The aviation industry of China is open for business. This is not a mere slogan — China is taking specific steps to open their aviation industry to non-Chinese participation.
I was looking at some back issues of Aviation Maintenance and I came across an article I wrote thirteen years ago entitled “China: More Open to Business Ideas Than You Might Think.” This is still true. China has a large fleet of aircraft that is expected to grow. While the first delivery of the Comac C919 means that China is now the proud manufacturer of a transport category passenger aircraft, there is still a significant investment in Airbus and Boeing aircraft that ties Chinese airlines to Western support for the foreseeable future.
I just returned from a trip to China and I find that the rhetoric in the media is very different from the discussions being had about aviation safety. I met with the Chinese government to discuss aviation safety programs and two things were very evident. First, the Civil Aviation Authority of China remains steadfastly committed to aviation safety. But second, in the wake of Covid, China is now “open for business.”
China really is trying to be open for business. The Chinese government is taking affirmative steps to open their aviation markets. This is not just about China opening its markets to the United States. China is trying to open its markets to the world.
The first way that they are doing this is by endorsing modern distribution quality assurance programs. The Chinese government has issued guidance explaining that Chinese airlines who intend to obtain parts from distributors must make sure that the distributors are accredited to an acceptable standard (CAAC Advisory Circular AC-120-FS-058 R3). The companion document, Information Bulletin IB-FS-MAT-001 R1, explains that there are two acceptable accreditations for distributors seeking to sell into China. The first is CAMAC ASP-R5. This standard is administered by the Civil Aviation Maintenance Association of China and is largely intended for domestic (Chinese) distributors. The second acceptable accreditation is the Aviation Suppliers Association’s ASA-100. This standard was developed as an international standard that has been formally endorsed by the FAA and EASA, and the Chinese government intends to rely on it mostly for foreign (non-Chinese) distributors.
This reliance on ASA-100 provides a mechanism for companies to demonstrate that they have adopted a quality system that is acceptable to the Chinese government, and that provides an acceptable level of safety.
A second way that China is embracing international business is by embracing the latest iterations of safety management systems (SMS). China has added SMS to the latest revision of its CCAR-145 repair station rules. This means that Chinese repair stations will meet the SMS requirements that other countries are imposing on the repair station community (EASA is requiring European repair stations to adopt SMS programs; the FAA chose not to include U.S. repair stations in the latest SMS notice of proposed rulemaking). This helps to ensure that Chinese repair stations will have safety systems comparable to those required by much of the rest of the world.
I was impressed by the Chinese decision to integrate SMS into the CCAR-145 rule. This sort of integration takes more government effort, but it makes it easier for repair stations to build a single system that complies with the regulations (easier than when the government issues a set of SMS regulations that are separate and potentially duplicative of the existing rules).
The third important change is a collaboration being developed by the Aircraft Fleet Recycling Association (AFRA) and the Chinese government that will permit China to use parts that are removed from aircraft — everywhere around the world.
Under current law, a Chinese repair station may not maintain a component that is removed from an aircraft by a third party (“used serviceable material”) and a Chinese operator may not permit installation of that used serviceable material following maintenance, unless the component has met three important conditions:
1. It was removed from the aircraft by a CCAR-145 (Chinese) repair station;
2. At the time of removal, the CCAR-145 repair station identified the component with a removal tag meeting CAAC standards; and
3. The CCAR-145 repair station listed the removed component in a centralized database of acceptably-removed parts.
CAAC has identified that it wants to extend this program to permit qualified disassembly facilities outside of China to be able to sell used serviceable material into the Chinese market. To do this, they have been working with AFRA to develop a Limited-Disassembly-Program that will allow non-Chinese disassemblers to obtain CAAC approval. This very limited approval would permit the companies to remove parts from aircraft of any registry, tag them according to Chinese standards, and list them in an English language database that can be used to verify the provenance of the components.
This program will meet a number of Chinese priorities including ensuring that parts are removed under acceptable practices that are intended to prevent damage to the parts. This meets a Chinese desire to protect their system from parts that may have been damaged during disassembly or during subsequent handling. The program will ensure a level of parts handling that is consistent with the AFRA Best Management Practice (BMP). The plan includes an English language database for verifying parts. This meets a Chinese desire to protect their system from parts of unknown provenance.
The AFRA-CAAC program is an ongoing project, but it shows CAAC’s commitment to safety and their commitment to opening the Chinese market to aircraft parts that can be demonstrated to be safe.
I am told that China is flying at about 75% of the number of flights available in 2019, and they hope to get back to 100% by the end of the year. This market is rapidly returning to prominence in the aviation marketplace, and they have made it clear that they want to be a partner in the global aviation community.