AC 120-16G

Advisory circular · Air Carrier Maintenance Programs

Approved
January 4, 2016
Last reviewed
August 6, 2024
Cancels
AC120-16F
Family
AC 120-16 · 6 versions
Revision
G
14 CFR parts
121, 135
14 CFR sections
§ 135.411

Guidance, not mandatory unless a rule or AD requires it. DRS record last changed November 22, 2025.

Show pages 3–14

(3) Typically, the Origina l Equipme nt Manufacture r (OEM) will include detailed inspectio n instructio ns that you should follow following these high-load events. The objective of these instructions is to detect aircraft damage following an in-service flight or ground event.

While there are many conditio ns that can result in high-loads on the airframe and subsequent structural damage, we consider the use of flight data in your inspection process particularly beneficial for the events identified above.

(4) Your processes for evaluating these events should address:

(a) An appropriate indication that an event has occurred;

(b) An evaluatio n of the severity of the event; and

(c) Coordination with the manufacturer, as appropriate. Your special inspection procedures for high-load events should be robust enough to:

• Identify that a very high-load event has occurred,

• Assure that indicatio ns of structural damage are found in an initial inspectio n,

• Involve the OEM, if necessary,

• Provide a process for additional inspections that designed to identify all of the structural damage, and

• Provide a process for approval for return to service.

c. Technical Data that Describe Maintenance Standards, Methods, Techniques, and Proce dure s.

(1) Accomplishing Specific Tasks. This section of your manual concerns detailed procedures for accomplishing specific tasks. You should describe methods, techniques, technical standards, measurements, calibration standards, operational tests, structural repairs, etc., in this section. You should also include procedures for aircraft Weight and Balance (W&B), jacking, lifting and shoring, storage, cold weather operations, towing, aircraft taxi, and aircraft cleaning.

You can derive your maintenance manual contents from the manufacturer’s publicatio ns.

However, based on your particular service experience, organization, and operating context, the FAA expects you to continuo usly modify and customize your maintenance manual as necessary for the continuing success of your maintenance program. This is one of the desired outcomes of a well-functioning Continuing Analysis and Surveillance System (CASS), which we explain in more detail in Chapter 11 of this AC, and in the current edition of AC 120-79, Developing and Impleme nt i ng an Air Carrier Continuing Analysis and Surveillance System.

(2) Airworthine ss Dire ctive s (AD). You are required to accomplish the provisions of ADs that we issue by 14 CFR part 39. While not specifically required by any regulatio n, you should also includ e in your manual a process for managing ADs (i.e., evaluating, accomplishing, and verifying ADs). Your AD management process, as described in the current edition of AC 39-9, Airworthiness Directives Management Process, should include the following six elements: planning, support, provisioning, implementing, recording, and auditing. You may not Par 3-3 Page 9

operate your aircraft that an AD applies to except in strict compliance with the provisions of the AD, so it is extremely important that you include in your AD process provisions that ensure:

• You review ADs for applicability to your aircraft;

• You accomplish the requirements of the AD within the timeframe specified in the AD;

• You keep records of the accomplishment and current status of each AD that applies to your aircraft; and

• You ensure that any subsequent maintenance or alteration to your aircraft does not remove the maintenance or alteratio n that was mandated by the AD.

(3) Removing AD Provisions. If you do subsequently remove the AD-mandated mainte na nce or alteratio n, you will be in violat io n of part 39 and may introduce an unsafe condition in your airplane. It would also make the required records for that particular AD inaccurate. If you determine that an alternative method of complia nce (AMOC) with an AD is necessary, you should refer to the current edition of FAA Order 8110.103, Alternative Methods of Compliance (AMOC). With regard to AD recordkeeping, see Chapter 8 of this AC for detailed information that deals with your maintenance recordkeeping system.

d. Work Cards. Work cards, sometimes referred to as job cards or task cards, while not a specific regulatory requirement, have evolved as a best practice. We consider work cards to be part of your air carrier manual and the air carrier maintenance program. They are the “what to do” and the “how to do it” parts of your maintenance program. You use work cards as a simple means of complying with maintenance performance and recordkeeping regulations. Your work cards provide a control element to the performance of maintenance. They also provide the means of ensuring that all maintenance personnel comply with your air carrier maintenance manual. It is an easy way for you to make sure that your maintenance personnel, as well as other personnel, are following your procedures. The second primary function is to document maintenance activities, providing a means for you to comply with your air carrier maintenance recordkeeping requirements. Work cards may also document the results of inspections, checks, and tests for data collection and analysis. The work-in-progress audits that you conduct regarding work card activit y as part of your CASS ensure that each individual who accomplishes work on your aircraft is following your manua l.

e. Contract Maintenance. If the air carrier chooses to use another person to perform mainte na nce for it, §§ 121.369(b)(10) and 135.427(b)(10) require that the air carrier’s manual includes policies, procedures, methods, and instructions for the accomplishment of all maintenance, preventive maintenance, and alterations carried out by a maintenance provider.

These policies, procedures, methods, and instructions must be acceptable to the FAA and provide for the maintenance, preventive maintenance, and alterations to be performed in accordance with the certificate holder’s maintenance program and maintenance manual.

NOTE: See Chapter 9 for more information regarding contract maintenance requirements.

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CHAPTER 4. AIR CARRIER MAINTENANCE ORGANIZ ATION

4-1. MAINTENANCE ORGANIZATION—GENERAL. Your maintenance organizatio n must be able to perform, supervise, manage, and amend your program; manage and guide your maintenance personnel; and provide the direction necessary to achieve your maintenance program objectives. Our regulatio ns require you to include a chart or a description of your maintenance organizatio n in your manual. You can read about maintenance organizatio n requireme nt s in 14 CFR part 121 subpart L, part 135 subpart J, and portions of part 119 subpart C. These organizatio nal regulatio ns apply to your organizatio n, as well as any other organizatio n that provides maintenance services for you. A chart is a good way to show your assignment of overall and direct authorities and responsibilities.

4-2. REQUIRED MAINTENANCE ORGANIZ ATION MANAGEMENT POSITIONS.

Part 119 subpart C includes specific requirements for maintenance management positions for operations under parts 121and 135. These are management positions required by the regulations.

However, you may need more management positions to administer and manage your maintenance organization. If necessary for your operation, you can ask the FAA for a deviation from the types and numbers of required part 121 or 135 management positions.

a. Part 121 Required Positions. For operations conducted under part 121, part 119, § 119.65(a) requires that each certificate holder have qualified personnel serving full-time in the Director of Maintenance (DOM) and Chief Inspector, or equivalent, positions. Section 119.67 defines the qualifications for these positions.

b. Part 135 Required Positions. For operations conducted under part 135, § 119.69(a) requires each certificate holder to have a qualified individ ua l serving in the DOM, or equivalent, position. Section 119.71(e) defines the qualifica t io ns for this position.

c. Managem ent Per sonnel. The regulatio ns require you to state the duties, responsibilities, and authority of each of your management personnel in your manual. You should state who has overall authority and/or responsibility, and who has direct authority and/or responsibility for a given process. Also, you must notify the FAA when you make changes in your part 119-required management personnel or when you have a vacancy in one of those positions.

NOTE: “Authority” means the power to design or change fundamental policy or procedures without having to seek higher level approval. Authority is permission; it is a right coupled with an autonomous power to accomplish certain acts or order others to act. Often one person grants another authority to act, such as an employer to an employee, a corporation to its officers, or a governmental empowerment to perform certain functions.

NOTE: “Responsibility” me ans the obligation to ensure a task or function is successfully carried out. Responsibility includes accountability for the action to carry out a task or function.

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4-3. REQUIRED AIR CARRIER MAINTENANCE ORGANIZATIONAL STRUCTURE.

a. Structure . Given the different types and sizes of air carriers, we wrote broad regulations in order to define an air carrier maintenance organization. A single means of compliance or a single organizational chart that would apply to all the different types and sizes of air carrier maintenance organizations is not possible.

b. Authority and Responsibility. You should designate an individ ual with the authority and the overall responsibility for managing and implementing your entire maintenance program, includ ing all inspectio n functio ns. The individ ual you designate must meet the qualificatio ns for the DOM listed in § 119.67(c) or § 119.71(e), as applicable. The inspectio n functio ns and the required inspection functions are part of your maintenance program.

c. Organizational Functions. The FAA recommends your maintenance organizatio n have three general organizatio nal functio ns to ensure that you conduct all operations to the highest possible degree of safety. If you are a larger organization, you may have different departments for each level, while in the smallest organizatio ns, you may carry out these functio ns through one or two individuals, maybe as a collateral duty. Generally, these three organizational functional levels include :

(1) Mechanics and/or inspectors performing the work at the first level (operations);

(2) Middle managers and supervisors at the second level (tactics); and

(3) The maintenance program accountable manager at the third level (strategy).

d. Position Descriptions. We expect you to assign clear authority and responsibility in your maintenance organizatio n, includ ing delegated responsibility, for the overall maintenance program and all of its elements and functions. You should include a position description that includes each position’s duties and responsibilities in your manual so that there is not a fragmented organizatio nal system with a high risk for confusio n over who is responsible for a given element, process, or task. Watch out for hidden duties and responsibilities where the duty and/or responsibility is shown in a process but not in the position description.

4-4. SEPARATION OF INSPECTION AND MAINTENANCE DEPARTMENTS.

a. Regulatory Requirements.

(1) If you perform maintenance (other than required inspections), §§ 121.365(a) and 135.423(a) require you to have an organizatio n that is adequate to perform maintenance work. Additionally, if you perform required inspections, §§ 121.365(b) and 135.423(b) require you to have an organizatio n that is adequate to perform required inspection work.

(2) Don’t confuse your maintenance production department with your maintenance organizatio n. Also, don’t confuse your inspectio n department, if you have one, with your required inspectio n organizatio n. We have defined “maintenance” in 14 CFR part 1, § 1.1 as “inspection, overhaul, repair, preservation, and the replacement of parts, but excluding preventive maintenance.” We do not define required inspection in § 1.1. However, within the Par 4-3 Page 12

context of parts 121 and 135, the term “required inspection” has a very specific regulatory meaning, and should not be confused with the general use of the word “inspection” throughout the regulatio ns.

(3) While there is no regulatory requirement to separate the maintenance organization from the required inspection organization, there is a requirement when performing both maintenance and required inspection work to organize the performance of those functions so as to separate the maintenance function from the required inspection function.

b. Organization. Regulations require you to organize the performance of all maintenance functio ns, includ ing inspection, repair, overhaul, and the replacement of parts, to separate the functio n of required inspectio ns from the functio n of the other maintenance, preventive maintenance, and alteration activities. This organizational separation must be below the level of administrative control where you exercise overall responsibility for the required inspection functio ns, as well as the other maintenance, preventive maintenance, and alteration functions.

Consistent with subparagraph 4-3b, your accountable manager exercises overall authority and responsibility over the required inspection functions, as well as the other maintenance (includ i ng inspection), preventive maintenance, and alteration functions. See Figure 4-1, Maintenance Organizational Chart, for a representative organizatio nal chart.

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FIGURE 4-1. MAINTENANCE ORGANIZATIONAL CHART Maintenance Organization Director of Maintenance or Equivalent Position Overall authority and responsibility for both RII and other maintenance and alteration functions Maintenance Department Required Inspection Organization Responsible Manager Direct responsibility for maintenance, preventive maintenance, and alteration functions Chief Inspector or Equivalent Position Direct responsibility for RII functions Mechanic RII Inspectors Par 4-4 Page 14

CHAPTER 5. ACCOMPLISHMENT AND APPROVAL OF MAINTENANCE AND

ALTERATIONS

5-1. ACCOMPLISHMENT OF MAINTENANCE.

a. Authority to Pe rform Maintenance. As a maintenance entity, you have authorizatio n under 14 CFR part 43, §§ 43.3(f) and 43.7(e); part 121, § 121.379; and part 135, § 135.437 to perform maintenance on your own air carrier aircraft and to approve them for return to service without obtaining any other maintenance certificatio n. In addition, §§ 121.379 and 135.437 provide clear authority for you, under your air carrier certificate, to perform maintenance on behalf of other air carriers who conduct operations under the same part as you do.

b. Cer tificate Requir em ents.

(1) Each individ ual who makes an airworthiness determinatio n on your behalf must hold an appropriate airman’s certificate. Sections 121.378 and 135.435 require that any individ ual who you put directly in charge of performing maintenance hold an airman certificate.

Section 121.371 requires that any individual that you authorize to perform Required Inspection Items (RII) for you hold an appropriate airman certificate. Section 121.709 requires that anyone who you authorize to issue an approval for return to service hold an appropriate airman’s certificate. Your Director of Maintenance (DOM) and chief inspector must hold an airman’s certificate with Airframe and Powerplant (A&P) ratings.

NOTE: The certificate requirements contained in the regulations stated above are dir ected at the air carrie r. The certificated airman acting in this position does not exercise the authority or privileges of his or her certificate.

(2) You accomplish all maintenance and approval for return to service on your aircraft under your air carrier certificate by your maintenance organizatio n or persons authorized by you, not by any individ ual or organizatio n under their own individual certificate. There is, however, one exception to the individual airman certificate requirement. It occurs if you arrange for a certificated repair station (CRS) located outside the United States to perform maintenance. At such repair stations, individuals directly in charge of performing maintenance or required inspections are not required to hold an FAA airman certificate.

5-2. MAJOR REPAIRS AND ALTERATIONS. Under §§ 121.379(b) and 135.437(b), major repairs and alterations must be done in accordance with technical data approved by the FAA.

Title 14 CFR, part 43, appendix A, contains a list of repairs and alterations that are considered to be major. However, exclusive reliance on the part 43, appendix A, list of major repairs and alterations to make the major/minor classification might result in the misclass if ica t io n of some repairs and alterations because the part 43, appendix A, list does not include evolving airplane design and constructio n techniques, such as composite structures and the high-speed, high-altitude pressurized jet transport. You should have detailed major/minor classification procedures in your manual to evaluate each repair or alteration on a case-by-case basis, using such factors as the certification basis of the aircraft; classification of the structure as primary, secondary, or a primary structural element; or classification as a fail-safe, safe- life, or damage-tolerant structure.

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5-3. AIRWORTHINESS RELEASE FORM OR AIRCRAFT LOG ENTRY AND APPROVAL FOR RETURN TO SERVICE. After performing any maintenance, preventive maintenance, or alterations on your airplane, you must approve it for return to service before you may operate it. As an air carrier, you must issue an approval for return to service under § 121.709 or § 135.443, as appropriate. You can read additional, more detailed information about the process for approving your airplanes for return to service in Chapter 8.

5-4. SCOPE OF MAINTENANCE. You must provide instructio ns in your maintenance program and maintenance manual for maintenance and alterations. These instructions should address the areas of what to do, when to do it, how to do it, and whether it was done properly.

The three major areas to consider are scheduled maintenance, unscheduled maintenance, and specific maintenance requirements for major components of the aircraft.

a. Scheduled Maintenance. Scheduled maintenance consists of all the individual maintenance tasks performed according to the maintenance time limitations, also called a mainte nance schedule. Your scheduled maintenance activities should include procedural instructions for the maintenance tasks and procedures for recording the results of the inspectio ns, checks, tests, and other maintenance. Your procedures should also provide for time-related activities such as recurring Airworthine ss Directive s (AD), Certification Maintenance Requireme nts (CMR), and life-limited parts retirement.

b. Unscheduled Maintenance. Unscheduled maintenance includes procedures, instructions, and standards for maintenance that occurs on an unscheduled or unforeseen basis. A need for unscheduled maintenance may result from scheduled maintenance tasks, pilot reports, or unforeseen events, such as high-load events, hard or overweight landings, tail strikes, ground damage, lightning strikes, or an engine over-temperature. In your maintenance manual, you should include instructio ns and standards for accomplishing and recording unscheduled maintenance.

c. Specific Maintenance Requirements for Major Aircraft Components.

(1) Engine Maintenance Program. Your engine maintenance program should cover the maintenance of installed engines and off-wing engines for each engine model you operate. If your aircraft has auxiliary power units (APU), you may want to include APU maintenance as part of your engine maintenance program. Usually, the installed engine or APU requirements will be contained in the mainte nance schedule. In addition to procedural information, the off-wing program described in your maintenance manual should provide shop scheduling infor mat io n or interva ls for cleaning, adjusting, inspecting, testing, and lubricating each part of the engine or APU. You should include in your maintenance manual the degree of inspectio n, the applicable wear tolerances, and the work required when the engine or APU is in the shop.

(2) Propeller Maintenance Program. If applicable, your propeller maintenance program should cover the maintenance of installed propellers and off-wing propellers for each model you operate. Usually, the installed propeller system scheduled maintenance requirements will be contained in the maintenance schedule. In addition to procedural information, the off-wing program described in your manual should provide shop scheduling information or interva ls for cleaning, inspecting, adjusting, testing, and lubricating each part of the propeller Par 5-3 Page 16

system requiring that maintenance. You should include in your maintenance manual the degree of inspection, the applicable wear tolerances, and the work required at these periods. Some modern propellers are constructed of composite materials and, therefore, may require unique tools, repair procedures, and specialized training for your maintenance personnel.

5-5. PARTS AND APPLIANCES MAINTENANCE PROGRAM. For the most part, this section of your maintenance program covers shop operations, which may include both scheduled and unscheduled tasks. You may conduct these shop operations at some location other than where you perform maintenance on your aircraft. Your parts and appliance maintenance program should cover both installed parts and appliances, and off-wing maintenance for each part and appliance model that you operate. Usually, the scheduled maintenance requirements for installed parts and appliances will be contained in the maintenance schedule. In addition to procedural informatio n, the off-wing program described in your maintenance manual should provide shop scheduling informatio n or intervals for cleaning, adjusting, inspecting, testing, and lubricating each component of the part and appliance requiring that maintenance. Include in your maintenance manual the degree of inspection, the applicable wear tolerances, and the work required when the part or appliance is in the shop.

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CHAPTER 6. MAINTENANCE SCHEDULE

6-1. THE MAINTENANCE SCHEDULE. Title 14 CFR part 119, § 119.49 and part 121, § 121.135(b) require you to have maintenance time limitations, also called a maintenance schedule. These same rules permit you to use standards for determining your maintena nc e time limita t io ns, which are the regulatory basis of FAA-approved reliability programs. The maintenance time limitatio ns set out the what, how, and when of your scheduled maintenance effort. Although in the past the schedule includ ed only basic overhaul limits and other general requirements, today it includes a specific list of each individual maintenance task and its associated interval. The regulations are broad enough to permit you to organize all of these individual tasks into a series of integrated scheduled work packages of your own design that provide a continuous succession of necessary or desirable scheduled maintenance tasks for your entire airplane.

NOTE: You should not confuse the meaning of the terms “instructions for continued airworthiness” (ICA), required by 14 CFR part 25, § 25.1529, “time limitations” (maintenance schedule), required by § 121.135(b)(18), and “airworthiness limitations” (AL) required by part 25, appendix H, § H25.4.

Although related, each term has a significant meaning within the context of the stated part and section of the regulation.

6-2. THE FAA’s ROLE IN RELATION TO THE MAINTENANCE SCHEDULE. The FAA authorizes your maintenance schedule through your operations specifications (OpSpecs), and your Continuing Analysis and Surveillance System (CASS) monitors that schedule to verify its effectiveness (i.e., producing the desired results). Your CASS will be your principal source of informatio n that might indicate a needed change to your maintenance schedule. (We describe the CASS in Chapter 11 and in much more detail in the current edition of AC 120-79, Developing and Impleme nt i ng an Air Carrier Continuing Analysis and Surveillance System.) We expect you to correct any deficiencies in your maintenance schedule. Under § 121.373(b) and 14 CFR part 135, § 135.431(b), if you do not make needed changes, we can require you to change your maintenance schedule or any other element of your maintenance program found deficient.

6-3. MAINTENANCE SCHEDULE CONTENTS.

a. Maintenance Schedule Should Contain the Following Information:

(1) What (Unique Identifier). This is the item that you are going to maintain. Your identifier should be specific enough to allow the individ ual that you assign to do the scheduled maintenance task to easily and accurately identify the item. The following are examples of items that an operator’s maintenance schedule may include:

• Airworthiness Directives (AD),

• Service Bulletins (SB)/Service Letters (SL),

• Replacement of life-limited items,

• Replacement of components for periodic overhaul or repair,

• Special inspections,

• Checks or tests, Par 6-1 Page 19

• Lubricatio n and servicing,

• Tasks identified in the Maintenance Review Board Report (MRBR),

• ALs,

• Certification Maintenance Requirements (CMR),

• Supplement a l Structural Inspection Documents (SSID), and

• Electrical wiring interconnection system (EWIS).

(2) How (Task). This is how you should maintain the item you are going to maintain, or the scheduled maintenance task you will perform. A scheduled maintenance task is a maintenance action that you perform at regular, scheduled intervals. The intent of this task is to ensure the item can continue to perform its intended functio n, allows you to discover a hidden failure, or to ensure that a hidden function is available. You should not use terms such as “hard-time (HT),” “on-condit io n,” or “conditio n monitored” in your maintenance schedule. The maintenance schedule should state the maintenance task to be performed to meet the requirement

(e.g., Replace, Inspect, and Test).

(3) When (Timing). You should accomplish scheduled maintenance tasks (one-time or repetitive) at an acceptable time in service. You may measure time in service in calendar-time, operational hours, flight cycles, or any other appropriate parameter.

b. Maintenance Schedule Objective. Your overall maintenance schedule objective is to do the correct tasks at the correct interval. Keep in mind that more maintenance is not always a good idea, so if you decide to decrease intervals or add tasks, you should go through the same justification process as any other change to the maintenance schedule.

c. Maintenance Schedule Best Pr actice. For task management, invento ry, and audit purposes, you should identify on the maintenance schedule the task or work card associated with each scheduled maintenance task. This way you can ensure that you accomplish all of your scheduled maintenance tasks according to your schedule.

6-4. STANDARDS FOR DETERMINING MAINTENANCE SCHEDULES. As we mentioned in paragraph 6-1, §§ 119.49 and 121.135 permit you to have standards for determining your maintena nc e time limita t io ns. In the past, we used this language as the regulatory basis for FAA-approved reliability programs that evolved during the 1960s. These programs were based on the Air Transport Association of America’s (ATA) now obsolete process-based Maintenance Steering Group—2nd Task Force (MSG-2) decision logic that focused on failure rates and maintaining individual parts of the aircraft. Consistent with the continuo us evolutio n of aviatio n, MSG–2 became obsolete in 1980 with the advent of the ATA’s task-based Maintenance Steering Group—3rd Task Force (MSG-3) decision logic. MSG-3 focused on aircraft systems and a loss of functio n rather than on an individ ua l part failure. In any case, the management of these MSG-2 process-based programs was actuarial analysis.

Air carriers used the failure rates of a part to determine, through a probability process, the likelihood that the part would have a similar failure rate in the future. The standard was the acceptable failure rate. Air carriers used a failure rate alert program with upper control limits (UCL) and lower control limits (LCL) to track part failure rates. The air carrier was obliged to take action only when the failure rate deviated from the probability-based prediction Par 6-3 Page 20