AC 120-16D

Historical

Advisory circular · Air Carrier Maintenance Programs

A newer version is currentThis is a historical version. AC 120-16G is the version in force, approved January 4, 2016.
Approved
March 20, 2003
Last reviewed
August 6, 2024
Cancels
AC120-16C
Cancelled by
AC120-16E
Family
AC 120-16 · 6 versions
Revision
D
14 CFR parts
119, 121, 135

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

AC 120-16D DATE 03/20/03 Initiated by: AFS-300

ADVISORY CIRCULAR

AIR CARRIER MAINTENANCE

PROGRAMS

U.S. DEPARTMENT OF TRANSPORTATION Federal Aviation Administration Flight Standards Service Washington, D.C.

PREFACE

This advisory circular (AC) describes air carrier aircraft maintenance programs. It explains the background as well as the Federal Aviation Administration’s (FAA) regulatory requirements for these programs. Also described are the nine elements of aircraft maintenance programs. As used in this AC, maintenance means “inspection, overhaul, repair, preservation, and the replacement of parts,” as well as preventive maintenance. This material is not regulatory, nor does it establish minimum standards. However, where terms such as “must,” “shall,” and “will” are used in this AC, such use reflects actual regulatory requirements.

/s/ Louis C. Cusimano for James J. Ballough Director, Flight Standards Service

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CONTENTS Page

CHAPTER 1. GENERAL1

100. What is the purpose of this advisory circular?1

101. Who does this AC apply to?1

102. What is the regulatory basis for air carrier maintenance programs?1

103. How does the FAA authorize your maintenance program?1

104. What are the objectives of air carrier maintenance programs?2

105. What are the elements of an air carrier maintenance program?2

CHAPTER 2. AIRWORTHINESS RESPONSIBILITY3

200. Who is responsible for maintenance on your aircraft?3

201. What is the difference between air carrier maintenance programs and general

aviation inspection programs used under part 91?3

CHAPTER 3. MAINTENANCE MANUAL5

300. Is an air carrier maintenance manual required?5

301. What is the role of an air carrier maintenance manual?5

302. What are the major sections of an air carrier maintenance manual?5

CHAPTER 4. MAINTENANCE ORGANIZATION7

400. Is an air carrier maintenance organization required and what does it do?7

401. What are the FAA-required management positions in your maintenance

organization?8

402. Functionally, what air carrier maintenance organizational structure is required?8

403. Is your inspection department required to be organizationally separate from

the rest of your maintenance organization?9

404. What are the organizational requirements for your Required Inspection Items?10

405. What are the requirements for your Director of Maintenance?10

406. What are the requirements for your part 121 Chief Inspector?10

407. What are the requirements for your part 135 Chief Inspector?11

CHAPTER 5. MAINTENANCE SCHEDULE13

500. What is a maintenance schedule?13

501. What is the role of the FAA in your maintenance schedule?13

502. What are the elements of a maintenance schedule?13

503. How are integrated scheduled work packages created?13

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CHAPTER 6. MAINTENANCE RECORDKEEPING SYSTEM17

600. Why do you have to make and keep maintenance records?17

601. Are there penalties for improper air carrier maintenance recordkeeping?17

602. How must you make and keep required maintenance records?17

603. What are the required air carrier maintenance records?17

604. When must these required records be made available to the FAA?18

605. Who must make these required records available to the FAA?18

606. Are there any other required records or reports that you must make and keep?21

607. Are you required to keep historical or source records to support your required

maintenance records?22

CHAPTER 7. ACCOMPLISHMENT AND APPROVAL OF MAINTENANCE AND

ALTERATIONS25

700. What is scheduled maintenance?25

701. What is unscheduled maintenance?25

702. What should your engine maintenance program contain?25

703. What should your propeller maintenance program contain?26

704. What should your parts and appliance maintenance program contain?26

705. What is the Aging Airplane Program?27

706. What are Required Inspection Items?27

707. What are some examples of RIIs?28

CHAPTER 8. CONTRACT MAINTENANCE29

800. What is the extent of your responsibility for maintenance performed by others?29

801. What are the requirements for performing unscheduled maintenance away from

your regular maintenance facilities?29

802. Who has the responsibility for releasing your aircraft as airworthy?29

803. How are new maintenance providers evaluated?30

804. How do you ensure your maintenance provider continues to comply with the

requirements?30

CHAPTER 9. CONTINUING ANALYSIS AND SURVEILLANCE SYSTEM33

900. What are the origins of the Continuing Analysis and Surveillance System?33

901. What is CASS?33

902. What does CASS do?33

903. What part of your air carrier maintenance program does your CASS monitor?34

904. How does CASS work?34

905. What are the principal elements of CASS?34

906. What are the general CASS objectives?35

907. What does the program execution part of your CASS accomplish?35

908. What does the program effectiveness part of your CASS accomplish?37

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CHAPTER 10. PERSONNEL TRAINING39

1000. What are the basic requirements for the training program?39

1001. What are some of the types of training that can be included

in a training program?39

1002. What is initial training and what does it include?39

1003. What is recurrent training and what does it include?39

1004. What is specialized training and what does it include?40

1005. What is maintenance provider training and what does it include?40

1006. What is competence-based training and what does it include?40

CHAPTER 11. HAZARDOUS MATERIALS AND DANGEROUS GOODS41

1100. What should my manual contain about hazardous materials?41

CHAPTER 12. ADMINISTRATIVE MATTERS43

1200. Which advisory circular does this AC cancel?43

1201. What is the regulatory basis of this AC?43

1202. Where can you find regulatory and guidance material related to the

information in this AC?44

1203. Where can you get materials related to the information in this AC?44

Page v (and vi)

CHAPTER 1. GENERAL

100. What is the purpose of this advisory circular?

This advisory circular (AC) describes air carrier aircraft maintenance programs. It explains the background as well as the Federal Aviation Administration’s (FAA) regulatory requirements for these programs. Also described are the nine elements of aircraft maintenance programs. As used in this AC, maintenance means “inspection, overhaul, repair, preservation, and the replacement of parts,” as well as preventive maintenance. This material is not regulatory, nor does it establish minimum standards. However, where terms such as “must,” “shall,” and “will” are used in this AC, such use reflects actual regulatory requirements.

101. Who does this AC apply to?

This AC applies to air carriers subject to Title 14 of the Code of Federal Regulations (14 CFR), parts 119, 121, and 135. For part 135 operations, this AC applies only to operations conducted with aircraft type-certificated for a seating capacity, excluding any pilot seat, of 10 seats or more.

102. What is the regulatory basis for air carrier maintenance programs?

Title 49 of the United States Code (49 U.S.C.) § 44701 (formerly the Federal Aviation Act of 1958, § 604) is the primary authority for all air carrier Federal Aviation Regulations. Title 49 U.S.C. § 44701 tells the FAA Administrator to promote the safe flight of civil aircraft in air commerce through regulations and standards prescribed in the interest of safety. Section 44701 further obliges the Administrator, when prescribing regulations and standards, to: (1) consider the duty of an air carrier to provide service with the highest possible degree of safety in the public interest; (2) consider differences between air transportation and other air commerce; and

(3) classify a regulation or standard appropriate to the differences between air transportation and other air commerce. The term “air commerce” is defined within 49 U.S.C. § 40102 as the operation of an aircraft within the limits of a federal airway. The term “air transportation” is defined within that same section as the transportation of passengers or property by aircraft as a common carrier for compensation.

103. How does the FAA authorize your maintenance program?

FAA issues you air carrier operations specifications (OpSpecs) authorizing you to use a maintenance program and the air carrier maintenance manual required by the FAA’s regulations.

This method for authorizing operations and maintenance in air transportation evolved from the Civil Aeronautics Board’s earlier method of issuing operating certificates and temporary permits accompanied by competency letters issued by the Secretary of Commerce. Containing information that authorized the air carrier’s services, routes, aircraft, maintenance, airmen, and weather procedures, these competency letters were considered part of the air carrier operating certificate and could be amended as the circumstances dictated. However, in 1953, the Civil Air Regulations were amended to require the issuance of air carrier OpSpecs that replaced, formalized, and standardized the competency letters being used at the time. The amended regulations also stated that OpSpecs were not part of an air carrier certificate. Tailored to your Par 100 Page 1

specific operating context and the requirements of your individual operations, OpSpecs convey the general terms of regulations into specific terms, conditions, and limitations. As with the predecessor competency letters, OpSpecs are amended as circumstances dictate. Approved by the FAA, OpSpecs are as legally binding as the regulations themselves.

104. What are the objectives of air carrier maintenance programs?

Your maintenance program assures that all parts of your aircraft can perform their intended function. Your maintenance program should reflect four specific program objectives to provide the highest possible level of safety in air transportation:

a. Each aircraft released to service is airworthy and has been properly maintained for operations in air transportation;

b. Maintenance and alterations you perform, or that other persons perform for you, are performed in accordance with your maintenance manual;

c. Competent personnel with adequate facilities and equipment perform your maintenance and alterations; and

d. You have a system of continuing cycles of surveillance, investigations, data collection, analysis, corrective action, and corrective action monitoring to ensure all parts of your maintenance program are effective and are being performed in accordance with your manual.

105. What are the elements of an air carrier maintenance program?

An air carrier maintenance program includes nine elements. This AC explains each of these elements individually. The nine elements are:

/g183/g32 Airworthiness responsibility /g183/g32 Maintenance manual /g183/g32 Maintenance organization /g183/g32 Maintenance schedule /g183/g32 Maintenance recordkeeping system /g183/g32 Accomplishment and approval of maintenance and alterations /g183/g32 Contract maintenance /g183/g32 Continuing analysis and surveillance system /g183/g32 Personnel training

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CHAPTER 2. AIRWORTHINESS RESPONSIBILITY

200. Who is responsible for maintenance on your aircraft?

As an air carrier, you are responsible for the maintenance of your aircraft. Under FAA’s regulations, you must perform and/or approve all maintenance and alterations on your aircraft.

You may arrange for a maintenance provider, such as a repair station, to perform your maintenance for you. However, you retain responsibility for the performance and approval of that maintenance even if someone else performs the work for you.

201. What is the difference between air carrier maintenance programs and general aviation inspection programs used under part 91?

Parts 121 and 135 require an air carrier to use a maintenance program for its aircraft, while on the other hand, sections of part 91 require operators to use an inspection program. Further, parts 121 and 135 establish the air carrier as responsible for the airworthiness of its aircraft and the performance of maintenance in accordance with its air carrier maintenance program and manual while part 91 establishes the owner or operator as responsible for maintaining the aircraft in an airworthy condition. This is consistent with the “differences” requirement of 49 U.S.C.

§ 44701. Under FAA’s regulations, every air carrier must have a maintenance program. The maintenance program and its elements must be described in detail in a program manual. An air carrier must carry out its maintenance program according to that manual.

The maintenance responsibility of an owner/operator under part 91 is limited to the selection of an existing inspection program, the scheduling of the aircraft for the inspections, and making the airplane available to authorized and certificated person(s) who accomplish the inspections and other maintenance. Under part 91, the properly authorized and certificated persons have the responsibility to perform the maintenance properly in accordance with the manufacturer’s manual and approve the aircraft for return to service, not the owner/operator.

On the other hand, an air carrier has the responsibility to determine the maintenance that is required, to perform that maintenance, and to approve for return to service its own aircraft. The air carrier also has the option to authorize another person to perform the maintenance, but the maintenance must be carried out in accordance with the air carrier’s maintenance program and maintenance manual. The air carrier still retains the responsibility for the proper accomplishment of the maintenance. In addition, an air carrier is responsible for the development and use of its own air carrier maintenance program along with a manual containing the program, the method of performing maintenance, a required inspection item system, a continuous analysis and surveillance system, a description of the maintenance organization, and a number of other things that, collectively and systemically, serve to ensure that each air carrier aircraft is airworthy. An air carrier is, along with FAA oversight, the ultimate authority with regard to its maintenance program and is solely responsible for the airworthiness of its aircraft.

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