U.S. Department of Transportation Federal Aviation Administration Advisory Circular Subject: Air Carrier Maintenance Programs Date: 9/11/08 Initiated by: AFS-300 AC No: 120-16E Change:
FOREWORD This advisory circular (AC) describes the scope and content of air carrier aircraft maintenance programs. It explains the background of these programs as well as the Federal Aviation Administration’s (FAA) regulatory requirements. Each of the 10 elements of air carrier maintenance programs are also described and explained. In this AC, air carrier maintenance means inspection, overhaul, repair, preservation, and the replacement of parts, as well as preventive maintenance. When “must” or “will” are used in this AC, they reflect regulatory requirements. When “you” or “your” is used in this AC, it refers to the air carrier.
ORIGINAL SIGNED by
James J. Ballough Director, Flight Standards Service
CONTENTS
ParagraphPage
CHAPTER 1. GENERAL INFORMATION1
100. Purpose of This AC1
101. Who This AC Affects1
102. Document This AC Cancels1
103. Legal Basis of Air Carrier Maintenance Programs1
104. Maintenance Program Authorization2
105. Air Carrier Maintenance Program Objectives2
106. Air Carrier Maintenance Program Elements3
CHAPTER 2. AIRWORTHINESS RESPONSIBILITY5
200. Responsibility for Aircraft Maintenance5
201. The Differences Between Air Carrier Maintenance Programs and Part 91 General
Aviation Inspection Programs5
CHAPTER 3. AIR CARRIER MAINTENANCE MANUAL7
300. Air Carrier Maintenance Manual Requirement7
301. Role of the Air Carrier Maintenance Manual7
302. Major Sections of the Typical Air Carrier Maintenance Manual7
CHAPTER 4. AIR CARRIER MAINTENANCE ORGANIZATION11
400. Maintenance Organization—General11
401. Required Maintenance Organization Management Positions11
402. Required Air Carrier Maintenance Organizational Structure12
403. Organizational Separation of the Inspection and Maintenance Departments12
CHAPTER 5. ACCOMPLISHMENT AND APPROVAL OF MAINTENANCE AND
ALTERATIONS15
500. Accomplishment of Maintenance15
501. Major Repairs and Alterations15
502. Airworthiness Release Form or Aircraft Log Entry and Approval for Return
to Service16
503. Scope of Maintenance16
504. Parts and Appliances Maintenance Programs17
CHAPTER 6. MAINTENANCE SCHEDULE19
600. The Maintenance Schedule19
601. The FAA’s Role in Relation to the Maintenance Schedule19
602. Maintenance Schedule Contents19
603. Standards for Determinig Maintenance Time Limitations20
CHAPTER 7. REQUIRED INSPECTION ITEMS23
700. Required Inspection Items23
701. RII Procedures, Standards, and Limits23
Page iii (and iv)
CHAPTER 8. MAINTENANCE RECORDKEEPING SYSTEM25
800. Reasons for Making and Keeping Maintenance Records25
801. Part 43 Requirements25
802. Work Performed by a Part 145 Repair Station25
803. Penalties for Improper Air Carrier Maintenance Recordkeeping26
804. Making and Keeping Required Records26
805. Required Air Carrier Maintenance Records26
806. When to Make Records Available to the FAA26
807. Responsibility for Making Records Available to the FAA26
808. Required Records27
809. Other Required Records and Reports29
810. Requirements for Reports of Major Alterations and Major Repairs32
811. Requirements for Historical or Source Records32
CHAPTER 9. CONTRACT MAINTENANCE33
900. Responsibility for Maintenance Performed by Others33
901. Unscheduled Maintenance Performed Away From Regular Facilities33
902. Airworthiness Release Form or Aircraft Log Entry33
903. Evaluating New Contract Maintenance Providers34
904. Continuing Maintenance Provider Oversight34
905. Using a Certificated Repair Station as One of Your Maintenance Providers35
CHAPTER 10. PERSONNEL TRAINING37
1000. Maintenance Program Training Requirements37
1001. Types of Training37
1002. Initial Training37
1003. Recurrent Training37
1004. Specialized Training38
1005. Maintenance Provider Training38
1006. Competency-Based Training38
CHAPTER 11. CONTINUING ANALYSIS AND SURVEILLANCE SYSTEM (CASS)41
1100. Background of the CASS41
1101. CASS is a Safety Management Tool41
1102. Basic CASS Processes41
1103. Risk-Based Decisions42
1104. Scope of CASS43
1105. CASS Design Principles43
1106. CASS Personnel Requirements44
CHAPTER 12. ADMINISTRATIVE45
1200. Regulatory References45
1201. Other Related Legal and Guidance Material45
1202. Obtaining Reference Material46
Par 100 Page 1 CHAPTER 1. GENERAL INFORMATION
100. PURPOSE OF THIS AC.
a. This AC describes the 10 elements that comprise air carrier maintenance programs and what you should include in your air carrier maintenance program.
b. In this AC, maintenance means inspection, overhaul, repair, preservation, and the replacement of parts, as well as preventive maintenance. Consistent with regulations, inspection functions are part of the maintenance program; they are not separate.
c. Your maintenance manual is the part of your air carrier manual that describes your maintenance program.
101. WHO THIS AC AFFECTS. This AC applies to those Title 14 of the Code of Federal Regulations (14 CFR) part 119 air carriers conducting operations under 14 CFR parts 121 and
135. For part 135 operations, this AC applies only to those maintenance operations conducted under § 135.411(a)(2). This AC also applies to each person employed or used by an air carrier certificate holder for any maintenance, preventive maintenance, or alteration of its aircraft.
Person is defined at 14 CFR § 1.1 as an individual, firm, partnership, corporation, company, association, joint-stock association, or governmental entity. It includes a trustee, receiver, assignee, or similar representative of any of them.
102. DOCUMENT THIS AC CANCELS. This AC cancels AC 120-16D, Air Carrier Maintenance Programs, dated March 20, 2003.
103. LEGAL BASIS OF AIR CARRIER MAINTENANCE PROGRAMS.
a. 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 instructs the FAA Administrator to promote the safe flight of civil aircraft in air commerce through regulations and standards prescribed in the interest of safety.
b. Section 44701 also obliges the Administrator to consider the duty of an air carrier to provide service with the highest possible degree of safety in the public interest, consider differences between air transportation and other air commerce, and classify a regulation or standard appropriate to the differences between air transportation and other air commerce when prescribing regulations and standards. The term “air commerce” is defined within 49 U.S.C.
§ 40102 as “foreign air commerce, interstate air commerce, the transportation of mail by aircraft, the operation of aircraft within the limits of a Federal airway, or the operation of aircraft that directly affects, or may endanger safety in, foreign or interstate air commerce.” Simply stated, operations in air commerce are almost everything but operations in air transportation.
c. Consistent with 49 U.S.C. § 44701, the FAA regulates aircraft operations at different levels of safety. Hence, the regulations that govern air carrier operations (air transportation) and the operations of other air commerce are structured differently to reflect the differences between these two segments of the aviation industry. Establishing appropriate standards and regulatory requirements is a risk management process and the underlying legal structure provides for more
Page 2 Par 103 than one level of acceptable risk. Air transportation regulations are all-inclusive and stand alone;
whereas the regulations governing other air commerce do not. Similarly, the scope of responsibility for those in air transportation is very broad and not shared, whereas in other air commerce it is relatively narrow and is commonly shared. The regulations in parts 119, 121, and 135 relate directly to air carrier maintenance programs and reflect the highest possible degree of safety in the public interest. The regulations in parts 43, 65, 91, and 145 do not necessarily reflect the highest possible degree of safety in the public interest. More specific references to relevant regulations are included in subsequent paragraphs of this AC.
d. The FAA introduced the Continuous Airworthiness Program (CAP) in a final rule at 29 FR 6522 on May 20, 1964. Over the years since then, CAP has become known, in a colloquial sense, as a Continuous Airworthiness Maintenance Program (CAMP). The 1964 rulemaking was in response to safety concerns and discoveries of weaknesses in the maintenance programs of some air carriers, as revealed during accident investigations and FAA surveillance of operator maintenance activities. The air carrier CAP was designed to strengthen requirements for air carrier safety management activities. Each one of the air carrier maintenance program elements described in this AC were a part of this 1964 rulemaking.
104. MAINTENANCE PROGRAM AUTHORIZATION. Your maintenance program is not approved by the FAA. The FAA issues air carrier operations specifications (OpSpecs) authorizing you to use a maintenance program and the maintenance manual required by FAA 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.
These competency letters contained information that authorized the air carrier’s services, routes, aircraft, maintenance, airmen, and weather procedures; they were considered part of the air carrier operating certificate and could be amended as the circumstances dictated. 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 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. Issued by the FAA, OpSpecs are made legally binding through specific regulatory language. (See § 119.33 for the applicable language.)
105. AIR CARRIER MAINTENANCE PROGRAM OBJECTIVES.
a. Your maintenance program ensures your aircraft and all of its parts can perform their intended functions and should reflect three specific program objectives to provide the highest possible level of safety in air transportation:
(1) Each of your aircraft released to service is airworthy and has been properly maintained for operations in air transportation;
(2) Maintenance and alterations that you perform, or that other persons perform for you, are performed in accordance with your maintenance manual; and
Par 105 Page 3 (and 4)
(3) Competent personnel with adequate facilities and equipment perform maintenance and alterations on your aircraft.
b. You should also have a system of continuing cycles of surveillance, investigation, data collection, analysis, corrective action, and corrective action verification that ensures all parts of your maintenance program are effective and are being performed in accordance with your manual. Effective means that the desired results are being achieved according to the maintenance program objectives and the standards that you, the air carrier, set.
106. AIR CARRIER MAINTENANCE PROGRAM ELEMENTS. An air carrier maintenance program includes the following 10 elements. This AC explains each of these elements individually. In some cases, there is another AC that provides more detailed information about one or more of the maintenance program elements. Where such ACs exist, this AC does not explain that element in depth.
• Airworthiness responsibility,
• Air carrier maintenance manual,
• Air carrier maintenance organization,
• Accomplishment and approval of maintenance and alterations,
• Maintenance schedule,
• Required Inspection Items (RII),
• Maintenance recordkeeping system,
• Contract maintenance,
• Personnel training, and
• Continuing Analysis and Surveillance System (CASS).
Par 200 Page 5 CHAPTER 2. AIRWORTHINESS RESPONSIBILITY
200. RESPONSIBILITY FOR AIRCRAFT MAINTENANCE.
a. Consistent with §§ 121.363 and 135.413, you, as a part 119 certificate holder, are primarily responsible for (1) the airworthiness of your aircraft, and (2) the performance of all of the maintenance on your aircraft.. Your air carrier certificate makes you a maintenance entity.
Under your air carrier certificate, you accomplish maintenance, preventive maintenance, or alterations, or you can use other persons who are not direct employees to accomplish that work.
Consistent with the FAA’s regulations at §§ 121.1(b) and 135.1(a)(2), the part 121 or 135 regulations govern each person that is employed or used by you for any maintenance, preventive maintenance, or alteration of your aircraft. Each of these persons who are used by you must be under your direction and control and must follow your maintenance program. You should note the definition of “person” in 14 CFR § 1.1
b. For any work done on your aircraft, you retain direct and primary responsibility for performing and approving all maintenance and alterations, whether that work is accomplished by you or by someone else (for example, a maintenance provider, such as a repair station).
However, you retain primary responsibility for the performance and approval of the maintenance done by that maintenance provider.
201. THE DIFFERENCES BETWEEN AIR CARRIER MAINTENANCE PROGRAMS AND PART 91 GENERAL AVIATION INSPECTION PROGRAMS. The following table provides a comparison of the differences between air carrier maintenance programs and part 91 general aviation inspection programs.
Element Part 121 and 135 Air Carriers Part 91 Owners/Operators Use of a maintenance or an inspection program.
Required to use a maintenance program for its aircraft.
Required to use an inspection program.
Responsible for the performance of maintenance in accordance with its maintenance program and manual, as well as the airworthiness of its aircraft, including airframes, aircraft engines, propellers, appliances, and parts thereof.
Responsible for maintaining the aircraft in an airworthy condition (§ 91.403).
Responsibilities within the relevant program.
NOTE: The wording in part 91 is deliberately different from the wording in parts 121 and 135 and is consistent with the difference between air carriers and other air commerce described in 49 U.S.C. § 44701.
Responsible for the development and use of the maintenance program and manual, determining the method of performing maintenance, a required inspection list, a continuous analysis and surveillance system, a Responsible for the selection of an existing inspection program and the scheduling of aircraft for the inspections, and; ensuring discrepancies that occur between scheduled inspections are repaired.
Page 6 Par 201 maintenance organization that can exercise operational control over maintenance operations, and other items that collectively and systematically serve to ensure each aircraft has been properly maintained for operations in air transportation and is airworthy.
Must determine what maintenance is required, how to do it, when to do it, perform that maintenance, and approve its own aircraft for return to service. May authorize another person to accomplish the maintenance work, but the maintenance must be carried out according to the air carrier’s maintenance program and manual.
The air carrier still retains the responsibility for the proper completion of maintenance (§ 121.363 or § 135.413).
Must make the airplane available to authorized and certificated person(s) who accomplish inspections and other maintenance.
Along with FAA oversight, is the primary authority with regard to its maintenance program. Holds the primary responsibility for the performance of maintenance in accordance with its maintenance program and manual, as well as the airworthiness of its aircraft, including airframes, aircraft engines, propellers, appliances, and parts thereof.
The authorized and certificated person(s) has the responsibility to perform the maintenance properly in accordance with the manufacturer’s manual and to approve the aircraft for return to service. The owner/operator does not have this responsibility. However, the owner/operator is responsible for ensuring maintenance personnel make appropriate entries in the aircraft maintenance records indicating the aircraft has been approved for return to service.
Par 300 Page 7 CHAPTER 3. AIR CARRIER MAINTENANCE MANUAL
300. AIR CARRIER MAINTENANCE MANUAL REQUIREMENT.
a. The FAA regulations (14 CFR §§ 121.133, 121.369, 135.21, and 135.427) require you to have a maintenance manual. It is a required part of your air carrier manual system. Some air carriers call their manuals “specifications.”
b. Your maintenance manual must be easy to revise, and have procedures for keeping all parts of your manual up to date. Your manual may be electronic.
c. You must make copies of your manual or appropriate portions of it (and changes or additions) 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, or appropriate parts, must keep it up to date.
d. Other regulations that relate to manual requirements are §§ 43.13(c), 121.135, 121.137,
135.23, and 135.427.
301. ROLE OF THE AIR CARRIER MAINTENANCE MANUAL.
a. Your maintenance manual is your key to standardized, consistent accomplishment and administration of your maintenance program.
b. Your maintenance manual:
(1) Identifies, describes, and defines your maintenance program.
(2) Provides instructions and procedures to administer, use, manage, and amend your program.
c. Your maintenance manual is a company publication, and you have sole responsibility for its organization and content, however, others may compile and publish it for you. Your maintenance manual may be electronic.
302. MAJOR SECTIONS OF THE TYPICAL AIR CARRIER MAINTENANCE MANUAL.
a. Organization of Your Maintenance Manual. Your maintenance manual should have a practical organization. Typically, it will have at least three sections: one covering administrative policies and procedures; a second covering detailed instructions for the administration, management, and accomplishment of the elements of the maintenance program;
and a third covering technical data that describes maintenance standards, methods, techniques, and procedures.
(1) Administrative Policies and Procedures. It is a management and administrative tool for organizing, directing, amending, and controlling your maintenance program.
Organizational charts delineating the functions, relationships, and lines of authority between
Page 8 Par 302 organizational elements and personnel usually are identified here. This part is where you list position descriptions, duties, responsibilities, and specific authority and responsibility attributes for each position within your maintenance organization. The authority and responsibility attributes should show who has overall authority and/or responsibility and who has direct authority and/or responsibility.
(2) Instructions for the Administration, Management, and Accomplishment of the Maintenance Program.
(a) This section contains detailed instructions for your 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. This section usually includes a description of scheduled maintenance tasks, procedural information, and detailed instructions (or specific air carrier maintenance manual references) for accomplishing maintenance tasks.
Additionally, you should describe criteria for initiating functional evaluation flights in this part of the maintenance manual, along with procedural requirements for them. In this portion of your manual, you should also include criteria and procedural information for unscheduled inspections, such as those associated with lightning strikes, tail strikes, engine temperature exceedance, hazardous material spills, hard or overweight landings, and any very high load event.
(b) You should have a comprehensive process in the unscheduled maintenance portion of your manual that addresses those rare, extremely high-load events that occur to aircraft. Specifically, you should have inspection processes that are used following certain high load events. These particular high load events are those for which the subsequent inspection process might benefit from the use of flight data. Listed below are the events deemed most significant:
1. Flight Events
• A severe turbulence encounter,
• Extreme maneuvers,
• Exceedance of speed limitations, and
• Heavy stall buffet.
2. Ground Events
• Hard landings,
• Over-weight landings, and
• Drift landings resulting in excessive side/drag load.