On March 6, the FAA said it had revoked the repair station certificate of Arlington, Texas-based AeroBearings “for improperly overhauling and repairing turbine engine bearings.” AeroBearings appealed the revocation, and an administrative law judge reduced the sanction to an indefinite suspension of the repair station certificate pending compliance with requirements set by the company’s FAA principal operations inspector. However, on May 11, the NTSB reversed that decision and reimposed the revocation.

On October 22, the Aeronautical Repair Station Association (ARSA) filed an amicus (friend of the court) brief to the U.S. Court of Appeals for the District of Columbia, asking the court to reverse the NTSB’s revocation.

In its original revocation, the FAA claimed that “AeroBearings routinely disassembles, inspects and overhauls turbine engine bearings without possessing the data necessary to perform key aspects of this safety critical work. The FAA further alleges that the repair station intentionally falsified documents certifying that these repairs were accomplished in accordance with appropriate data and federal safety regulations.”

The FAA said it received two complaints to its hotline “from customers who reported quality problems with bearings overhauled by the company.” The agency further said that the work that AeroBearings did “exceeded their available data on bearings for a variety of aircraft engines…” These included engines manufactured by GE Aviation, Pratt & Whitney, and CFM International.

“The FAA further alleges that because AeroBearings did not possess the necessary approved data to determine that the overhauled engine bearings met original manufacturers’ design specifications, AeroBearings could not determine they were airworthy.”

ARSA’s amicus brief explains FAA regulations and their intent to the Court of Appeals. According to ARSA, the FAA’s order of revocation “alleged falsification of multiple maintenance releases based on incomplete information in block 12 of FAA Form 8130-3. During the original proceedings, the inspector agreed there was no false or incorrect information on any of the forms; the entries were simply incomplete.”

FAA regulations in FAR Parts 43 and 145 do not require inclusion of “maintenance record” information in block 12, ARSA explained. What is required by FAR 145.219(b) is a maintenance release, which is the 8130-3 approval for return to service or logbook entry. And FAR 43.9 requires provision of the complete maintenance record, which contains far more information than is required in the maintenance release. “A maintenance release is a certification that the work performed was accomplished correctly; it is not a complete maintenance record,” the ARSA brief explained.

If the NTSB’s revocation order is upheld, warned ARSA executive director Sarah MacLeod, “we’ll have to change the rules,” which would involve an overwhelming amount of work that would take years to accomplish. Essentially, the NTSB’s order means every maintenance provider that doesn’t include the complete maintenance record in the maintenance release has been falsifying maintenance records for many years, she explained.

Another key issue was the FAA’s questioning of “the use of specialized equipment for which the company did not possess the original engineering data.” Manufacturers of aircraft, engines, and components specify test and measurement equipment required for maintenance of their products. Some maintenance providers manufacture their own test and measurement tools and equipment, based on engineering data provided by the original manufacturer. As long as this equipment is shown to “achieve the appropriate result, there are no regulations that require retention of the data or recording of the demonstration used to make the showing,” according to ARSA.

In its brief, ARSA wrote: “The reasoning of the National Transportation Safety Board (NTSB) threatens to upend the carefully crafted regulatory scheme implemented by the FAA and international civil aviation safety authorities around the world.”

ARSA believes that the NTSB’s order of revocation should be reversed “based on this plain reading of the rules.”