Advisory U.S. Department of Transportation Federal Aviation Circular Administration Subject: Air Carrier Maintenance Programs Date: 1/4/16 AC No: 120-16G Initiated by: AFS-300 Change:
This advisory circular (AC) explains what the term “maintenance program” means. Our explanation describes the scope and content of air carrier aircraft maintenance programs. This is important as there is a significant difference between an air carrier maintenance program and an inspectio n program used in non-air carrier maintenance operations. We explain the background of these programs as well as the Federal Aviation Administration’s (FAA) regulatory requirements. We also describe and explain each of the 10 elements of air carrier maintenance programs. When we use “must” or “will” in this AC, we are referencing actual regulatory requirements. When we use “we,” “us,” or “our” in this AC, we mean the FAA. When we use “you,” “your,” or “yours,” we mean you, the air carrier. When we use the term “person,” it has the same meaning as that in Title 14 of the Code of Federal Regulations (14 CFR) part 1, § 1.1.
This AC is one method of compliance with the requirements of the regulations. Instead of following this method, you may elect to follow an alternate method, provided that your method is acceptable to us. Because the method of compliance that we present in this AC is not mandatory, the term “should” applies only if you choose to follow this particular method without deviatio n. You should tailor your maintenance program to your specific operation; therefore, we are not providing a single means of compliance that applies to all operators required to have a maintenance program. We have included informatio n in this AC about our expectations regarding your implementatio n of an air carrier maintenance program. We based these expectations on our regulatio ns. As required by 14 CFR part 121, § 121.367 and part 135, § 135.425, your maintenance program must ensure that each of your aircraft released to service is Airworthy and properly maintained for operations in air transportation; that you provide competent personnel, adequate facilities, and equipment; and that everyone who works on your aircraft follows your manual and your program.
In addition to strict complia nce with parts 121 and 135 regulations, we encourage you to consider additional processes and methodologies for use in your maintenance program, such as industry best practices, or other government guidance relevant to maintenance, preventive maintenance, and alteration activities.
ORIGINAL SIGNED by /s/ J ohn S. Duncan Director, Flight Standards Service
CONTENTS
Paragraph Page
CHAPTER 1. GEN ERAL INFORMATION1
1-1. Purpose1
1-2. Cancellation1
1-3. Aud ience1
1-4. Legal Basis for Air Carrier Maintenance Program s1
1-5. Maintenance Program Authorization3
1-6. Air Car r ie rMaintenance Program Objectives3
1-7. Air Car r ie r Maintenance Program Elem ents4
CHAPTER 2. AIRWORTHINESS RESPONSIBILITY5
2-1. Responsibility for Aircraft Maintenance5
2-2. Differences Between Programs5
Table 2-1. Maintenance Program and Inspecti on Program Differences5
CHAPTER 3. AIR CARRIER MAINTENANCE MANUAL7
3-1. Air Car r ie r Maintenance Manual Requirem ent7
3-2. Rol e of You r Air Carrier Maintenance Manual7
3-3. Major Sections of the TypicalAir Ca rr ie rMaintenance Manual7
CHAPTER 4. AIR CARRIER MAINTENANCE ORGANIZATION11
4-1. Maintenance Organiz ati on—General11
4-2. Req uired Maintenance Organizatio n Management Po sitio ns11
4-3. Required Air Carrier Maintenance Organizatio nal Structure11
4-4. Separation of Inspectio n and Maintenance Departments12
Figure 4-1. Maintenance Organiz ati onal Chart14
CHAPTER 5. ACCOMPLISHMENT AND APPROVAL OF MAINTENANCE AND
ALTERATIONS15
5-1. Accomplishment of Maintenance15
5-2. Major Repairs and Alterations15
5-3. Airworthiness Release Form or Aircraft Log Entry and Approval for Return to
Service16
5-4. Scope of Maintenance16
5-5. Parts and Appliances Maintenance Program17
CHAPTER 6. MAINTENANCE SCHEDULE19
6-1. The Maintenance Schedul e19
6-2. The FAA’s Ro le in Re la t ion to the Maintenance Sched ule19
6-3. Maintenance Sched ule Co ntents19
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CONTENTS (Continued) Paragraph Page
6-4. Standards for Determining Maintenance Schedules20
CHAPTER 7. REQ UIRED INSPEC TION ITEMS23
7-1. R equired Inspection Items (RII)23
Figure 7-1. Required Inspection Items24
7-2. RII Procedures, Standards, and Limits25
CHAPTER 8. MAINTENANCE RECORDK EEPING SYSTEM27
8-1. Reasons for Making and Keeping Maintenance Records27
8-2. Part 43 Requirements27
8-3. Work Performed by a Part 145 Certificated Repair Station (CRS)27
8-4. Air Car r ie rMaintenance Recordkeeping28
8-5. Mak ingand Keeping Required Records28
8-6. Required Air Carrier Maintenance Records28
8-7. When to Make Records Available to the FAA28
8-8. Responsibility for Making Records Available to the FAA29
8-9. Required Records29
8-10. Other Required Records and Reports31
8-11. Requirements for Reports of Major Alterations and Major Repairs34
8-12. Requirements for Historical or Source Records34
CHAPTER 9. CONTRACT MAIN TEN ANCE37
9-1. Contract Maintenance37
9-2. Responsibility for Maintenance Performed by Others39
9-3. Unscheduled Contract Maintenance Performed Away from Regular Facil ities39
9-4. Airworthiness Release Form or Aircraft Log Entry39
9-5. Evaluating New Maintenance Providers40
9-6. Continuing M aintenance Provi der Oversight41
9-7. Using a Certificated Repair Station (CRS) as O ne o f Yo ur Maintenance Provi ders41
CHAPTER 10. PERSONNEL TRAINING43
10-1. Maintenance Program Training Requi rem ents43
10-2. Types of Training43
10-3. Initial Training43
10-4. Recurrent Training43
10-5. Specialized Training44
10-6. Maintenance Provider Training44
10-7. Com petency-Based Training44
Page iv
CONTENTS (Continued) Paragraph Page
CHAPTER 11. CONTINUING ANALYSIS AND SURVEILLANCE SYSTEM47
11-1. Back gro und o f the Continuing Analysis and Surveillance System (CASS)47
11-2. CASS is a Saf ety Management Tool47
11-3. Basic CASS Processes47
11-4. Risk-Based Deci sions49
11-5. Scope of a CASS49
11-6. CASS Design Principles49
11-7. CASS Personnel Requirements50
CHAPTER 12. ADMINISTRATIVE51
12-1. Whom to Contact51
12-2. Regul atory Ref erences51
12-3. Other Related Regulations and Guidance Material51
12-4. Obtaining Ref erence Material(current ed itio ns)52
Page v (and vi)
CHAPTER 1. GENERAL INFORMATION
1-1. PURPOSE. In this advisory circular (AC), we describe the 10 elements that comprise air carrier maintenance programs and what you should include in your air carrier maintenance program. Consistent with regulations, inspectio n functio ns are an inherent and integral part of your maintenance program; they are not separate. Your maintenance manual is the part of your air carrier manual that describes your maintenance program.
1-2. CANCELLATION. This AC cancels AC 120-16F, Air Carrier Maintenance Programs, dated November 15, 2012.
1-3. AUDIENCE. This AC applies to you if you are a Title 14 of the Code of Federal Regulatio ns (14 CFR) part 119 air carrier conducting operations under 14 CFR parts 121 and/or 135. For part 135 operations, this AC applies only to those maintenance operations conducted under part 135, §§ 135.411(a)(2), 135.411(b), and 135.411(d). This AC also applies to each person employed or used by an air carrier for any maintenance, preventive maintenance, or alteration of its aircraft. We have defined the meaning of “person” in 14 CFR part 1, § 1.1 as “an individual, firm, partnership, corporation, company, association, joint-stock association, or governmental entity. ” This regulatory meaning of “person” includes a trustee, receiver, assignee, or similar representative of any of them. Whenever we say “person” in this AC, we mean the same as that in § 1.1.
1-4. LEGAL BASIS FOR AIR CARRIER MAINTENANCE PROGRAMS.
a. Title 49 of the United States Code (49 U.S.C.). Title 49 U.S.C. § 44701 is the primary authorit y for all air carrier Federal aviation regulat io ns. Title 49 U.S.C. § 44701 instructs us to promote the safe flight of civil aircraft in air commerce by prescribing regulations and standards in the interest of safety.
b. Air Comme rce . When prescribing regulations and standards, 49 U.S.C. § 44701 also obliges us to consider your duty to provide service with the highest possible degree of safety in the public interest, to consider differences between air transportation and other air commerce, and to classify a regulation or standard appropriate to the differences between air transportation and other air commerce. Congress has defined the term “air commerce” within 49 U.S.C. § 40102 as “foreign air commerce, interstate air commerce, the transportation of mail by aircraft, the operation of aircraft within the limits of a Federal airway, or the operation of aircraft that directly affects, or may endanger safety in, foreign or interstate air commerce.”
Simply stated, operations in air commerce are almost everything but operations in air transportation.
c. Regulations. Consistent with the requirements of 49 U.S.C. § 44701, we regulate aircraft operations at different levels of safety. Hence, we have prescribed those regulations that govern air carrier operations (air transportation) and the operations of other air commerce with a different structure to reflect the differences between these two segments of the aviation industry.
Establishing appropriate standards and regulatory requirements is a risk management process (RMP), and the underlyin g legal structure provides for more than one level of acceptable risk appropriate to different types of flight operations. We have written air transportation regulations Par 1-1 Page 1
to be all-inclusive and stand-alone, whereas the regulations governing other air commerce are not. Similarly, we wrote the scope of responsibility for those in air transportation operations to be very broad and not shared, whereas in other air commerce we wrote the scope of responsibility to be relatively narrow and commonly shared. The regulatio ns in parts 119, 121, and 135 relate directly to air carrier maintenance programs, and reflect the highest possible degree of safety in the public interest. The regulations in 14 CFR parts 43, 65, 91, and 145 do not necessarily reflect the highest possible degree of safety in the public interest. We have included more specific references to relevant regulations in subsequent paragraphs.
d. Pe rformance-based Regul ations. We wrote almost all of the maintenance regulations in parts 121 and 135 in a performance-based format. We used the performance-based regulatory approach because it focuses on measurable outcomes, rather than on prescriptive processes, techniques, or procedures. Performance-based regulation leads to defined results without a specific direction or specific instruction in the regulation regarding how to obtain those results.
This approach permits our regulations to apply to a wide variety of certificate holders and still have the same standards. For example, our perfor mance-based regulations in part 121, § 121.367 and § 135.425 apply equally to the 1-airplane operator and the 900-airplane operator. The defined result is always the same: an Airworthy airplane that the operator has properly maintained for operations in air transportation. Performance-based regulation also permits the regulatio n to remain current in the face of advances in technology or methodology.
e. Acceptable Means of Com pliance (AMC). The other half of writing performance-based regulation is to explain what constitutes an AMC. We wrote this AC to show you what acceptable methods of compliance with the performance-based maintenance program regulatory requirements are. In this AC, we have described processes, techniques, and procedures that will lead to the defined results in the maintenance regulations. None of the informatio n in this AC is mandatory or constitutes a regulatio n. We have not included any material in this AC that imposes, reduces, or changes a regulatory burden on anyone. If you use the method of compliance presented in this AC, the term “should” used herein applies only if you choose to follow these particular methods. You should tailor your maintenance program to your particular and specific operation; therefore, we cannot provide a single means of compliance that applies to all certificate holders required to develop and implement an air carrier maintenance program.
f. Continuous Airworthiness Program (CAP). The Federal Aviation Adminis trat io n (FAA) introduced the CAP in a fina l rule at 29 Federal Register (FR) 6522 on May 20, 1964. Since then, the CAP has become known, in a colloquial sense, as a Continuo us Airworthiness Maintenance Program (CAMP). This 1964 rulemaking was our response to safety concerns, and discoveries of weaknesses in the maintenance programs of some air carriers that we found during accident investigatio ns and surveillance of operator maintenance activities. We designed the air carrier CAP to strengthen requirements for air carrier safety management activities. Each one of the air carrier maintenance program elements that we describe in this AC were a part of that 1964 rulemaking.
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1-5. MAINTENANCE PROGRAM AUTHORIZ ATION. We do not approve your CAMP.
There is no regulation that requires an approval. However, we do issue air carrier operations specifications (OpSpecs) to you that authorize you to use a maintenance program and the air carrier maintenance manual required by FAA regulatio ns. This method for authorizing operations and maintenance in air transportation evolved from the Civil Aeronautics Board’s (CAB) earlier method of issuing operating certificates and temporary permits accompanied by competency letters issued by the Secretary of Commerce. These competency letters contained informatio n that authorized the air carrier’s services, routes, aircraft, maintenance, airmen, and weather procedures; they were part of your air carrier operating certificate. We, or you, could amend them as the circumstances dictated. In 1953, we amended the Civil Air Regulatio ns (CAR) to require the issuance of air carrier OpSpecs that replaced, formalized, and standardized the competency letters that we used at the time. We also amended the regulations to state that OpSpecs were not part of your air carrier certificate. Tailored to your specific operating context and the requirements of your individ ual operations, we use OpSpecs to convey the general terms of regulations into specific terms, conditions, and limitations. As with the predecessor competency letters, OpSpecs are amended as circumstances dictate. Issued by us, the terms, conditions, and limitations contained in OpSpecs are made mandatory through specific regulatory language. (Refer to part 119, § 119.5 for the applicable language.)
1-6. AIR CARRIER MAINTENANCE PROGRAM OBJECTIVES.
a. Program Objectives. Your maintenance program must ensure that three specific program objectives are achieved in order to provide the highest possible level of safety in air transportation:
(1) Each of your aircraft that you release to service must be Airworthy and properly maintained for operations in air transportation;
(2) You, or any other person, perform all of the maintenance and alterations on your aircraft in accordance with your maintenance manual; and
(3) You, or any other person, provide competent personnel, and adequate facilities and equipment to perform maintenance and alterations on your aircraft.
b. Continuing Analysis and Surveillance System (CASS). Your maintenance program should also have a system of continuing surveillance, investigatio n, data collectio n, analysis, corrective action, and corrective action followup that ensures all parts of your maintenance program are effective and are being performed in accordance with your manual. “Effective” means that you are achieving the desired results according to the maintenance program objectives and the standards that you, the air carrier, set. Program performance means that all personnel are following your program as you have documented it in your manual.
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1-7. AIR CARRIER MAINTENANCE PROGRAM ELEMENTS. We explain each of these elements individ ua l ly. However, if another AC exists that provides more detailed information about one or more of the maintenance program elements, we will not explain that element in depth. Your air carrier mainte na nce program include s the following 10 elements:
• Airworthiness responsibility,
• Air carrier maintenance manual,
• Air carrier maintenance organizatio n,
• Accomplishment and approval of maintenance and alterations,
• Maintenance schedule,
• Required Inspection Items (RII),
• Maintenance recordkeeping system,
• Contract maintenance,
• Personnel training, and
• CASS.
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CHAPTER 2. AIRWORTHINESS RESPONSIBILITY
2-1. RESPONSIBILITY FOR AIRCRAFT MAINTENANCE.
a. Part 119 Certificate Holder Responsibilities. Consistent with 14 CFR part 121, § 121.363 and part 135, § 135.413, you, as a 14 CFR part 119 certificate holder, are primarily responsible for the airworthiness of your aircraft, and the performance of all maintenance or alterations on your aircraft. Your air carrier certificate makes you a maintenance entity. Under your air carrier certificate, you accomplish your own maintenance, preventive maintenance, or alterations, or you can use other persons who are not direct employees to accomplish that work.
Consistent with our regulatio ns in §§ 121.1(b) and 135.1(a)(2), the part 121 or 135 regulat io ns govern each person that you use or that you employ for any maintenance, preventive maintenance, or alteratio n of your aircraft. Each of these persons that you use must be under your direction and control, and must follow your maintenance program.
b. Maintenance Responsibilities. For any work done on your aircraft, you retain direct and primary responsibility for performing and approving all maintenance and alterations, whether you accomplish that work or whether someone else does it for you, such as a repair station. However, you always retain primary responsibility for the performance and approval of the maintenance done by that maintenance provider (MP).
2-2. DIFFERENCES BETWEEN PROGRAMS. The following table provides a comparison of the differences between air carrier maintenance programs and 14 CFR part 91 General Aviation (GA) inspectio n programs.
TABLE 2-1. MAINTENANCE PROGRAM AND INSPECTION PROGRAM
DIFFERENCES NOTE: The wording in part 91 is deliberately different from the wording in 14 CFR parts 121 and 135, and is consistent with the difference between air transportation and other air commerce described in 49 U.S.C. § 44701.
Elem ent Part 121 and 135 Air Carrie rs Part 91 Owne rs/Ope rato rs Use of a maintenance or an inspectio n program.
Required to use a maintenance program for its aircraft.
Required to use an inspection program.
Responsibilities within the relevant program.
Responsible for the performance of maintenance in accordance with its maintena nce program and manual, as well as the airworthiness of its aircraft, including airframes, aircraft engines, propellers, appliances, and parts thereof.
Responsible for maintaining the aircraft in an Airworthy conditio n (14 CFR part 91, § 91.403).
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Responsibilities within the relevant program.
Responsible for the development and use of the maintenance program and manual;
determining the method of performing maintenance; a required inspectio n list; a Continuo us Analysis and Surveillance System (CASS); a maintenance organizatio n that can exercise operational control over maintenance operations;
and other items that collectively and systematically serve to ensure each aircraft has been properly mainta ined for operations in air transportation and is Airworthy.
Responsible for the selection of an existing inspection program and the scheduling of aircraft for the inspectio ns, and for ensuring that discrepancies that occur between scheduled inspections are repaired.
Must determine what maintenance is required, how to do it, when to do it, perform that maintenance, and approve its own aircraft for return to service.
May authorize another person to accomplish the maintenance work, but the maintenance must be carried out according to the air carrier’s maintenance program and manual. The air carrier still retains the responsibility for the proper completio n of mainte na nce (part 121, § 121.363 or part 135, § 135.413).
Must make the airplane available to authorized and certificated person(s) who accomplish inspections and other maintenance.
Along with FAA oversight, is the primary authority with regard to its maintenance program.
Holds the primary responsibility for the performance of maintenance in accordance with its maintenance program and manual, as well as the airworthiness of its aircraft, including airframes, aircraft engines, propellers, appliances, and parts thereof.
The authorized and certificated person(s) has the responsibility to perform the maintenance properly in accordance with the manufacturer’s manual and to approve the aircraft for return to service. The owner/operator does not have this responsibility.
However, the owner/operator is responsible for ensuring maintenance personnel make appropriate entries in the aircraft maintenance records indicating the aircraft has received approval for return to service.
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