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.

Show pages 1–11

CHAPTER 3. MAINTENANCE MANUAL

300. Is an air carrier maintenance manual required?

You are required by FAA’s regulations to have a maintenance manual and to include it in your system of manuals. Your manual must be easy to revise and you must have procedures for keeping all parts of your manual up-to-date. Some air carriers call their manual “specifications.”

Copies of your manual or appropriate portions (and changes or additions) must be made available to those persons who are required to comply with it. You must also provide a copy to the representatives of the Administrator assigned to you. Each person who is furnished a manual must keep it up-to-date.

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

Your maintenance program manual is key to standardized, consistent accomplishment and administration of your maintenance program. It is a required part of your air carrier manual system. The manual identifies, describes, and defines your maintenance program. It also provides instructions and procedures to administer, use, manage, and amend your program.

Your manual is a company publication and you have sole responsibility for its organization and content, including technical content. However, others may compile and publish it. The manual may be electronic.

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

Your manual should be organized in a practical arrangement. It should have at least three or more sections such as administrative policies and procedures; detailed instructions for the administration, management, and accomplishment of the maintenance program; and technical manuals that describe maintenance standards, methods, techniques, and procedures.

1. Administrative policies and procedures.

This section deals with policies and procedures for the administration and amendment of your maintenance program. It is used as a management and administrative tool for organizing, directing, and controlling the maintenance program. Organizational charts delineating the functions, interrelationships, and lines of authority between organizational elements and personnel are normally identified here. For clarity, you may choose to identify the interrelationship between production and inspection functions in a separate inspection manual.

2. Detailed instructions for the administration, management, and accomplishment of the maintenance program.

This section contains detailed instructions for the management of the various functions and interrelationships of each maintenance program element such as maintenance time limitations, recordkeeping, maintenance program management and oversight, contract maintenance management and oversight, and personnel training. A description of scheduled maintenance tasks and procedural information and detailed instructions (or specific air carrier maintenance Par 300 Page 5

manual references) for accomplishing maintenance tasks is normally included in this section.

Additionally, you should describe criteria for initiation of functional evaluation flights in this part of the manual, along with procedural requirements for these flights. This portion of the manual may also include criteria and procedural information for unscheduled inspections such as those associated with lightning strikes, tail strikes, engine temperature exceedances, hazardous material spills, and hard or overweight landings.

3. Technical manuals that describe maintenance standards, methods, techniques, and procedures.

The technical manual section concerns detailed procedures for the accomplishment of specific tasks. You should describe methods, techniques, technical standards, measurements, calibration standards, operational tests, structural repairs, etc. in this portion of the manual. You should also include procedures for aircraft weight and balance, jacking and shoring, storage, cold weather operations, towing, aircraft taxi, aircraft cleaning, jacking, lifting, and shoring. You can derive your technical manual contents from the manufacturer’s publications; however, based on your particular service experience, organization, and operating context, the FAA expects that your manual is continuously modified and customized as necessary for the continuing success of your maintenance program. Accordingly, your air carrier technical manual will not be the same as the manufacturer’s manual.

4. Work cards.

Work cards, while not a regulatory requirement, have evolved as a “best practice.” Work cards are considered part of the air carrier maintenance manual and the air carrier maintenance program. They are used as an uncomplicated means of compliance with regulations for performance of maintenance as well as maintenance recordkeeping. Work cards normally serve two primary functions. The first is to provide detailed, concise procedural instructions that serve to organize and control the maintenance activity, while providing a means to ensure the maintenance activity complies with the air carrier manual. The second primary function is to document the maintenance activity, providing a means to comply with the air carrier maintenance recordkeeping requirements. A secondary function is to document the results of inspections, checks, and tests for data collection and analysis.

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CHAPTER 4. MAINTENANCE ORGANIZATION

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

You, as an air carrier, are required to have a maintenance organization that is 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. You are required to include a chart or a description of your maintenance organization in your manual.

You can read about all of the maintenance organization requirements in subpart L of part 121, subpart J of part 135, and portions of subpart C of part 119. These organizational regulations apply to your organization as well as any other organization that provides maintenance services for you.

NOTE: For the purposes of discussion in this AC, “authority” means the power to design or change fundamental policy or procedures without having to seek a higher-level management approval. Additionally, “responsibility” means the obligation, along with the requisite accountability, to ensure that a task or function is successfully carried out.

Together, these regulations require your maintenance organization to:

/g183/g32 Have an organization that can do the required maintenance;

/g183/g32 Have a Director of Maintenance (DOM);

/g183/g32 Have a Chief Inspector (part 121 only);

/g183/g32 Prepare and keep current a manual for the use and guidance of personnel accomplishing maintenance on your aircraft;

/g183/g32 Ensure your maintenance is accomplished in accordance with your manual;

/g183/g32 Organize the accomplishment of your required inspection function separate from the accomplishment of your other inspection, maintenance, and alteration functions;

/g183/g32 Ensure competent personnel and adequate facilities and equipment are provided for your maintenance;

/g183/g32 Ensure that each airplane released for service after maintenance is airworthy and has been properly maintained for operations in air transportation;

/g183/g32 Ensure that your maintenance program remains effective; and /g183/g32 Ensure that persons exercising management oversight and control, particularly revision control, over the content, organization, and performance of your maintenance program are qualified and have practical experience and demonstrated technical and managerial capabilities to effectively organize, manage, and control your maintenance program.

These persons should be able to carry out their duties in a way that will fulfill your responsibility to operate with the highest possible degree of safety.

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

FAA’s regulations include specific requirements for maintenance organization management positions, including a DOM and a Chief Inspector. For part 121, you must have qualified persons serving full-time in these or equivalent positions. If necessary for your operation, you can ask FAA for a deviation from the types and numbers of required management positions. In your manual, you are required to list the names and addresses, and to state the duties, responsibilities, and authority of your required management personnel. Also, you are required to notify the FAA when you make changes in your required management personnel or when you have a vacancy. For part 135 operations, the organizational requirements are the same as part 121, except that a Chief Inspector position is not required.

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

The regulations for an air carrier maintenance organization are necessarily broad, given all the different types and sizes of air carriers. These organizational regulations apply to your organization and to any other organization that provides maintenance services for you. The structure of your maintenance organization should be tailored to your specific size and staffing requirements; therefore, a single means of compliance or a single organizational chart that would apply to all air carrier organizations is not possible. However, in all maintenance organizations, you should designate a single person or position to have the authority and the overall responsibility for managing and implementing your entire maintenance program. The FAA expects you to designate this person as your DOM. You do not have to use the term Director of Maintenance as the position title; however, you should identify the person in your organizational chart as the FAA DOM or use a similar term. Your DOM should incorporate three organizational functions in your air carrier maintenance organization in order to operate efficiently and effectively, and to support flight operations with the highest possible degree of safety. These three organizational functions should be present whether your maintenance organization consists of just one person or a multitude of persons and should be documented in your manual. Although maintenance organizations vary widely in size, scope, and staffing, the requirements of authority and responsibility apply equally to all organizations. The functions are as follows:

/g183/g32 The first level maintenance function is carried out by your mechanics/inspectors and other maintenance personnel. These people do the basic work of your maintenance organization,

i.e., the inspection, overhaul, repair, replacement of parts, preventive maintenance, and alterations of your authorized aircraft.

/g183/g32 The second level maintenance function is carried out by your middle managers such as your maintenance foreman or supervisor, your maintenance manager or supervisor, and/or your Chief Inspector. These people directly supply the resources for the first level maintenance function, and they directly organize, control, and supervise your mechanics/inspectors in the accomplishment of the first level maintenance functions. For smaller organizations,

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particularly in part 135 operations, some or all of these second level functions may be carried out by one or a few individuals on an as-needed basis.

/g183/g32 The third level maintenance function is carried out by your maintenance organization’s accountable manager, whom the FAA expects is your DOM. This person has the authority and overall responsibility for your maintenance program; provides general leadership and financial management; provides vision of the scope, size, and structure of the organization;

sets the general organizational direction and objectives; prepares the organization for the future; and provides the focus on forecasting and planning for shifting needs and new technologies. In most organizations, except for the smallest, it will be common for the person with overall responsibility for maintenance program functions to delegate some or much of this work to others within the maintenance organization. In the smallest maintenance organizations, particularly part 135 operations, your DOM may have responsibility for all three organizational functions.

This work may be accomplished directly by the person that has been delegated responsibility;

however, depending on the size and staffing of the organization, this work may also be delegated. Regardless, the person with specific responsibility has the obligation to carry out the specific function(s) of the maintenance program, including overseeing and managing any personnel to whom maintenance program functions and duties are delegated. The FAA expects to see clear authority and responsibility, including delegated responsibility, for the overall maintenance program and all of its elements and functions. You should include a description of each person’s duties and responsibilities in your manual so that there is not a fragmented organizational system with high risk of confusion over who is responsible for a given task.

403. Is your inspection department required to be organizationally separate from the rest of your maintenance organization?

There is no specific regulatory requirement to keep your inspection department separate from the rest of your maintenance organization. The regulations include inspection as one of the functions of maintenance. Therefore your inspection department, if you choose to have one and your organization is large enough to have one, should be an integral unit of your maintenance organization at the first and second functional levels described above. In larger part 121 maintenance organizations, responsibility for the general inspection function usually resides in an inspection unit and is delegated to your Chief Inspector. In these larger organizations, the other maintenance, preventive maintenance, and alteration functions reside in a maintenance unit or units that are a counterpart to the inspection unit. You should organize these maintenance unit(s) at the same organizational level as your inspection unit, with a supervisor/manager at the same level as your Chief Inspector. In part 135 operations, where FAA’s regulations do not require you to have a Chief Inspector, the DOM may or may not delegate the inspection function to another person. It is important to note that the general inspection function described in this section and elsewhere in this AC is not the required inspection function described in paragraph 404 and Chapter 7.

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

There is a specific regulatory organizational requirement focusing on the required inspection item (RII) function. This RII organizational requirement is the same for both part 121 and part 135 air carriers. In addition to the discussion here, you may read about RII functional requirements in Chapter 7 of this AC. FAA regulations require you to organize the accomplishment of your RII functions to separate this function from the other maintenance (inspection, overhaul, repair, preservation, and the replacement of parts), preventive maintenance, and alteration functions. This separation must be below the level of administrative control where overall responsibility for the RII function and the other maintenance, preventive maintenance, and alterations reside. In simple terms, this means that the part of your organization that accomplishes your maintenance, preventive maintenance, and alterations cannot be the same part that accomplishes your RII. In larger maintenance organizations, the RII function may be located in an organization whose sole function is RII. In others, RII may reside in an inspection unit that is responsible for the general inspection function. However, to be consistent with the regulations, you must keep the accomplishment of any RII function separate from the accomplishment of any general inspection function. In a smaller organization, particularly a part 135 organization, the RII function may be the responsibility of one or two persons. Because the need for RII may not be a daily occurrence, in most, if not all maintenance organizations, RII is a collateral duty assignment.

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

The DOM has the maintenance function responsibility and is the accountable manager with the authority and overall responsibility for the entire maintenance program and other maintenance, preventive maintenance, and alteration functions. You should place the DOM at the point in your organizational structure where he or she will have the overall responsibility and authority to prescribe your maintenance policy and to organize, direct, and control the overall maintenance program and maintenance organization. Inherent with this overall responsibility and authority, your DOM should be able to commit the corporate resources necessary to carry out maintenance operations with the highest possible degree of safety. Under FAA’s regulations, your DOM must be a currently certificated mechanic with airframe and powerplant ratings. This standard ensures the DOM is knowledgeable about basic safety and regulatory responsibilities inherent with supervising, performing, inspecting, and returning to service air carrier aircraft and components.

All other regulatory requirements for the DOM position are based on that person having a mechanic certificate.

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

The Chief Inspector has the maintenance function responsibility for the required inspection function of the maintenance program. In most organizations, except for the smallest, the Chief Inspector will also have the delegated responsibility for the general inspection function, as well as serving as the focal point for conflict resolution regarding inspection findings. Your Chief Inspector should not be placed at a point in your organizational structure that is below the management person having operational responsibility for the production aspects of your Page 10 Par 404

maintenance, preventive maintenance, and alteration functions. Under FAA’s regulations, the Chief Inspector must be a currently certificated mechanic with airframe and powerplant ratings.

This standard ensures the Chief Inspector is knowledgeable about the inherent responsibilities involved with supervising and inspecting air carrier aircraft and components. All other regulatory requirements for the Chief Inspector position are based on that person having a mechanic certificate.

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

For part 135 operations, FAA’s regulations do not specify a Chief Inspector organizational requirement; however, the regulatory requirements for the required inspection function and responsibility remain and must still be addressed in the air carrier organization. The part 135 DOM has overall responsibility for the entire air carrier maintenance program, including the overall responsibility for the required inspection function.

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CHAPTER 5. MAINTENANCE SCHEDULE

500. What is a maintenance schedule?

FAA regulations require you to have a maintenance schedule called “maintenance time limitations.” The maintenance time limitations set out the what, how, and when of your scheduled maintenance effort. Although in the past the schedule included only basic overhaul limits and other general requirements, today it includes a specific list of each individual maintenance task and its associated time limit. The tasks are usually organized into a series of integrated scheduled work packages that provide a continuous succession of necessary or desirable scheduled maintenance tasks for the entire aircraft.

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

The FAA authorizes and monitors your maintenance schedule. The FAA expects you to make changes to your maintenance schedule in the interest of safety. If you do not, the FAA is authorized to require you to change your maintenance schedule.

502. What are the elements of a maintenance schedule?

An air carrier’s maintenance schedule should contain at least the following information:

1. What (unique identifier): The item to be maintained. The identifier should be specific enough to allow the item to be easily and accurately identified.

2. How (task): The scheduled maintenance task to be done. A scheduled maintenance task is a maintenance action performed at regular, scheduled intervals to ensure the item can continue to perform its intended function within its operating context, or to discover a hidden failure. Terms such as “hard time,” “on-condition,” or “condition monitored” should not be used in the maintenance schedule. These terms are vague, non-specific, and usually do not adequately describe the task to be performed.

3. When (frequency): The maintenance interval is the time-in-service when you must perform the maintenance task. In addition, for task management, inventory, and audit purposes, you should identify the task or work card associated with each scheduled maintenance task.

503. How are integrated scheduled work packages created?

You can simplify administration and control of individual scheduled maintenance tasks by grouping or packaging the tasks into integrated scheduled work packages. The checks or work packages required most frequently are generally packages of short-duration maintenance tasks that do not need specialized equipment or facilities. The more complex work packages, usually identified as letter checks such as “A,” “B,” “C,” and so on, are generally scheduled at successively longer intervals. Some letter checks may be set up to incorporate all of the work covered by the preceding check plus the tasks assigned at that letter check interval. Thus, each successive letter check may require an increased amount of labor, technical skill, and specialized Par 500 Page 13

equipment or facilities. However, it is possible that a letter check may not completely supersede a previous letter check because of the exclusion of certain maintenance tasks.

a. Air carriers have customarily expressed intervals for letter-check packages in operating hours or flight cycles. However, primarily for the convenience and ease of scheduling large fleets of aircraft, you may wish to convert these intervals to stand-alone calendar time intervals based on the average daily usage of the aircraft. You do not need to include hours or cycles in a calendar time interval or the term “whichever comes first.” If you do this conversion, your letter-check packages will include tasks to be performed once a day, once a week, once a month, and so on. In order to use calendar intervals, you should monitor your aircraft utilization to ensure the calendar interval remains valid in relation to average daily usage of the aircraft. This is particularly important when including calendar, cycle, and hourly controlled tasks in a single letter check.

b. Air carrier scheduled major structural airframe inspections have, historically, been known as “D” or “E” checks. These very large, complex work packages have also been designated by other terminology such as “Heavy Maintenance Check,” “Major Maintenance Check,” “Heavy Level Check,” “Special Structural Visit,” and “Airframe Overhaul.” This type of scheduled work package normally consists of a hangar visit or series of visits that are designed to accommodate the accomplishment of major scheduled maintenance tasks.

c. Originally, the “D” or “E” check was the aircraft manufacturer’s recommended inspection interval for major maintenance requirements such as structural inspections, systems operational/functional checks, aircraft modifications, cabin refurbishment, painting, etc.

However, studies of the content of these checks revealed that most of the inspection tasks scheduled for accomplishment during the “D” or “E” check work packages were also listed as requirements in the “C” or multiple “C” work packages. This resulted in a duplication of task requirements. Also considered was that heavy maintenance, modifications, and refurbishment are mostly operator discretionary items that are often scheduled seasonally or in other time periods independent of the scheduled structural inspection program. It was therefore deemed advisable, due to improved efficiency, to redistribute the structural task items to the appropriate interval and eliminate the “D” or E” check terminology altogether.

d. It should also be noted that although manufacturers identified the major structural inspections for older airplanes as “D” or “E” checks, the major structural inspections for newer aircraft are not so identified. In fact, the manufacturer’s recommended structural inspections for one of the newest transport category aircraft are not consolidated into work packages or letter checks at all. The recommendation simply contains a listing of all of the tasks and intervals that are considered critical to airworthiness. Using the listing, you are expected to design work packages that best suit your particular maintenance organization and operating environment.

Moreover, modern air carrier maintenance philosophy does not normally identify a major inspection interval other than a “C” check. In any case, you may design and identify your structural inspection program or integrated work packages as you deem appropriate, consistent with your maintenance policy and the amendments determined by your Continuing Analysis and Surveillance System (CASS).

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e. You may not wish to be faced with an intermittent, heavy workload of “C” and “D” checks, each requiring a large expenditure of labor-hours and taking an airplane out of service for a month or more. Instead, you can distribute appropriate “C” and “D” check tasks among the more frequent letter checks. In this way, aircraft are not subject to lengthy out-of-service times, and the actual scheduled maintenance workload will remain relatively constant, although the actual tasks performed may vary greatly for the same letter check from one time to the next. For example, a task that has a long accomplishment interval but is not time-consuming may be assigned to one of the more frequent letter checks but scheduled only for every second or fourth such check. Conversely, a group of tasks that are especially time-consuming may be distributed among successive letter checks of the same designation, while tasks that are monitored independently may be scheduled for the time of the nearest check regardless of its letter check designation. Consequently, for the same letter check, the actual tasks performed will differ greatly from one scheduled visit of the airplane to the next. Hence, the letter check designation terms “1A,” “3A,” “1B,” “4B,” “1C,” “2C,” “4C,” “8C,” etc.

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