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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
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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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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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