying and non-flying crewmembers for GFR approval.

Facilitates GFR facility inspections.

Mitigates risk, continually improves safety.

DCMA 8210.1C, Change 1

• Additional Comments: Flight Operations and Ground Operations

Procedures (FGOPs)

– FIRST: is the Ground Flight Risk Clause (GFRC) included in contract?

• If YES, then the entire 8210.1C, Change 1 is applicable

• If NO, then only 8210.1C, Change 1 Attachment 16 is applicable

– Second: the manuals must ensure the MOST RESTRICTIVE contract provisions are included in the manuals (i.e.. Pilots Quals, Currency)

– Most Restrictive: Manuals must ensure compliance with the following (as applicable): U.S.

Federal Law (PAO/State), Contract Requirements, DCMA INST 8210.1C, Regulations (14CFR Part 91), ICAO Standards, Foreign CAA Regulations AND ALL INITIAL AND REVISED

MANUALS MUST BE APPROVED PRIOR TO OPERATIONS.

Flight Operating Procedures (FOPs) Ground Operating Procedures (GOPs) Pilots Training Program Maintenance Training Program Safety Program Emergency Response Plan Cross Reference Matrix There is a NEW, soon to be released version of the 8210 (8210.1D).

GFR Inspections

• Additional Comments: GFR Inspections Scheduled – Every 6 months

(per operating location). Similar to Part 135 facilities inspections and aviation safety inspections.

Required validation:

Compliance with DCMA 8210.1C, Change 1 Compliance with the Contract Compliance with the contractors GFR approved FOPs/GOPs Interim Flight Clearance (IFC) compliance Corrective Actions from Prior GFR and AMMT Inspections

NOTE: EVERY 6 MONTHS, the contractor is required to complete an internal review of its manual and procedures and submit the audit results to the GFR, along with any corrective actions and manual updates.

Inspections can last 1-2 days, based on findings and prior inspection results.

Outcome of inspections:

Satisfactory – No findings CAR – Level 1 (GFR / Management Team – Corrections made on the spot followed-up by manual revs) CAR – Level 2 (Contracting Officer / PMA-226 / Contractor’s President – Warning) CAR – Level 3 (Contracting Officer / PMA-226 / Contractor’s President – Possible Disbarment)

Safe for Flight (SFF)

• Additional Comments: Safe For Flight Inspection

– Required for

• New Contracts (Prior to Start of Operations),

• New Aircraft Types,

• New Mission Types, and

• New Primary Operating or Repair Facilities

– Team of 4-6 people

– Team consists of Operations and Maintenance specialists from Pax River

– Validate the GFR approved procedures, contract compliance and can safely conduct the contracted missions

AMMT

Aviation Maintenance Management Team (AMMT)

Team of Maintainers from Pax River will validate:

Ground Operations Procedures (GOPs)

Contract Requirements related to maintenance

Aircraft Interim Flight Clearance Compliance

Inspection Every 2 Years after start of Operations & will last 4-5 Days

Required to provide internet access and a conference room for the AMMT

Results of maintenance audit will be shared with the Contracting Officer, PMA- 226, GFR, and Contractor

Focused Inspection Areas

Compliance with IFC and Deferred Maintenance Program Flight Logs & Write-ups (all write-ups at maintenance facilities?)

Aircraft Alterations approved in the IFC

Pilot and Maintenance Training Records – Actual or Digital Signatures of Instructors and Students (Ref FAA AC for Digital Sigs) Pilot & Maintainer Training Exams maintained in Training Files Signed Forms DD2628 and DD1821 in Training Folders

Tool Control, Toolbox Inventories, Tool & Equipment Calibration Records

PAO / CAO Compliance - PAO vs CAO Training, Repositioning Flights, GFR Approved Daily Schedules, Only Authorized Crew Onboard PAO Flights, PAO/CAO Record Keeping.

Putting Everything Together

New contractors will be required to work on multiple things at once during the stand-up period. These will include working with the Program Managers on contract requirements. However, it will also include working with the engineers on data required for the IFC. Contractors must also submit FGOPs to the GFR as early as possible to prevent delays.

Remember: FGOPs must be approved before the initial GFR inspection, SFF and AMMT inspections can be scheduled.

Contact Info

Wilson Gilliam, GFR

NAVAIR / PMA-226

wilson.e.gilliam.civ@us.navy.mil Cell: 757-701-5054