2. You must make mechanical reliability reports.
You should use these reports to help you identify deficiencies within your maintenance program.
The FAA uses these reports as a means of gathering information for its Service Difficulty Reporting System.
3. You must make mechanical interruption reports.
Essentially, these reports document the inability of the aircraft to arrive at its scheduled destination due to mechanical difficulties. You should use these reports to help you determine the degree of effectiveness of your maintenance program.
4. If you are a part 121 air carrier, you are required to make a report of each major alteration and each major repair made on your aircraft.
You are required to make and submit a major alteration report to the FAA. You are also required to make a report of each major repair, but you are not required to submit it. You must, however, make it available for inspection by the FAA. In addition, because you are an air carrier, you do not have to use FAA Form 337 to report a major alteration or repair that you accomplished, although you can use it.
5. If you are a part 135 air carrier, you are required to make a report of each major alteration and each major repair made on your aircraft.
You are not required to submit either report, but you must make them available to the FAA when they ask.
NOTE: These alteration and repair reports should not be confused with the current status listing of major alterations required under part 121 as well as the current status listing of major repairs and alterations required under part 135.
607. Are you required to keep historical or source records to support your required maintenance records?
There is no regulatory or statutory requirement for you to prepare, store, or retain historical or source records to support your required aircraft maintenance records or current status records.
Indeed, if you have a good system to prepare, store, and retain your required maintenance records and you monitor that system under your CASS, you should not need historical or source records for support. Unless there is evidence to the contrary, an aircraft maintenance record produced by your maintenance recordkeeping system should be acceptable by itself, without historical or source records. The FAA will not require you to produce or maintain any records not required by statute or regulation. However, you may wish to archive certain source
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documentation records that you used to introduce parts or components into your maintenance system. These records may include documents such as the manufacturer’s invoice for new parts, export certificates of airworthiness, documentation of a major repair or alteration, or other similar information that may be useful in the future.
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CHAPTER 7. ACCOMPLISHMENT AND APPROVAL OF
MAINTENANCE AND ALTERATIONS
You must provide instructions in your manual and program for maintenance and alterations for three major areas: scheduled maintenance, unscheduled maintenance, and specific maintenance requirements for major components of the aircraft.
700. What is scheduled maintenance?
Scheduled maintenance consists of all the individual maintenance tasks performed according to the maintenance time limitations (maintenance schedule). Your scheduled maintenance activities should include procedural instructions for the maintenance tasks and requirements to record the results of the inspections, checks, tests, and other maintenance.
701. What is 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 hard or overweight landings, tail strikes, lightning strikes, or engine overtemperature. You should include instructions and standards for the accomplishment of unscheduled maintenance in your technical manuals. You should include detailed procedures for recording all types of unscheduled maintenance in your manual.
702. What should your engine maintenance program contain?
Your engine maintenance program should cover both installed engines and off-wing maintenance 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.
Normally, the installed engine or APU requirements will be contained in the maintenance time limitations. In addition to procedural information, the off-wing program described in your manual should provide shop scheduling information or intervals for cleaning, adjusting, inspecting, testing, and lubricating each part of the engine or APU requiring that maintenance.
Include in your maintenance manual the degree of inspection, the applicable wear tolerances, and the work required when the engine or APU is in the shop. Your engine maintenance or APU program should contain at least the following segments:
a. Procedures for installed and off-wing scheduled and unscheduled engine or APU maintenance tasks.
b. The engine or APU overhaul standard, if applicable.
c. The engine or APU build standard.
d. Procedures for managing the maintenance of short-term and long-term leased aircraft engines or APUs.
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e. Procedures for management and maintenance of engines or APUs while they are in a shop maintenance status, whether the engines are leased or not.
f. Procedures for integrating a short-term or long-term leased engine or APU into your maintenance program.
g. Procedures for engine or APU condition and trend monitoring, if used.
703. What should your propeller maintenance program contain?
Your propeller maintenance program should cover each model of both installed propellers and off-wing propellers that you operate. Normally, the installed propeller system requirements will be contained in the maintenance time limitations. In addition to procedural information, the offwing program described in your manual should provide shop scheduling information or intervals for cleaning, inspecting, adjusting, testing, and lubricating each part of the propeller system requiring that maintenance. 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 training for maintenance personnel. Your propeller maintenance program should contain at least the following segments:
a. Procedures for installed and off-wing scheduled and unscheduled propeller system maintenance tasks.
b. The propeller system overhaul standard, if applicable.
c. The propeller system build standard.
d. Procedures for managing the maintenance of short-term and long-term leased propellers.
e. Procedures for management and maintenance of propellers while they are in a shop maintenance status, whether they are leased or not.
f. Procedures for integrating a leased propeller into your maintenance program.
704. What should your parts and appliance maintenance program contain?
For the most part, this component 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 you operate. Normally, the installed part and appliance requirements will be contained in the maintenance time limitations. In addition to procedural information, the off-wing program described in your manual should provide shop scheduling information or intervals for cleaning, adjusting, inspecting, testing, and lubricating each component of the part and appliance requiring that maintenance.
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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. Your parts and appliance maintenance program should contain at least the following segments:
a. Procedures for installed and off-wing scheduled and unscheduled parts and appliance maintenance tasks.
b. The parts and appliance overhaul standard, if applicable.
c. The parts and appliance build standard.
d. Procedures for managing the maintenance of short-term and long-term leased parts and appliance engines.
e. Procedures for management and maintenance of parts and appliances while they are in a shop maintenance status, whether the parts or appliances are leased or not.
f. Procedures for integrating short-term or long-term leased parts and appliances into your maintenance program.
g. Procedures for parts and appliance condition and trend monitoring, if used.
705. What is the Aging Airplane Program?
The FAA developed the aging aircraft program to address the continued airworthiness of large transport, commuter, and other aircraft that have reached or exceeded their design service life objective. Your Aging Airplane Program normally should cover:
a. Structural modification and inspection;
b. Corrosion prevention and control;
c. Supplemental structural inspection program review and update; and
d. Structural repair assessment requirements.
NOTE: Many FAA ADs associated with the Aging Airplane Program require structural modification, corrosion prevention and control, and supplemental inspection programs. You may integrate these requirements into your overall maintenance program; you do not need to treat it as a separate program, unless the AD requires separation.
706. What are Required Inspection Items?
Under FAA’s regulations, you must designate certain tasks as “required inspection items” (RII).
These required inspections cover maintenance tasks which, if not properly performed or if done Par 704 Page 27
with improper parts or materials, could result in a failure, malfunction, or defect which would endanger the continued safe flight and landing of the aircraft. In the case of maintenance tasks performed by other persons, you may delegate the RII function to the other person’s inspection organization provided you document the arrangement and control it through your maintenance manual. Some examples of other terminology used to describe RII are back-check, buy-back, and duplicate inspection.
1. Your maintenance program manual must specifically identify all RII tasks and procedures.
It should also include procedures to identify and authorize RII personnel, both within your organization and in other organizations that perform maintenance for you. You must formally notify persons authorized to accomplish RII items of the authorization and its scope. You should also identify RII on work forms, job cards, engineering orders, and so on, or by any other method consistent with your maintenance program. A primary concept of the RII function is that the person performing the item of work may not perform the required inspection on that item of work. Additionally, you must design your maintenance organization to separate the accomplishment of your required inspection function from the accomplishment of your maintenance, preventive maintenance, and alteration function. You must also have procedures in your manual to ensure that only a supervisor of an inspection unit or the person that has overall responsibility for both the RII function and the other maintenance, preventive maintenance, and alteration functions may countermand the decision of any RII inspector regarding an RII. These requirements apply equally to your organization or to an organization performing your maintenance for you.
2. RIIs differ from other inspection tasks in their critical effect on flight safety.
For example, work on a landing gear position indicating system might be a normal inspection, whereas an elevator rigging check conducted to check adjustment of elevator travel would be designated RII because improper adjustment might result in reduced controllability of the aircraft. You must consider all RIIs with the same emphasis regardless of whether an individual RII is related to a scheduled or an unscheduled task. The fact that an RII requirement arises at an awkward time or inconvenient location cannot have a bearing on the requirement to accomplish these types of inspections properly.
707. What are some examples of RIIs?
In determining the tasks to designate as RIIs, you should consider the following examples. This list does not cover all RIIs.
a. Installation, rigging, and adjustments of flight controls and surfaces.
b. Installation and repair of major airframe or engine structural components.
c. Installation of an aircraft engine, propeller, propeller blade, or rotor.
d. Installation, repair, and calibration of certain avionics and navigational equipment.
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CHAPTER 8. CONTRACT MAINTENANCE
800. What is the extent of your responsibility for maintenance performed by others?
When you use a maintenance provider to provide all or part of the maintenance on your airplane or its component parts, that maintenance provider’s organization becomes, in effect, an extension of your maintenance organization. However, you remain responsible for all of the maintenance performed by that maintenance provider on your airplanes. You must determine the maintenance provider’s capability to do the work. You must direct the work. Since all work on your aircraft must be performed in accordance with your manual and your maintenance program, you must also provide the maintenance provider with appropriate material from your maintenance manual for that work. Your manual system should accommodate work performed for you by maintenance providers. The policy and procedures segment of your manual should assign responsibilities and delineate procedures to administer, control, and direct contracted work. The technical material that you provide should be arranged for the use and guidance of the maintenance provider.
NOTE: When possible, you should have a written contract with anyone performing maintenance work for you on a continuing basis. This will help ensure that your responsibilities are addressed. In the case of major operations, such as engine, propeller, or airframe overhaul, the contract should include a specification for the work. You should include or reference that specification in your manual system.
801. What are the requirements for performing unscheduled maintenance away from your regular maintenance facilities?
Sometimes, on an unanticipated basis, you will need maintenance while your aircraft is away from your regular maintenance facilities. You may also need maintenance services on short notice. Your manual should include procedures for obtaining these services under these unanticipated conditions. You should outline the steps you will take to control and direct the work that is to be done. Unscheduled, short-notice requirements for maintenance does not abrogate your responsibility to determine that your maintenance provider has the organization, adequate facilities and equipment, competent personnel, and appropriate portions of your manual for the work that is to be done. These determinations must be made before the maintenance provider starts to work on your aircraft.
802. Who has the responsibility for releasing your aircraft as airworthy?
You, as an air carrier, have the responsibility for releasing your aircraft as airworthy. Each individual, whether employed by you or by a maintenance provider doing work for you, who releases one of your aircraft for service following maintenance must be an individual, a certificated mechanic or repairman, and be specifically authorized by you to do so. An individual may not release one of your aircraft unless you authorize them to do so.
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1. You must designate each individual authorized to execute the airworthiness release for you by name and occupational title. The individual signing the release acts as your authorized agent.
He or she certifies the maintenance covered by the release has been accomplished according to your manual and maintenance program and that no known condition exists that would make the aircraft unairworthy. This arrangement in no way reduces the responsibility of maintenance personnel for maintenance functions or tasks they perform or supervise.
2. In your manual, you should describe the circumstances when a release is required. Normally, an airworthiness release is required following completion of maintenance prescribed by OpSpecs, or maintenance activities involving RII. You may not operate your aircraft unless you have approved it for return to service or issued an airworthiness release.
803. How are new maintenance providers evaluated?
Before you can use a maintenance provider for the first time, you must conduct an audit of that maintenance provider to conf irm the provide r complie s with pe rtine nt requir ements of 14 CFR part 121, subpart L. In most cases, this will be an on-site audit. You must demonstrate, through this audit or by some other means, that the maintenance provider meets all of the following requirements and is capable of performing the work consistent with the requirements of your program. The maintenance provider must have:
a. The capability to do the work;
b. An organization structured to do the work;
c. Competent, trained personnel to do the work;
d. Relevant and current technical and administrative material from your manual for the work;
e. Adequate facilities and equipment to do the work;
f. The ability to transfer and receive data and information necessary to support your CASS;
and
g. A current listing of individuals trained, qualified, and authorized by you to conduct required inspections. The list must identify these individuals by name, occupational title, and the inspection(s) they are authorized to perform.
804. How do you ensure your maintenance provider continues to comply with the requirements?
Ensuring the maintenance provider’s continued compliance is part of your CASS. You should establish a schedule for auditing and inspecting each maintenance provider. These audits should determine the maintenance provider’s continuing compliance with both 14 CFR part 121, subpart L, and your maintenance program. The audit schedule should be based on your own unique set of circumstances and needs. It should not be fixed; rather, the frequency of audits or Page 30 Par 802
inspections should respond to such variables as your level of confidence in the maintenance provider, the complexity and quantity of the work, the quality of the work produced, and the quality of the records and certifications provided. Because of these variables, your audit schedules may not be the same as another air carrier’s and should change in response to information from your CASS. For maintenance providers, your CASS will continuously:
a. Ensure that all maintenance on your aircraft or component parts performed by the maintenance provider is done in accordance with your manual and maintenance program.
b. Detect and identify, and provide timely corrective action for, all deficiencies or deviations in those portions of your maintenance program done by the maintenance provider, including maintenance recordkeeping.
c. Track and evaluate the standards of performance (quality) of the maintenance done by the maintenance provider. You must include provisions for timely corrective action if the quality of work becomes unsatisfactory.
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CHAPTER 9. CONTINUING ANALYSIS AND SURVEILLANCE SYSTEM
900. What are the origins of the Continuing Analysis and Surveillance System?
Introduction of a Continuing Analysis and Surveillance System (CASS) resulted from a FAA/National Transportation Safety Board (NTSB) joint study of a series of maintenancerelated air carrier accidents occurring during the 1950s. The joint study found that, in some cases, the primary causal factor of an accident was the effectiveness of the air carrier’s maintenance program itself. The study found that some maintenance programs were incapable or ineffective in preventing the failure that led to the accident. In other cases, the maintenance program was determined to be effective, but maintenance personnel failed to accomplish required maintenance tasks or failed to accomplish the task correctly. The study found that the maintenance program was often not performed properly.
a. Responding to this discovery, FAA introduced regulatory requirements that require air carriers to establish and use a system for the continuing analysis and surveillance of the performance and effectiveness of their inspection, maintenance, preventive maintenance, and alterations programs.
b. The system must also provide a way to correct any deficiency in those programs, regardless of whether those programs are carried out by the air carrier or by another person.
CASS is crucial to the effective management of your maintenance program and your realization of the highest possible degree of safety.
901. What is CASS?
CASS is an air carrier quality assurance system. In a structured, methodical manner, CASS helps you ensure that you reach your maintenance program objectives. CASS is the only management system that is mandated by regulation. Used properly, your CASS becomes an inherent way of doing business for you, and helps you promote a safety culture in your company by providing a formal process for employees to identify and correct safety discrepancies.
902. What does CASS do?
Your CASS must be designed to detect and correct air carrier maintenance program deficiencies in the areas of program effectiveness and program performance (program execution). Your CASS provides a structured process to identify factors that could lead to an accident or incident through collection and evaluation of information that can be used as indicators of the degree of maintenance program effectiveness and performance. This is accomplished through a closedloop, continuous cycle of surveillance, investigations, data collection and analysis, corrective action, corrective action monitoring, and back to surveillance. Your CASS should ensure that all elements of your maintenance program are being accomplished in accordance with your manual (program execution), that your program is effective in achieving its goals, and that deficiencies in your maintenance program and manuals are identified and corrected. CASS collects information, analyzes the information, and looks for precursors, indicators, or symptoms of discrepancies in your maintenance program so that you can develop and implement corrective action. FAA’s regulations allow the FAA to direct changes to your maintenance program to correct deficiencies if you do not make the changes by yourself.
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