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• ALs,
• CMRs,
• Supplemental Structural Inspection Documents (SSID), and
• Electrical wiring interconnection system (EWIS).
(2) How (Task). This is how you should maintain the item you are going to maintain, or the scheduled maintenance task you will perform. A scheduled maintenance task is a maintenance action that you perform at regular, scheduled intervals. The intent of this task is to ensure the item can continue to perform its intended function, allows you to discover a hidden failure, or to ensure that a hidden function is available. You should not use terms such as hard-time (HT), on-condition, or condition monitored in your maintenance schedule. The maintenance schedule should state the maintenance task to be performed to meet the requirement
(e.g., Replace, Inspect, and Test).
(3) When (Timing). You should accomplish scheduled maintenance tasks (one-time or repetitive) at an acceptable time in service. You may measure time in service in calendar-time, operational hours, flight cycles, or any other appropriate parameter.
b. Maintenance Schedule Objective. Your overall maintenance schedule objective is to 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.
c. Maintenance Schedule Best Practice. For task management, inventory, and audit purposes, you should identify, on the maintenance schedule, the task or work card associated with each scheduled maintenance task. This way you can ensure that you accomplish all of your scheduled maintenance tasks according to your schedule.
6-4. STANDARDS FOR DETERMINING MAINTENANCE SCHEDULES. As we mentioned in paragraph 6-1, §§ 119.49 and 121.135 permit you to have standards for determining your maintenance time limitations. In the past, we used this language 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 the ATAs 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 on 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 had authorization to move the UCL or LCL to make the failure rate within the alert program limits.
Par 6-4 Page 21
a. Reliability Centered Maintenance (RCM). 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. DOD 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 does not fail the same way; failures occur according to six different failure patterns.
RCM also determined that everything does not 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.
b. MSG–3 Decision Logic. 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 ATA’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 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 MRBR working group members. 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.
c. Effective Scheduled Maintenance. 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.
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d. MRBR Changes. MRBR revisions are developed to address global in-service experience in addition to reflecting new design configurations and new rules. Therefore, when MRBR revisions occur, you should review them and determine if they necessitate a change in your maintenance schedule based on your particular needs, experience, and program’s goals and philosophy.
e. Failure Effect Categories (FEC). While you may make changes to your maintenance schedule, it is important for you to consider the task FEC that arises from application of the MSG-3 logic used to develop the MRBR (since this helps identify the relative criticality of the task). You should not delete or change the scope of MSG-3 FECs 5 (Evident Safety) and 8 (Hidden Safety) tasks without the concurrence/approval of the FAA Maintenance Review Board (MRB) Chairman and the OEM/type-certificate holder (TCH).
NOTE: To protect the identity and significance of a safety-related task, you should identify each task in your maintenance schedule that is a CMR, AL, or those with FECs 5 and 8.
Par 7-1 Page 23 CHAPTER 7. REQUIRED INSPECTION ITEMS
7-1. RIIs.
a. Tasks as RIIs. Sections 121.369(b) and 135.427(b) require you to designate certain tasks as RIIs. Your RIIs must include at least those tasks that could result in a failure, malfunction, or defect that endangers the safe operation of the aircraft if the task is not completed properly or if you use improper parts or material. If other persons perform maintenance tasks for you, you may authorize them to accomplish your RII requirement, provided that your manual satisfies the regulatory requirements, as outlined in paragraph 7-2.
Consistent with the regulations, you remain primarily responsible for the performance of each RII accomplished by the other person.
b. Making RII Lists. Your RII lists should identify specific items of maintenance for each aircraft type you operate. It is inappropriate to designate entire systems as RIIs. You should adhere to a decision process, similar to the following, when creating a list of RIIs:
Page 24 Par 7-1 FIGURE 7-1. REQUIRED INSPECTION ITEMS
Par 7-1 Page 25 (and 26)
c. RIIs and Safety. 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, it is related to a scheduled or an unscheduled task, or it arises at an awkward time or at an inconvenient location.
7-2. RII PROCEDURES, STANDARDS, AND LIMITS.
a. List of Other Persons. Your manual must include a list of persons with whom you have arranged for the performance of any required inspections (§§ 121.369(a) and 135.427(a)) both within your organization and within other organizations that perform maintenance on your behalf. This listing must include a designation by occupational title of the personnel authorized to perform each required inspection (§§ 121.369(b)(3) and 135.427(b)(3)).
b. Certification. With consideration of the exception at §§ 121.378(a) and 135.435(a), 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 does not exercise that certificate 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)).
c. RII Requirements. You should clearly identify your RII requirements on work forms, job cards, engineering orders, etc., or by any other method consistent with your maintenance program. A primary concept of the RII function is to prevent any person who performs any item of work from performing any required inspection of that work (§§ 121.369(b)(7) and 135.427(b)(7)). Therefore, it is important that you identify RIIs whenever possible so that everyone knows that an RII is required. You should also clearly state RII buy-back procedures (§§ 121.369(b)(4) and 135.427(b)(4)).
d. Standards and Limitations. You must set procedures, standards, and limits necessary for required inspections and acceptance or rejection of the RII (§§ 121.369(b)(5) and 135.427(b)(5)). You should 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 RIIs. As you will not find RIIs or procedures, standards, and limits for RIIs in an OEM manual, you will have to develop these and put them in your manual. Your manual must specify the method of performing required inspections (§§ 121.369(b)(3) and 135.427(b)(3)).
e. Procedures. Your manual must include procedures to ensure that you perform and complete all required inspections (§§ 121.369(b)(6) and 135.427(b)(6)) before you release the aircraft to service (§§ 121.369(b)(9) and 135.427(b)(9)).
Par 8-1 Page 27 CHAPTER 8. MAINTENANCE RECORDKEEPING SYSTEM
8-1. 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 U.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.
8-2. 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 135. That is another way of saying that the recordkeeping requirements of § 43.9(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.
8-3. WORK PERFORMED BY A PART 145 REPAIR STATION.
a. Retaining Records. Part 145, § 145.219 sets forth requirements for a CRS 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. Copies of Records. 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 CRS 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 CRS must use the performance standards of part 121 or 135, including the recordkeeping requirements, instead of following the provisions in part 145 and the repair station’s Repair Station Manual (RSM).
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, our 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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8-4. 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; and
(2) Us, 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. Reviewing Maintenance Records. 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.
8-5. MAKING AND KEEPING REQUIRED RECORDS.
a. Recordkeeping System. FAA regulations (§ 121.369(c) or § 135.427(c)) require you to have and use a recordkeeping system for the preservation and retrieval of all work performed on your aircraft. 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 that your aircraft is Airworthy and capable of safe flight.
b. Record Locations. 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.
c. ADs. FAA regulations (§§ 121.380(a)(2)(vii) and 135.439(a)(2)(v)) also require you to keep a record of the current status of applicable ADs, including the date and methods of compliance, and, if the AD involves recurring action, the time and date when the next action is required.
8-6. REQUIRED AIR CARRIER MAINTENANCE RECORDS. Current requirements found in §§ 121.380 and 135.439 call for two types of records: a list of current status information, and air carrier airworthiness release form records.
8-7. WHEN TO MAKE RECORDS AVAILABLE TO THE FAA. Section 119.59(c) mandates that you must make your air carrier maintenance records available to us. We can require you to make your records available to us at any time.
Par 8-8 Page 29
8-8. 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.
8-9. REQUIRED RECORDS. You are required to make and keep certain current status records. Current status recordkeeping requirements are listed in §§ 121.380 and 135.439 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” (§ 43.2(b)).
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 is due, and
(4) The time in service when the next scheduled overhaul is due.
Page 30 Par 8-9 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 RTS.
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 ADs. 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 applies;
(2) The AD number (and/or regulatory amendment number);
(3) For new ADs, the time when the AD action is due, expressed in the appropriate parameter (hours, cycles, calendar-time);
(4) The date when the required action was accomplished and the time in service expressed in the appropriate parameter (hours, cycles, calendar-time);
(5) If the requirement is recurring or not due yet, the date when the next action is due, and the time in service expressed in the appropriate parameter (hours, cycles, calendar-time); and
(6) 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 SB permits the use of more than one method of compliance, the record must include a reference to the specific method of compliance used. If you use an AMOC to comply with an AD, the method of compliance means a description of the AMOC and a copy of the FAA approval.
Par 8-9 Page 31 NOTE: You should not confuse the current status listing of an AD or method of compliance with an AD record of accomplishment, which is a description of the work and who performed it and/or issued the approval for RTS. They are two separate and distinct records.
f. Current Major Alterations of Each Airframe, Engine, Propeller, and Appliance.
A listing means a record that contains at least the following information:
(1) A listing identifying each major alteration, as well as the associated item that has been altered, and
(2) A description of, or reference to, the FAA-approved technical data that you 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 RTS. You must not confuse this listing with the requirement to submit a copy of each report of a major alteration to the FAA. There are two different requirements—one for a major alteration current status listing, and one for a report for each major alteration that you accomplish.
g. Airworthiness Release Form. 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,
(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.