Par 600 Page 19 CHAPTER 6. MAINTENANCE SCHEDULE
600. THE MAINTENANCE SCHEDULE. Sections 119.49 and 121.135(b) require you to have maintenance time limitations, also called a maintenance schedule. These same rules permit you to make standards for determining your maintenance time limitations. This language is the regulatory basis of FAA-approved reliability programs that were developed in the 1960s. 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 regulations are broad enough to permit you to organize all of these individual tasks into a series of integrated scheduled work packages of your own design that provide a continuous succession of necessary or desirable scheduled maintenance tasks for your entire airplane.
601. THE FAA’s ROLE IN RELATION TO THE MAINTENANCE SCHEDULE. The FAA authorizes your maintenance schedule through your OpSpecs, and your CASS monitors that schedule to verify its effectiveness, i.e., producing the desired results. Your CASS will be your principal source of information that might indicate a needed change to your maintenance schedule. (CASS is described in chapter 11 of this AC and in much more detail in AC 120-79.)
The FAA expects you to correct any deficiencies in your maintenance schedule. Under §§ 121.373(b) and 135.431(b), if you do not make needed changes, the FAA can require you to change your maintenance schedule or any other element of your maintenance program found deficient.
602. MAINTENANCE SCHEDULE CONTENTS.
a. Your maintenance schedule should contain at least the following information:
(1) What (Unique Identifier). This is the item that you are going to maintain. Your identifier should be specific enough to allow the item to be easily and accurately identified by the individual assigned to do the scheduled maintenance task.
(2) How (Task). How to maintain the item; the scheduled maintenance task to be done.
A scheduled maintenance task is a maintenance action that you perform at regular, scheduled intervals so that you can ensure the item can continue to perform its intended function within its operating context, or so you can discover a hidden failure, or to ensure that a hidden function is available. You should not use terms such as hard time, on-condition, or condition monitored in your maintenance schedule. These terms represent obsolete 1960s methodology, are vague, and do not describe the maintenance task you are performing. If your maintenance schedule contains these terms, there is a risk that the scheduled maintenance you want and need may not be the maintenance that is being performed.
(3) When (Frequency). The time-in-service interval between the times when you accomplish a scheduled maintenance task. Your intervals are measured in time in service and may be measured by calendar time, operational hours, flight cycles, or any other appropriate parameter. In addition, for task management, inventory, and audit purposes, you should identify, on the maintenance schedule, the task or work card associated with each scheduled maintenance
Page 20 Par 602 task. This way, you can ensure that all of your scheduled maintenance tasks are being accomplished according to your schedule.
b. Your overall maintenance schedule objective is to correctly do the correct tasks at the correct interval. Keep in mind that more maintenance is not always a good idea, so if you decide to decrease intervals or add tasks, you should go through the same justification process as any other change to the maintenance schedule.
603. STANDARDS FOR DETERMINING MAINTENANCE TIME LIMITATIONS.
a. As we mentioned in paragraph 600 earlier, §§ 119.49 and 121.135 permit you to have standards for determining your maintenance time limitations. In the past, this language was used as the regulatory basis for FAA-approved reliability programs that evolved during the 1960s.
These programs were based on the Air Transport Association of America’s (ATA) now obsolete process-based Maintenance Steering Group – 2nd Task Force (MSG–2) decision logic that focused on failure rates and maintaining individual parts of the aircraft. Consistent with the continuous evolution of aviation, MSG–2 became obsolete in 1980 with the advent of ATA’s task-based Maintenance Steering Group – 3rd Task Force (MSG–3) decision logic. MSG–3 focused on aircraft systems and a loss of function rather than an individual part failure. In any case, the management of these MSG–2 process-based programs was actuarial analysis. Air carriers used the failure rates of a part to determine, through a probability process, the likelihood that the part would have a similar failure rate in the future. The standard was the acceptable failure rate. Air carriers used a failure rate alert program with upper control limits (UCL) and lower control limits (LCL) to track part failure rates. The air carrier was obliged to take action only when the failure rate deviated from the probability-based prediction, i.e., exceeded the UCL or the LCL. If the part did not respond, the air carrier was authorized to move the UCL or LCL to make the failure rate within the alert program limits.
b. During the 1970s, after collecting a large amount of operational data over time, the industry came to the realization that using failure rates and alert programs was not the most effective way of managing scheduled maintenance. Using the vast amount of operational data that was available, United Airlines developed and published a report during 1978 under a U.S.
Department of Defense contract entitled “Reliability Centered Maintenance (RCM).” This very significant document was in stark contrast to the previous part failure rate focus. RCM focused on the loss of function of an aircraft system. RCM determined that everything doesn’t fail the same way; failures occur according to six different failure patterns. RCM also determined that everything doesn’t require the same type of maintenance; there are four different types of scheduled maintenance. RCM also took into account the different consequences (safety, operational, and economic) of a loss of function, as well as system functional redundancy and inherent design safety when determining if scheduled maintenance was required. In some cases, RCM determined that no scheduled maintenance was required. This resulted in doing only required maintenance, and a much lower maintenance burden.
c. The RCM document was the major basis for the ATA’s development of the MSG–3 decision logic in 1980. Since then, most aircraft manufacturers have used the Air Transport Association’s MSG–3 decision logic to help them develop scheduled maintenance requirements for their new products. Besides providing organization and flow to the deliberative process, the
Par 603 Page 21 (and 22) primary attribute of the MSG–3 process is that the user can develop initial scheduled maintenance requirements without the operational data that is required to determine the need for scheduled maintenance tasks. Using the techniques of the MSG–3 decision logic, it is fairly simple to decide what tasks are required to be included in an initial scheduled maintenance program. However, the MSG–3 decision logic does not contain task interval selection decision logic to help the user determine where to set the task intervals, or how to adjust them after service is initiated. Using the MSG–3 process, initial task intervals are set on the basis of knowledge of the design, and the best judgment of the working group members. Under MSG–3, initial intervals are, essentially, a best guess. As a result, validation of initial interval selections must occur when the aircraft begins service and starts generating the operational data that was not available when the initial intervals were set.
d. An inherent function of your CASS is to determine the effectiveness of your scheduled maintenance effort through operational data collection and analysis activity. You use this important function to determine the level of scheduled maintenance effectiveness and to make the changes necessary to achieve the standard of effectiveness that you have set. Effective means: “it is producing the desired results.” Thus, from an operational standpoint, an indicator of effectiveness of your scheduled maintenance effort is the availability of your aircraft for flight operations. If your aircraft are unavailable for flight operations due to maintenance reasons, then your scheduled maintenance program may not be as effective as it should be. There may be other elements of your maintenance program besides the scheduled maintenance element that may be deficient as well, but your CASS procedures will identify the root cause and help you identify and make the adjustments/changes necessary to achieve the level of flight operations availability (the result) that you have set.
Par 700 Page 23 (and 24) CHAPTER 7. REQUIRED INSPECTION ITEMS
700. REQUIRED INSPECTION ITEMS.
a. Sections 121.369(b) and 135.427(b) require you to designate certain tasks as Required Inspection Items (RII). Your RIIs cover at least those maintenance tasks that, if not properly performed or if done with improper parts or materials, could result in a failure, malfunction, or defect that would endanger the continued safe flight and landing of your aircraft. In case maintenance tasks are performed for you by other persons, you may authorize them to accomplish your RII requirement. However, you must document the arrangement and control it through your maintenance manual. Consistent with the regulations, you remain primarily responsible for the performance of each RII accomplished by the other person.
b. RIIs relate directly to flight safety. Consider all your RIIs with the same safety of flight consideration and emphasis even if accomplishing an individual RII adversely impacts your flight schedule, or is related to a scheduled or an unscheduled task or arises at an awkward time or at an inconvenient location.
701. RII PROCEDURES, STANDARDS, AND LIMITS.
a. Your manual must include procedures for you to identify and authorize RII personnel, both within your organization and within other organizations that perform maintenance on your behalf (§§ 121.369(b)(3) and 135.427(b)(3)). Each individual that you grant an RII authorization to must hold an appropriate airman’s certificate. This is an air carrier qualification requirement;
the individual certificate is not exercised when accomplishing the RII. You must formally notify each of these individuals of their RII authorization as well as its scope (§§ 121.371(d) and
135.429(e)).
b. You should clearly identify your RII requirements on work forms, job cards, engineering orders, and the like, 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. Therefore, it is important that you identify RIIs whenever possible so that everyone knows that an RII is required.
c. You must have those procedures, standards, and limits necessary for the accomplishment of your required inspections. You must also have those procedures, standards, and limits necessary for the acceptance or rejection of each of your required inspection items. As you will not find required inspection items or procedures, standards, and limits for required inspection items in an OEM manual, you will have to develop these and put them in your manual.
d. You must have procedures in your manual to ensure that only a supervisor of an inspection unit or the person who has overall responsibility for both the RII function and other maintenance and alteration functions may countermand the decision of any RII inspector regarding an RII (§§ 121.369(b)(8) and 135.427(b)(8)). These requirements apply equally to an organization performing maintenance on your behalf, as well as your own maintenance organization. See Figure 4-1 for a representative organizational chart.
Par 800 Page 25 CHAPTER 8. MAINTENANCE RECORDKEEPING SYSTEM
800. REASONS FOR MAKING AND KEEPING MAINTENANCE RECORDS. Your primary reason to make and retain air carrier maintenance records is to show that the U.S.
Standard Airworthiness Certificate on your aircraft is effective and that your 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. If your required aircraft maintenance records are incomplete or inaccurate, it can render your aircraft’s Standard Airworthiness Certificate ineffective. Maintenance actions, in almost all cases, become intangible or abstract after the fact. Therefore, in order for you to make a maintenance action tangible, you must make a record of that maintenance action. Additionally, making a record of certain summary information supports identification of the current inspection and airworthiness status of your aircraft.
801. PART 43 REQUIREMENTS. You can find the basic requirement to make a maintenance record in § 43.9(a); however, § 43.9(b) indicates that the governing requirements for you, an air carrier, are found in part 121 or part 135. That is another way of saying that the recordkeeping requirements of part 43(a) do not apply to you. However, the requirements of § 43.9(b) are consistent with the air carrier maintenance recordkeeping requirements of §§ 121.369(c) and
121.380(a) and (c), or §§ 135.427(c) and 135.439.
802. WORK PERFORMED BY A PART 145 REPAIR STATION.
a. Section 145.219 sets forth requirements for a certificated repair station to retain certain records of maintenance that it performs. It also requires the repair station to make those records available to the FAA. However, these §§ 43.9(a) and 145.219 requirements do not apply when the repair station is accomplishing any work on your aircraft.
b. The wording of the § 145.205, regulations as well as §§ 119.1(c), 121.1(b) and
135.1(a)(2) compel a part 145 certificated repair station to follow the procedures and requirements of your maintenance program and applicable sections of your maintenance manual when accomplishing any maintenance or alterations on your aircraft. Consequently, a certificated repair station must use the performance standards of part 121 or part 135, including the recordkeeping requirements, instead of following the provisions in part 145 and the repair station’s repair station manual. This is consistent with the requirements of The Paperwork Reduction Act which does not permit the government to require two separate, but identical sets of records. The responsibility for retaining records in accordance with the retention requirements of §§ 121.380(c) and 135.439(b) rests with you, the air carrier, not the repair station. However, if a part 145 repair station wants to retain a copy of those records generated by working on your aircraft, the FAA’s regulations do not preclude them from doing so. Asking the part 145 repair station to keep your records for you is consistent with regulations, although you are responsible for retaining them and making them available to the FAA. This is consistent with the requirements of § 119.59(c).
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803. PENALTIES FOR IMPROPER AIR CARRIER MAINTENANCE RECORDKEEPING.
a. Maintenance records are important for:
(1) You as operator to fulfill your responsibility to determine the airworthiness status of your aircraft.
(2) The FAA to use them for its continuing review of aircraft maintenance records as a direct means of determining the airworthiness and safety status of air carrier aircraft.
b. Because reviewing maintenance records is often 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.
804. MAKING AND KEEPING REQUIRED RECORDS.
a. FAA regulations (§ 121.369(c) or § 135.427(c)) 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 maintenance manual. The primary objectives of these systems are 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 your aircraft is airworthy and capable of safe flight.
b. FAA regulations (§ 119.59(b)(1)(ii)) also require you to make and keep a listing that identifies the location of each record, document, and report that you are required to make and keep, as well as a listing that identifies each person that is responsible for each of those records, documents, and reports.
805. REQUIRED AIR CARRIER MAINTENANCE RECORDS. Current requirements found in §§ 121.380 and 135.439 call for two types of records: a list of summary information and air carrier Airworthiness Release Form records.
806. WHEN TO MAKE RECORDS AVAILABLE TO THE FAA. Section 119.59(c) mandates you must make your air carrier maintenance records available to the FAA. The FAA can require you to make your records available to them at any time.
807. RESPONSIBILITY FOR MAKING RECORDS AVAILABLE TO THE FAA. Under § 119.59(b)(1), you must make a list of persons in your organization that you have designated to be responsible for making each required maintenance record, document, or report available to the FAA upon request. You must make a list of the location of each record, document, or report.
You must keep this list current and make it available to the FAA at your principal base of operations.
Par 808 Page 27
808. REQUIRED RECORDS. You are required to make and keep certain summary status records. Summary current status recordkeeping requirements are listed in §§ 121.380 and
135.427 and explained as follows:
a. Total Time in Service. The total time in service of the airframe, each installed engine, and each installed propeller is a record that contains the time in service accrued since new or rebuilt, expressed in hours, landings, or cycles.
NOTE: It is important for you to know that rebuilt does not have the same meaning as overhauled.
b. Current Status of Each Life-Limited Part. 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:
(1) Time in service since new, expressed in the appropriate parameter (hours, cycles, calendar time);
(2) The time in service remaining to the specified life limit expressed in the appropriate parameter (hours, cycles, calendar time);
(3) The specified life limit expressed in the appropriate parameter (hours, cycles, calendar time); and
(4) A record of any action that alters the part’s life limit or changes the parameter of the life limit.
NOTE: If you conduct operations under part 135, total time in service and the current status of life-limited parts also includes rotors.
c. Time Since Last Overhaul. The listing of the time since last overhaul means a record that contains at least the following information:
(1) An identification of the item that requires overhaul and its associated scheduled overhaul interval,
(2) The time in service since the last overhaul was accomplished,
(3) The time in service remaining until the next scheduled overhaul, and
(4) The time in service when the next scheduled overhaul is due.
NOTE: The listing of time since last overhaul refers to summary current status information. You must not confuse it 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.
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d. Current Inspection Status of the Aircraft. 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 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 until the next accomplishment of each of the scheduled inspection packages and tasks required by the maintenance program under which the aircraft is maintained; and
(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. Current Status of Applicable Airworthiness Directives (AD). The current status of applicable ADs 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 when the required action was accomplished and the time in service expressed in the appropriate parameter (hours, cycles, calendar time).
(4) If the requirement is recurring, the date when the next action is due, and the time in service expressed in the appropriate parameter (hours, cycles, calendar time).
(5) With regard to an AD, the method of compliance means 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 AD or method of compliance must not be confused with an AD record of accomplishment, which is a description of the work and who performed it and/or issued the approval for return to service.
f. The current major alterations of each airframe, engine, propeller, and appliance. A listing means a record that contains at least the following information:
Par 808 Page 29
(1) A listing identifying each major alteration, as well as the associated item to which the major alteration has been installed, and
(2) A description of, or reference to, the FAA-approved technical data used to make the major alteration.
NOTE: If you conduct operations under part 135, you must include in this listing, all current major repairs, as well as major alterations, and you must include major repairs and major alterations to each rotor.
NOTE: The listing of the current major alterations refers to summary current status information. You must not confuse this with a major alteration report, which is a description of the work performed, a description of the FAA-approved technical data used to make the major alteration, and the identification of the individual who performed and/or issued the approval for return to service. You must not confuse this listing 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 Form have been met. These records support the use of an Airworthiness Release Form, which is not part of the aircraft maintenance logbook. 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 last overhaul for items that required an overhaul, NOTE: An overhaul record is not required to contain a record of AD accomplishment. The regulations require separate records of AD current status. The regulations also require that the record of AD accomplishment be kept, but for only one year.
(3) Detailed records of all unscheduled maintenance that has not been superseded by work of equivalent scope and detail, and
(4) Copies of the Airworthiness Release Form covering the last 60 days of operation.
809. OTHER REQUIRED RECORDS AND REPORTS. The FAA regulations require you to make other reports and records as discussed in this paragraph. 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 elements of your maintenance program. These records are one of the sources of information for your CASS. The FAA also uses these reports in its continuous oversight of your maintenance program activities.
a. Maintenance Log. Sections 121.701 and 135.65 require any person who takes action in response to a reported or observed failure or malfunction to make a record of that action in the