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SSCC Engineering & Maintenance Sub-Committee Briefing to P&M TAG Liam Sisk Chairman

SSCC Engineering & Maintenance Sub-Committee Briefing to P&M TAG Liam Sisk Chairman. Why are rules too complex?. Requirements spread across different rules and AMC material (e.g. Part M and Part 145 overlap)

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SSCC Engineering & Maintenance Sub-Committee Briefing to P&M TAG Liam Sisk Chairman

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  1. SSCCEngineering & Maintenance Sub-Committee Briefing toP&M TAGLiam SiskChairman

  2. Why are rules too complex? Requirements spread across different rules and AMC material (e.g. Part M and Part 145 overlap) Requirements not ‘proportionate’ despite assertions to that effect – see GA activities to address now…. No clear ‘philosophy’ behind rules – is it performance, objective or risk based regulation? AMC material not written in a consistent manner and frequently contains too many words to describe a potentially straightforward and simple requirement – what is wrong with using a simple table to clarify a requirement? Translation of AMC results in different interpretations caused in some cases by the (English) language inconsistencies in the AMC itself (use of ‘shall’; ‘should’; ‘may’; etc) Have fallen into trap (perhaps) of ‘paper doesn’t refuse ink’

  3. Size of Rulemaking Programme Needs to be much reduced Develop ‘quota’ or limit for number of tasks which can be progressed at one time under each major regulatory heading (once established) Process for determining which tasks are being progressed must have room for tasks driven by ‘industry needs’ as well as safety related tasks

  4. What type of material should be in the rules Keep the Basic Rule simple and do not add complex requirements into Basic Rule Should be a ‘light’ framework for the areas being addressed This philosophy will only work with a much more effective and transparent standardisation process Should industry have a role in standardisation?

  5. What type of material should be in the AMC/GM Clear philosophy required as to what is AMC and what should be included there and what GM should be used for Working groups need clear instructions / guidelines re development of proposed rule changes and associated AMC/GM AMC should amplify and clarify the rule in a simple and clearly written manner – long sentences and paragraphs to be avoided

  6. Current implementation issues See GA input from Franz x 2 Implementation issues more frequently raised from certain member states – ‘standardisation’ appears not to be effective in resolving these issues

  7. Implementation difficulties Over complex regulations Too many regulations Increased difficulties in bringing new personnel through licencing system Fewer certifying staff available for small and medium organisations More ‘pressure’ in the system = potential longer term safety concern?

  8. Summary ‘Simplify, simplify, simplify’ – outgoing ED statement

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