7-1 CHAPTER 7. MEL CREATION AND FORMATTING
7.1 General. When constructing an MEL, each operator should consider their particular aircraft configurations and operational procedures. An MEL is based on the MMEL for the aircraft and should include the characteristics of an MMEL. In addition to the required MEL format items, an operator’s MEL should include specific content based on the items installed on the operator’s aircraft. An operator’s MEL should incorporate the phraseology used in the MMEL, wherever appropriate, to ensure clarity and standardization.
7.2 MEL Format Outline. Operators may copy the MMEL format outline directly into their MEL. An operator may also customize their MEL format provided the format does not make the MEL in any way less restrictive than the MMEL. The MMEL format outline contains eight sections. An MEL should always include six of those sections. The operator may include additional information sections in addition to the ones listed in Chapter 2, Minimum Equipment List (MEL)—General. The following information describes the operator’s recommended MEL format:
7.2.1 V ertical Bar (Change Bar) . All change bars applicable to the previous revision of the MMEL or MEL should be removed prior to release of the next revision in a manner consistent with the operators’ manual system revision process.
7.2.2 Su b system Titles. Identify subsystem titles in column one with 1), 2), etc. For example (bullets are used in this example, but are not required):
• 28-xx Fuel Quantity Indicating System o 1) Main Tank o 2) Center Tank
7.2.3 Items That Must be Operative for All Conditions. Generally, an MEL should not include any items that must be operative for all conditions. Operators may include certain items listed as required to be operative to ensure they have not inadvertently been missed, or for fleets with varied configurations, etc.
7.2.4 W hen a n MMEL Relief Item is Deleted or Moved. When an MMEL relief item is deleted or moved, the item name and sequence number will be retained in the MMEL, with an appropriate notation in the “Remarks or Exceptions” column. The MMEL revision number of the deleted or moved relief item is included. For example:
• Relief is deleted entirely: “Deleted, Revision X.”
• Relief is combined with relief at another location: “Relief combined with ATA 31-XX, [Relief Title], Revision X.”
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• Relief is moved to another Air Transport Association of America (ATA) chapter:
“Relief moved to ATA 31-XX, Revision X.”
• Relief is moved to another FAA-approved document: “Relief moved to [Document Name], Revision X.”
Note: Operators may follow the MMEL format using the MEL revision number as appropriate, may simply delete the applicable item, may list the item as required operative, or may use another method that is acceptable to the FAA.
7.2.5 N umber Installed/Number Required for Dispatch . In the “Number Installed” or “Number Required for Dispatch” column, use a number whenever possible; otherwise, use a “-” with proper qualification.
7.2.6 Single Proviso Formatting. W hen only one proviso condition exists, it should be arranged into the statement of relief.
7.2.7 Control or Switch Position. Where a control or switch position is specified, indicated by label, or special emphasis is required, use all caps instead of underlining (e.g., “ON-OFF” or “OPEN-CLOSED.”) Use of the word “position” in reference to “ON-OFF” or “OPEN-CLOSED” is often redundant and need not be included. Alternative means of emphasis may be used, consistent with the aircraft manuals and operator manual system, if approved by the Principal Operations Inspector (POI).
7.2.8 Reference to Another Item Listed in the MEL. Where a proviso refers to another item listed in the MEL, typically to require that item be operative, the item will always be referred to using the exact same title as listed. The relief item number will generally not be used to reference an item.
7.2.9 Limiting Altitudes. Wh enever possible, all limiting altitudes stated should include the words “or below” (e.g., “10,000 feet MSL or below,” “FL 310 or below”).
7.2.10 Specific Word Usage. The word “operative” should be used instead of “operable.” Delete the word “the” wherever possible.
7.2.11 Provisos. Use letter and parenthesis (e.g., a), b), etc.) to identify proviso conditions.
Delete the word “or” when it is located between proviso conditions. Each set of needed proviso conditions should be repeated as required to eliminate the use of “or.” Use a comma after all proviso conditions and prior to the last one use “, and.” Use a period after last proviso condition. For example:
a) F irst c ondition,
b) Second condition, and
c) Last condition.
7.2.12 N ote(s) . Each note applies only to the relief proviso it immediately follows and is located in the “Remarks or Exceptions” column, using all caps for the word “NOTE.” Note(s)
7-3 should be repeated, as necessary, following each applicable proviso. If there is only one note, do not number it. If there is more than one note, number each (e.g., “NOTE 1:”, “NOTE 2:”).
7.3 Prohibited Items. An MEL will not include items of the aircraft required by operating regulations (e.g., wings, flaps, rudder, etc.), nor will it include instruments and equipment required for specific operations under 14 CFR (refer to § 91.1115).
7.4 MEL Restrictions. An operator’s MEL may not be less restrictive in any way (more restrictive is acceptable) than the following:
• The MMEL from which it was developed;
• Title 14 CFR;
• The operator’s Operations Specification (OpSpec)/Management Specification (MSpec) D095, Minimum Equipment List (MEL) Authorization;
• The Airplane Flight Manual (AFM)/Rotorcraft Flight Manual (RFM) limitations and emergency procedures;
• The Supplemental Type Certificate (STC)/instructions for continued airworthiness (ICA) (as applicable); or
• Applicable Airworthiness Directives (AD).
Note: Occasionally, an AD may apply to an item that may be authorized to be inoperative under the MEL. In those cases, the operator must fully comply with the terms of the AD or an FAA-approved alternative method of compliance (AMOC) with the AD. Refer to 14 CFR part 39, §§ 39.3 and 39.19. When provisions of an AD allow operation of the aircraft on the condition that certain installed items be used or be operable, those affected items must be operable, even if the MEL provides for deferral of repair.
7.5 F leet MELs. An operator may develop a fleet MEL for multiple aircraft of the same make and model (M/M). When a fleet MEL is used, aircraft of the same M/M may have differing numbers of specific items installed. PIs may approve an operator’s use of a fleet MEL to reflect all of the items that are applicable to a specific aircraft fleet type. This is allowable provided the MMEL applies to all of the make, model, and series (M/M/S) aircraft contained in the fleet. For example, the MMEL applies to all model B747-100/200/300 aircraft.
7.5.1 I dentify Each Model and Configuration Difference. A fleet MEL should identify each aircraft model and configuration difference, when appropriate. The operator does not need to list aircraft identification numbers.
7.5.2 Modifications Within a Fleet. The aircraft manufacturer determines the configuration of the aircraft, the items installed, and the official parts listed during the initial aircraft type certification process conducted at the time of manufacture. Any subsequent installation or removal of items must be accomplished through the use of an STC or other
7-4 FAA-acceptable methods, techniques, and practices, including the use of FAA-approved technical data if the installation or item removal is a major alteration. Operators with an approved fleet MEL may continue to operate under the provisions of the current fleet MEL with new items installed in one or more fleet aircraft. However, operators may not defer repair of the new items until an appropriate revision to the fleet MEL has been approved.
7.5.3 OpSpecs/MSpecs and Manuals. The operator’s OpSpec/MSpec D095 and appropriate company manuals, such as the maintenance manual, should list aircraft M/M/S for each fleet MEL approval.
8-1 CHAPTER 8. FAA REVIEW AND INITIAL APPROVAL OF AN OPERATOR’S MEL
8.1 General. When an operator submits an MEL to the responsible Flight Standards office for approval, the Principal Operations Inspector (POI) will coordinate with the Principal Avionics Inspector (PAI), Principal Maintenance Inspector (PMI), and inspectors in other specialties as necessary during the approval process. The process of developing and obtaining FAA approval of an MEL can be viewed as a five-phase process: preliminary, submission, MEL review, MEL management program review, and approval and issuance of Operations Specification (OpSpec)/Management Specification (MSpec) D095, Minimum Equipment List (MEL) Authorization.
8.2 Preliminary. In the preliminary phase, the operator will consult with the principal inspectors (PI) regarding the requirements for initially developing an MEL. The PIs will discuss the operator’s type and scope of operations and advise the operator on how to find the current MMEL for their fleet(s).
8.3 Submission. Upon developing a draft of their proposed MEL, the operator will submit the MEL and associated documents to the FAA for review. The submitted material should be in a format that allows review and comment that is acceptable to the responsible Flight Standards office. Additionally, an MEL should be in a format that provides the FS office with the ability for thorough review and comment. The submission should include, at a minimum:
1. The proposed MEL.
2. The current equipment list for each aircraft make/model/series (M/M/S) that will be included in the MEL.
3. The MEL management program and its procedures, as required by OpSpec/MSpec D095.
4. MEL-related portions of the operator’s training program for flight and ground personnel and any associated guidance material.
5. Any manual(s) or document(s) that are referenced in the MEL and MEL management program, including:
a. Instructions for managing the repair of items listed in the MEL.
b. Policies and procedures for flightcrews to report mechanical irregularities.
c. Procedures for:
• Approving the aircraft for return to service (part 43, §§ 43.9 and 43.11); or
• Preparing the aircraft airworthiness release or the appropriate entry (§§ 91.1443, 121.709, 125.411, or 135.443).
d. Procedures for maintenance, preventive maintenance, and alterations.
e. Procedures for verification of aircraft airworthiness.
f. Inspection program requirements and procedures for required inspection personnel.
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8.4 Review and Findings of an Operator’s MEL Submission.
8.4.1 Initial Review. The PIs will conduct an initial review of the operator’s submittal to verify its completeness and will verify that submittal is detailed enough to permit a thorough evaluation. They will contact the operator if the proposed MEL package is incomplete or otherwise unacceptable.
8.4.2 C omprehensive Review. If the initial review is acceptable, the PIs will then conduct a comprehensive review. This review will normally be completed within 90 days from the initial review.
8.4.2.1 During the comprehensive review process, the MMEL is used as the primary reference document; however, the review will include verification that the MEL does not conflict with the applicable regulations of 14 CFR, the Airplane Flight Manual (AFM)/Rotorcraft Flight Manual (RFM), and the operator’s OpSpecs/MSpecs. Items that are not eligible for deferral, and therefore cannot be listed in the MEL, include:
• Type Certificate Data Sheet (TCDS) items.
• Any items required by the rules under which the aircraft is type certificated and which are essential for safe operations under all operating conditions.
• Instruments and equipment required for specific operations under the applicable operating rule(s)
• Any items required by Airworthiness Directives (AD).
8.4.2.2 The reviewers will verify, amongst other things, that:
1. The MEL format should contain sections and content, as listed in Chapters 2, Minimum Equipment List (MEL)—General, and 3, Minimum Equipment List (MEL)—Content.
2. The table of contents and pages are numbered according to the applicable Air Transport Association of America (ATA) or Joint Aircraft System/Component (JASC) numbering system.
3. The prescribed MEL preamble is used without modification (refer to MMEL PL-34).
4. The MEL contains all installed items listed in the MMEL for which relief is requested.
5. The MEL repair categories are not less restrictive than the MMEL.
6. The “Number Required” section agrees with the number installed, according to the current equipment list and is not less restrictive than the MMEL.
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7. The operator’s program includes a revision process to ensure that the MEL is revised when there are changes in the MMEL, including process instructions and a method for maintaining a current List of Effective Pages (LEP) of the MEL.
8. All abbreviations and symbols used in the MEL are defined.
9. The MEL “Remarks or Exceptions” column includes specific procedures in accordance with the requirements of the operating rules (e.g., parts 91K, 121, 135, etc.) under which the operator conducts its operation. The procedures should address what is required when a particular item is inoperative, any fleet configuration differences, and that the dispatch requirements are specified in sufficient detail. “Remarks or Exceptions” may not be general.
10. T he operator’s (M) and (O) procedures are fully developed.
8.5 MEL Management Program Review. The review of the operator’s submission will also verify that the operator’s MEL management program meets the requirements of OpSpec/MSpec D095 and the requirements of FAA Order 8900.1, Volume 4, Chapter 4, Configuration Deviation List (CDL) and Minimum Equipment List (MEL). The MEL management program should at least include:
1. A l i st of personnel responsible for MEL management.
2. A list of personnel authorized to defer maintenance in accordance with the MEL.
3. A description of specific duties and responsibilities, by job title, of the personnel who manage the MEL management program.
4. A description of training requirements for conducting MEL procedures.
5. Procedures for granting deferral authority.
6. Procedures for controlling an extension to specified repair intervals, as permitted by OpSpec/MSpec D095, to include the limit of the extension and the procedures to be used for authorizing an extension.
7. Instructions for the placarding of inoperative and removed items, including sample placards, as they would appear in service.
8. A plan for bringing together parts, maintenance personnel, and aircraft at a specific time and place for repair.
9. A review of items deferred because of the unavailability of parts to ensure that a valid back order exists with a firm delivery date.
10. A method that provides for tracking the date and, when appropriate, the time an item was deferred and subsequently repaired. The method should include a supervisory review of:
• The number of deferred items per aircraft; and
• Each deferred item to determine the reason for any delay in repair, length of delay, and the estimated date the item will be repaired.
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11. Procedures for control of MEL deferred maintenance items, including:
• Item procurement and distribution for the corrective action(s) associated with deferred items.
• Scheduling of corrective action(s), describing when and where maintenance is performed.
• Coordination between the operator’s maintenance, flight operations, and dispatch/operational control organizations regarding MEL conditions and limitations and any operational restrictions.
• Reporting and recording of the deferred MEL item and the subsequent repair or replacement of the item.
8.6 Correction of Deficiencies. The operator will correct any deficiencies before the MEL and the MEL management program approval.
8.7 Approval and Issuance of OpSpec/MSpec D095. When the review verifies that the MEL complies with all applicable requirements, the POI will sign the MEL LEPs or the control page(s) as applicable, indicating MEL approval. Authorization to use the approved MEL is granted through the issuance of OpSpec/MSpec D095. If the operator has not been previously authorized to operate with an MEL, the PMI will issue OpSpec/MSpec D095. The responsible Flight Standards office will maintain a copy of each current MEL, provided to the FAA by the operator.
9-1 CHAPTER 9. MEL REVISIONS
9.1 General. Either the FAA or the operator may initiate revisions to an MEL. All MEL revisions require approval from the Principal Operations Inspector (POI) per § 91.213.
9.2 FAA-Initiated Revisions. An operator’s MEL can be revised due to FAA actions, revision to the MMEL, a Global Change (GC) in an MMEL PL, or a request from the operator’s responsible Flight Standards office. There are two types of MMEL revisions:
nonmandatory/interim and mandatory/standard.
9.2.1 No n -Mandatory/Interim MMEL Revision.
9.2.1.1 Applicability. A nonmandatory/interim MMEL revision is optional and an operator has discretion on revising or not revising its MEL in light of the non-mandatory/interim MMEL revision.
9.2.1.2 Numbering. A nonmandatory/interim MMEL revision is identified by the current standard revision number plus a lowercase letter. For example, a non-mandatory/interim revision following Revision 5 will be identified as Revision 5a. There may be subsequent interim revisions to the same standard revision. These carry the next lowercase letter (e.g., 5b, 5c, 5d).
Note: The operator’s MEL revision number does not have to match the MMEL revision number. Operators may use their own revision numbering system.
9.2.2 M andatory/Standard MMEL Revision. A mandatory/standard MMEL revision is compulsory under § 119.51 and includes changes that are applicable to all operators using an approved MEL for a specific aircraft make and model (M/M). All operators should amend their MELs by following these standards:
9.2.2.1 A pplicability. If a mandatory/standard MMEL revision is not applicable to an operator, the operator will document the inapplicability in a form that is acceptable to the POI. The operator will then reissue the MEL control page and will indicate that the MEL is in compliance with the required MMEL revision.
9.2.2.2 Numbering. A mandatory/standard MMEL revision is numbered with the next successive change to the basic MMEL revision number. For example, the next mandatory/standard revision following non-mandatory/interim Revisions 6a or 6b is Revision 7.
9.2.2.3 Submission and Review Time Table. Operators should incorporate MMEL changes into their MEL and submit them for review and approval within 90 days of the MMEL revision date. In the case where relief for an item is removed from an MMEL, there may be a more restrictive time requirement for an operator to revise its MEL to remove the relief. If at any time an operator does not take active steps to revise its MEL, the POI may initiate the
9-2 process to remove the MEL operations specification (OpSpec)/management specification (MSpec) authorization in accordance with applicable regulations.
Principal inspectors (PI) will complete the MEL review and approval process within 90 days of receiving the MEL revision from the operator.
9.2.2.4 Restrictive Categories or Provisos. If an MMEL revision results in a more restrictive repair category or proviso, the operator does not have to close and reinitiate an existing open MEL item affected by the revision. Existing MEL items may remain open in accordance with the original repair category and proviso under which the item was initially deferred until such time as the item is repaired and the MEL item is closed. If an MMEL revision results in a change to the system or sequence item number, the operator does not have to close an open MEL item and reinitiate it under its new number. Instead, the item may continue to be tracked under its original item number until the repair category interval is reached.
9.2.3 M MEL PL GC . A GC is newly developed or changed MMEL relief for an item which may or may not be time sensitive. The sole purpose of a GC designation is to allow operators to obtain timely MEL relief for installed items referenced in an MMEL PL prior to the release of a revised MMEL. Operator incorporation of a GC is optional.
9.2.3.1 A pplicability. GCs are applicable to all or a large number of MMELs and will describe its applicability (inclusion or exclusion) when it does not apply to all aircraft types. GCs may be used to provide immediate relief for items required by a new regulatory requirement, FAA policy change, or new technology.
9.2.3.2 Numbering. GCs are identified by the letters “GC” after the MMEL PL revision number on the title page. For example: “MMEL Policy Letter (PL)-54, Revision 10 GC”.
9.2.3.3 Frequency of Publication and Life Span. GCs will not typically occur in great number or regularity and their application and use is normally limited.
Most GCs have an expiration date and the relief granted by the GC may only be exercised in an operator’s MEL before the GC expires. It is expected that the applicable aircraft’s MMEL will be amended with the relief contained in the MMEL PL GC before the expiration of the GC designation. GCs may be extended by the FAA’s initiative or upon request by the Flight Operations Evaluation Board (FOEB) Chair. The Office of Safety Standards division responsible for the PL is the approving authority for all GC extension requests. Although a GC designation may expire, the PL itself is still applicable until amended or archived.
9.2.3.4 Review and Approval. The POI has the authority to approve the operator’s MEL revision on the basis that the GC is an approved addendum to the existing MMEL.
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9.2.3.5 Header Box. A GC will contain a header box that will explain its applicability. The header box will also contain requirement(s) on how to apply the sample proviso(s) of the GC to an operator’s MEL. See Figure 9-1 below for an example of a GC header box.
Figure 9-1. Example Global Change Header Box
MMEL GLOBAL CHANGE (GC) This is an approved addendum to all existing MMEL documents. Operators may seek use of the specific relief contained in this PL by revising their minimum equipment list (MEL). In doing so, each applicable sample proviso stating the relief in this PL must be copied verbatim in the operator’s MEL. Approval of a revised MEL is gained utilizing established procedures, through the operator’s assigned Principal Operations Inspector (POI).
9.2.4 Revisions Initiated by a Flight Standards Service (FS) Office. The operator’s responsible Flight Standards office may require the operator to initiate an MEL revision for reasons such as the issuance of an Airworthiness Directive (AD), discovery of deficiencies in the operator’s MEL (including Maintenance (M) and Operations (O) procedures) or when the operator modifies their fleet. The operator’s responsible Flight Standards office will inform the operator in writing of the need to revise their MEL, including the reason(s) for the required revisions. The operator is allowed 90 days to complete the revision process.
The responsible Fight Standards office may specify a lesser period if the PIs determine that safety of flight could be affected.
9.3 Operator-Initiated Revisions. An operator-initiated MEL revision may not be less restrictive than the MMEL. An operator may revise their MEL for a number of reasons such as aircraft modifications, installation of additional equipment, changes in types of operation, or changes in maintenance or operational procedures. Operators may also revise their MEL due to suggestions or findings from their safety programs, such as Safety Management System (SMS) or Aviation Safety Action Program (ASAP).
9.3.1 Major Aircraft Modifications. An operator may need to initiate an MEL revision due to major aircraft modifications, such as a Supplemental Type Certificate (STC), a major alteration (FAA Form 337, Major Repair and Alteration (Airframe, Powerplant, Propeller, or Appliance)), or a modification to the type certificate (TC). (See Chapter 4, MEL Relief for Items Installed After Type Certification, for design changes to a TC.)
9.3.2 In stallation of Additiona l Items. An operator may initiate a change based on the installation of additional items. An operator may only add an item to their MEL if it is included in the MMEL. If an operator desires relief for an item that is not included in the MMEL, the operator may request an MMEL revision from the FOEB Chair, through their PI or directly through the Aircraft Evaluation Division (AED) (refer to FAA Order 8900.1 for information regarding the FOEB and the MMEL revision process).
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9.3.3 Changes in Operational Complexity. An operator may need to revise their MEL due to changes in operational complexity, such as adding a type of operations (e.g., passenger carrying operations) or additional OpSpec/MSpec authority (e.g., Extended Operations (ETOPS) or Category (CAT) II/II landing minimums).
9.3.4 C hanges in (M) and (O) Procedures. (M) and (O) procedures may need to be revised due to changes in operational complexity, a change by the Original Equipment Manufacturer (OEM) in recommended procedures, or as the result of analysis of data acquired through the operator’s SMS program (the Safety Assurance Process) or from voluntary programs such as ASAP data.