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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CHAPTER 6. MAINTENANCE RECORDKEEPING SYSTEM
600. Why do you have to make and keep maintenance records?
Air carrier maintenance records are made and retained to show that the U.S. Standard Airworthiness Certificate is effective and that the aircraft is airworthy. A U.S. Standard Airworthiness Certificate is effective only as long as the maintenance and alterations are performed according to the requirements of the FAA’s regulations. Incomplete or inaccurate required aircraft maintenance records can have the effect of rendering a Standard Airworthiness Certificate ineffective. Maintenance actions, in almost all cases, become intangible or abstract after the fact. Therefore, in order for an aircraft operator to make a maintenance action tangible, a record of that maintenance action must be made. Additionally, making a record of certain summary information supports the current airworthiness status of an aircraft.
601. Are there penalties for improper air carrier maintenance recordkeeping?
Maintenance records are important because the FAA uses its continuing review of aircraft maintenance records as a direct means of ensuring the airworthiness and safety of air carrier aircraft. Because the review of maintenance records is the only direct means of determining the accomplishment of required maintenance, federal law treats the act of intentionally failing to make and keep, as well as the act of intentionally falsifying, mutilating, or altering air carrier aircraft records as a criminal act, subject to the imposition of substantial fines and/or imprisonment.
602. How must you make and keep required maintenance records?
The FAA’s regulations require you to have and use a recordkeeping system for the preparation, storage, and retention of required aircraft maintenance records. You must document your system in your air carrier manual. The primary objective of these systems is the generation, storage, retention, and retrieval of accurate and complete air carrier aircraft maintenance records. As stated earlier, these records are primarily made to show that the U.S. Standard Airworthiness Certificate of your air carrier aircraft is effective, and therefore the aircraft is airworthy and capable of safe flight.
In addition to the summary records and airworthiness release records, your recordkeeping system should have detailed documentation and source requirements and procedures for administrative handling of aircraft components and parts. You must clearly identify these procedures in your recordkeeping system and manual. These source and documentation requirements for parts and components may include, but are not limited to, documentation of Airworthiness Directives (AD) compliance, life-limited parts current status information, description of maintenance performed, and appropriate certification of new and repaired parts.
603. What are the required air carrier maintenance records?
Over the years, FAA’s air carrier aircraft maintenance record making and retention requirements have evolved from the minimal records of repairs and alterations required in the pre WW2 era, to Par 600 Page 17
the current requirements for two types of records: a list of summary information, and air carrier airworthiness release records.
604. When must these required records be made available to the FAA?
Under FAA’s regulations, you must make these records available to the FAA in a reasonable amount of time. The FAA can make a request to see your records at any time or place.
605. Who must make these required records available to the FAA?
You must designate those persons in your organization who are responsible for providing each required record or report to the FAA on request. You must make a list of these persons and their location. The list must include the records, documents, and/or reports that each person is responsible for. You must keep this list current, and make it available to the FAA at your principal base of operations.
1. Summary information.
Air carriers are required to make and keep a list of certain summary status records. You are required to transfer these records with the aircraft when it is sold. Summary current status recordkeeping requirements are listed and explained as follows:
a. The “total time-in-service of the airframe, each installed engine, and each installed propeller.” Total time-in-service is a record that contains the time-in-service accrued since new or rebuild, expressed in hours and landings or cycles.
b. The “current status of each life-limited part” of each airframe, engine, propeller, and appliance means a record that contains, at least, the following information:
NOTE: For part 135 air carriers, total time-in-service and current status of life-limited parts includes rotors.
(1) Time-in-service since new expressed in the appropriate parameter (hours, cycles, calendar time, etc.).
(2) The time-in-service remaining to the specified life limit expressed in the appropriate parameter (hours, cycles, calendar time, etc.).
(3) The specified life limit expressed in the appropriate parameter (hours, cycles, calendar time, etc.).
(4) A record of any action that alters the part’s life limit or changes the parameter of the life limit.
c. The listing of the “time since last overhaul” means a record that contains, at least, the following information:
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(1) A listing of the item that requires overhaul, and its associated scheduled overhaul interval.
(2) The time-in-service since the last overhaul.
(3) The time-in-service remaining to the next scheduled overhaul.
(4) The time-in-service when the next scheduled overhaul is due.
NOTE: The listing of “time since overhaul” refers to summary current status information and must not be confused with an overhaul record, which is a description of the work performed and the identification of the person who performed and/or issued the approval for return to service.
d. The “current inspection status of the aircraft” means a record that contains, at least, the following information:
(1) A listing identifying each of the scheduled inspection packages and each task and their associated intervals that are required by the maintenance program under which the aircraft is maintained.
(2) The time-in-service accrued since the last accomplishment of each of the scheduled inspection packages and tasks required by the maintenance program under which the aircraft is maintained.
(3) The time-in-service remaining to the next accomplishment of each of the scheduled inspection packages and tasks required by the maintenance program under which the aircraft is maintained.
(4) The time-in-service when the next accomplishment of each of the scheduled inspection packages and tasks required by the maintenance program under which the aircraft is maintained is due.
e. The “current status of an airworthiness directive” means a record that contains, at least, the following information:
(1) Identification of the particular airframe, engine, propeller, appliance, or component to which the AD is applicable.
(2) The AD number (and/or regulatory amendment number).
(3) The date and the time-in-service expressed in the appropriate measuring parameter (hours, cycles, calendar time, etc.) when the required action was accomplished.
(4) If the requirement is recurring, the time-in-service when the next action is due expressed in the appropriate measuring parameter (hours, cycles, calendar time, etc.).
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(5) The method of compliance means: with regard to an AD, a concise description of the action taken to comply with the requirements of the AD. If the AD or its referenced manufacturer’s service bulletin permits the use of more than one method of compliance, the record must include a reference to the specific method of compliance used. If the operator uses an alternate method of compliance (AMOC) to comply with an AD, the method of compliance means a description of this AMOC and a copy of the FAA approval.
NOTE: The listing of “current status of an airworthiness directive” or “method of compliance” refers to summary current status information and must not be confused with an AD record of accomplishment, which is a description of the work performed and the identification of the person who performed and/or issued the approval for return to service.
f. A listing of “the current major alterations of each airframe, engine, propeller, and appliance” means a record that contains, at least, the following information:
(1) A listing identifying each major alteration as well as the associated item to which the major alteration has been installed.
(2) A description, or reference to, the FAA-approved technical data used to make the major alteration.
NOTE: For part 135 air carriers, this listing includes a list of all current major repairs, as well as a requirement for a listing of major repairs and alterations to each rotor.
NOTE: The listing of “all of the current major alterations” refers to summary current status information and must not be confused with a major alteration report, which is a detailed description of the work performed, a description of the FAA-approved technical data used to make the alteration, and the identification of the person who performed and/or issued the approval for return to service. This listing also must not be confused with the requirement to submit a copy of each report of a major alteration to the FAA.
g. “All the records necessary to show that all requirements for the issuance of an airworthiness release have been met.” While the regulatory requirement for these records does not provide a detailed list of these records, this requirement is generally accepted to mean:
(1) Detailed records of all scheduled maintenance that has not been superseded by work of equivalent scope and detail.
(2) Detailed records of the accomplishment of the last overhaul for those items required to be overhauled.
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NOTE: An overhaul record is not required to contain a record of AD accomplishment. The regulations require records of AD current status and accomplishment to be made and preserved as a separate and distinct record.
(3) Detailed records of all unscheduled maintenance that has not been superseded by work of equivalent scope and detail.
(4) Adequate copies of the airworthiness release. “Adequate copies” is generally accepted to mean copies covering the last 60 days of operation.
NOTE: All of these items (a-g) are required, by regulation, to be transferred with the aircraft when it is sold.
2. Air carrier airworthiness release records.
The FAA’s regulations require that each time you perform maintenance or alterations on your aircraft, you must make, or cause to be made, an airworthiness release or log entry before you can operate the aircraft. You are also required to give a copy of the airworthiness release to the pilot-in-command, and to keep a record of the airworthiness release for at least two months. You must keep all of the records necessary to show that all of the requirements for the issuance of an airworthiness release have been met. These records must be retained for at least one year after the work is performed, or until the work is superseded by work of equivalent scope and detail.
However, you must keep detailed records of the accomplishments of the last required overhaul until the work is superseded by work of equivalent scope and detail.
Generally speaking, the airworthiness release is executed each time the aircraft completes a scheduled check. A log entry is executed each time the aircraft is approved for return to service after unscheduled maintenance. You may not operate the aircraft unless you issue an airworthiness release or approve it for return to service.
606. Are there any other required records or reports that you must make and keep?
Besides the records listed above, FAA’s regulations require you to make other reports and records, listed below. You can use these records and reports to review your maintenance operations to determine the adequacy of the maintenance portion of your air carrier manual and the effectiveness of your maintenance program, as well as your CASS. FAA also uses these reports in its continuous oversight of your maintenance program.
1. You must keep an aircraft maintenance log.
Whenever you take action in response to a reported or observed failure or malfunction, you must make a record of that action in the maintenance log of the aircraft. You must ensure that each pilot-in-command enters all mechanical irregularities occurring during flight time, and that these are entered in the maintenance log at the end of that particular flight time.
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