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1-5. MAINTENANCE PROGRAM AUTHORIZATION. We do not approve your maintenance program. There is no regulation that requires an approval. However, we do issue air carrier operations specifications (OpSpecs) to you that authorize you to use a maintenance program and the air carrier maintenance manual required by FAA regulations. This method for authorizing operations and maintenance in air transportation evolved from the Civil Aeronautics Board’s (CAB) 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 part of your air carrier operating certificate. We, or you, could amend them as the circumstances dictated. In 1953, we amended the Civil Air Regulations (CAR) to require the issuance of air carrier OpSpecs that replaced, formalized, and standardized the competency letters that we used at the time. We also amended the regulations to state that OpSpecs were not part of your air carrier certificate. Tailored to your specific operating context and the requirements of your individual operations, we use OpSpecs to 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 us, the terms, conditions, and limitations contained in OpSpecs are made mandatory through specific regulatory language. (Refer to part 119, § 119.5 for the applicable language.)
1-6. AIR CARRIER MAINTENANCE PROGRAM OBJECTIVES.
a. Program Objectives. Your maintenance program must ensure that three specific program objectives are achieved in order to provide the highest possible level of safety in air transportation:
(1) Each of your aircraft that you release to service must be Airworthy and properly maintained for operations in air transportation;
(2) You, or any other person, perform all of the maintenance and alterations on your aircraft in accordance with your maintenance manual; and
(3) You, or any other person, provide competent personnel, and adequate facilities and equipment to perform maintenance and alterations on your aircraft.
b. Continuing Analysis and Surveillance System (CASS). Your maintenance program should also have a system of continuing surveillance, investigation, data collection, analysis, corrective action, and corrective action followup that ensures all parts of your maintenance program are effective and are being performed in accordance with your manual. “Effective” means that you are achieving the desired results according to the maintenance program objectives and the standards that you, the air carrier, set. Program performance means that all personnel are following your program as you have documented it in your manual.
1-7. AIR CARRIER MAINTENANCE PROGRAM ELEMENTS. Your air carrier maintenance program includes the following 10 elements. We explain 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. If another AC exists, we will not explain that element in depth.
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• 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
• CASS.
Par 2-1 Page 5 CHAPTER 2. AIRWORTHINESS RESPONSIBILITY
2-1. RESPONSIBILITY FOR AIRCRAFT MAINTENANCE.
a. Part 119 Certificate Holder Responsibilities. Consistent with §§ 121.363 and 135.413, you, as a part 119 certificate holder, are primarily responsible for the airworthiness of your aircraft, and the performance of all of the maintenance or alterations on your aircraft.
Your air carrier certificate makes you a maintenance entity. Under your air carrier certificate, you accomplish your own maintenance, preventive maintenance, or alterations, or you can use other persons who are not direct employees to accomplish that work. Consistent with our regulations in §§ 121.1(b) and 135.1(a)(2), the part 121 or 135 regulations govern each person that you use or that you employ for any maintenance, preventive maintenance, or alteration of your aircraft. Each of these persons that you use must be under your direction and control and must follow your maintenance program.
b. Maintenance Responsibilities. For any work done on your aircraft, you retain direct and primary responsibility for performing and approving all maintenance and alterations, whether you accomplish that work or whether someone else does it for you, such as a repair station. However, you always retain primary responsibility for the performance and approval of the maintenance done by that maintenance provider.
2-2. DIFFERENCES BETWEEN PROGRAMS. The following table provides a comparison of the differences between air carrier maintenance programs and part 91 General Aviation (GA) inspection programs.
TABLE 2-1. MAINTENANCE PROGRAM AND INSPECTION PROGRAM
DIFFERENCES 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 (14 CFR part 91, § 91.403).
NOTE: The wording in part 91 is deliberately different from the wording in 14 CFR parts 121 and 135 and is consistent with the difference between air transportation and other air commerce described in 49 U.S.C. § 44701.
Responsibilities within the relevant program.
Responsible for the development and use of the maintenance Responsible for the selection of an existing inspection program and the
Page 6 Par 2-2 program and manual, determining the method of performing maintenance, a required inspection list, a Continuous Analysis and Surveillance System (CASS), a 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.
scheduling of aircraft for the inspections, and for ensuring that discrepancies that occur between scheduled inspections are repaired.
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 (RTS). 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 (part 121, § 121.363 or part 135, § 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 RTS. 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 received approval for RTS.
Par 3-1 Page 7 CHAPTER 3. AIR CARRIER MAINTENANCE MANUAL
3-1. AIR CARRIER MAINTENANCE MANUAL REQUIREMENT.
a. Maintenance Manuals. Our regulations (§§ 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.” Some use other terms.
b. Revising Maintenance Manuals. 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 or in another form.
c. Availability. You must make copies of your manual, or appropriate portions of it, available to those persons required to comply with it, including any changes or additions. Each person, including us, who you furnish a manual or appropriate parts to, must keep it up to date.
d. Other Related Regulations. Other regulations that relate to your manual requirements are part 43, § 43.13(c), and §§ 121.135, 121.137, 135.23, and 135.427.
3-2. ROLE OF YOUR AIR CARRIER MAINTENANCE MANUAL.
a. Standardization. Your maintenance manual is your key to standardized, consistent accomplishment and administration of your maintenance program. Your maintenance manual:
(1) Identifies, describes, and defines your maintenance program, and
(2) Provides instructions and procedures to administer, use, manage, and amend your program.
b. Organization and Format. 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.
c. Contract Maintenance. Air carriers normally write their manual to address their employees. However, if the air carrier chooses to use another person to perform maintenance for it, the air carrier must ensure their manual requirements address the use of the other person.
3-3. MAJOR SECTIONS OF THE TYPICAL AIR CARRIER MAINTENANCE MANUAL. Your maintenance manual should have a practical organization. Typically, it will have at least three sections: the first covering administrative policies and procedures; a second covering detailed instructions for the administration, management, and accomplishment of the elements of your maintenance program; and a third covering technical data that describes maintenance standards, methods, techniques, and procedures.
a. Administrative Policies and Procedures. The primary function of this part of your manual is as a management and administrative tool for organizing, directing, amending, and controlling your maintenance program. Usually, you will place organizational charts delineating the functions, relationships, and lines of authority between your organizational elements and
Page 8 Par 3-3 personnel here. You may list position descriptions, duties, responsibilities, and specific authority and responsibility attributes for each position within your maintenance organization here. The authority and responsibility attributes that you place here should show who has overall authority and/or responsibility and who has direct authority and/or responsibility for given functions.
b. Instructions for the Administration, Management, and Accomplishment of the Maintenance Program.
(1) 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, airworthiness directive management, maintenance program management and oversight, contract maintenance management and oversight, and personnel training. This section usually includes a description of your scheduled maintenance tasks, procedural information, and detailed instructions, or specific air carrier maintenance manual references for accomplishing your 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 (hazmat) spills, hard or overweight landings, and any very high-load event.
(2) 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 you should use 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. You should consider the events listed below as most significant:
(a) Flight Events.
• A severe turbulence encounter,
• Extreme maneuvers,
• Exceedance of speed limitations, and
• Heavy stall buffet.
(b) Ground Events.
• Hard landings,
• Overweight landings, and
• Drift landings resulting in excessive side/drag load.
(3) Typically, the Original Equipment Manufacturer (OEM) will include detailed inspection instructions that you should follow following these high-load events. The objective of these instructions is to detect aircraft damage following an in-service flight or ground event.
While there are many conditions that can result in high-loads on the airframe and subsequent structural damage, we consider the use of flight data in your inspection process to be particularly beneficial for the events identified above.
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(4) Your processes for evaluating these events should address:
(a) An appropriate indication that an event has occurred,
(b) An evaluation of the severity of the event, and
(c) Coordination with the manufacturer, as appropriate. Your special inspection procedures for high-load events should be robust enough to:
• Identify that a very high-load event has occurred,
• Assure that indications of structural damage are found in an initial inspection,
• Involve the OEM if necessary,
• Provide a process for additional inspections that are designed to identify all of the structural damage, and
• Provide a process for approval for return to service (RTS).
c. Technical Data that Describe Maintenance Standards, Methods, Techniques, and Procedures.
(1) Accomplishing Specific Tasks. This section of your manual concerns detailed procedures for accomplishing specific tasks. You should describe methods, techniques, technical standards, measurements, calibration standards, operational tests, structural repairs, etc., in this section. You should also include procedures for aircraft Weight and Balance (W&B), jacking, lifting and shoring, storage, cold weather operations, towing, aircraft taxi, and aircraft cleaning.
You can derive your maintenance manual contents from the manufacturer’s publications.
However, based on your particular service experience, organization, and operating context, the FAA expects you to continuously modify and customize your maintenance manual as necessary for the continuing success of your maintenance program. This is one of the desired outcomes of a well-functioning CASS, which we explain in more detail in Chapter 11, Continuing Analysis and Surveillance System, and in the current edition of AC 120-79, Developing and Implementing a Continuing Analysis and Surveillance System.
(2) Airworthiness Directives (AD). You are required to accomplish the provisions of ADs that we issue by 14 CFR part 39. While not specifically required by any regulation, you should also include in your manual a process for managing ADs (i.e., evaluating, accomplishing, and verifying ADs). Your AD management process, as described in the current edition of AC 39-9, Airworthiness Directives Management Process, should include the following six elements: planning, support, provisioning, implementing, recording, and auditing. You may not operate your aircraft that an AD applies to except in strict compliance with the provisions of the AD. So it is extremely important that you include in your AD process provisions that ensure that:
you review ADs for applicability to your aircraft; you accomplish the requirements of the AD within the timeframe specified in the AD; you keep records of the accomplishment and current status of each AD that applies to your aircraft; and you ensure that any subsequent maintenance or alteration to your aircraft does not remove the maintenance or alteration that was mandated by the AD. If you do subsequently remove the AD-mandated maintenance or alteration, you will be in violation of part 39 and may introduce an unsafe condition in your airplane. It would also
Page 10 Par 3-3 make the required records for that particular AD inaccurate. If you determine that an alternative method of compliance (AMOC) with an AD is necessary, you should refer to the current edition of FAA Order 8110.103, Alternative Methods of Compliance (AMOC). With regard to AD recordkeeping, Chapter 8, Maintenance Recordkeeping System, contains detailed information that deals with your maintenance recordkeeping system.
d. Work Cards. Work cards, sometimes referred to as job cards or task cards, while not a specific regulatory requirement, have evolved as a best practice. We consider work cards to be part of your air carrier manual and the air carrier maintenance program. They are the “what to do” and the “how to do it” parts of your maintenance program. You use work cards as a simple means of complying with maintenance performance and recordkeeping regulations. Your work cards provide a control element to the performance of maintenance. They also provide the means of ensuring that all maintenance personnel comply with your air carrier maintenance manual. It is an easy way for you to make sure that your maintenance personnel, as well as other personnel, are following your procedures. The second primary function is to document maintenance activities, providing a means for you to comply with your air carrier maintenance recordkeeping requirements. Work cards may also document the results of inspections, checks, and tests for data collection and analysis. The work-in-progress audits that you conduct regarding work card activity as part of your CASS ensure that each individual who accomplishes work on your aircraft is following your manual.
Par 4-1 Page 11 CHAPTER 4. AIR CARRIER MAINTENANCE ORGANIZATION
4-1. MAINTENANCE ORGANIZATION—GENERAL. Your maintenance organization must be 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. Our regulations require you to include a chart or a description of your maintenance organization in your manual. You can read about maintenance organization requirements in part 121 subpart L, part 135 subpart J, and portions of part 119 subpart C. These organizational regulations apply to your organization, as well as any other organization that provides maintenance services for you. A chart is a good way to show your assignment of overall and direct authorities and responsibilities.
4-2. REQUIRED MAINTENANCE ORGANIZATION MANAGEMENT POSITIONS.
Section 119.65 includes specific requirements for maintenance management positions for operations under part 121. These are a Director of Maintenance (DOM) and a chief inspector, or equivalent positions. These are management positions required by the regulations. However, you may need more management positions to administer and manage your maintenance organization.
a. Part 121 and 135 Required Positions. For operations conducted under part 121, § 119.65 requires you to have qualified individuals serving full-time in the DOM and chief inspector, or equivalent, positions. If necessary for your operation, you can ask the FAA for a deviation from the types and numbers of required part 121 or 135 management positions.
b. Chief Inspector. For operations conducted under part 135, § 119.69 requires you to have a qualified individual serving in the DOM management position. There is no regulatory requirement for a part 135 chief inspector management position. However, in a practical sense, you will have an individual in your part 135 maintenance organization who has direct responsibility for the RII function, as well as those other duties, responsibilities, and functions normally associated with a part 121 chief inspector.
c. Management Personnel. The regulations require you to state the duties, responsibilities, and authority of each of your management personnel in your manual. You should state who has overall authority and/or responsibility, and who has direct authority and/or responsibility for a given process. Also, you must notify the FAA when you make changes in your part 119-required management personnel or when you have a vacancy in one of those positions.
NOTE: “Authority” means the power to design or change fundamental policy or procedures without having to seek higher level approval. Authority is permission; it is a right coupled with an autonomous power to accomplish certain acts or order others to act. Often one person grants another authority to act, such as an employer to an employee, a corporation to its officers, or a governmental empowerment to perform certain functions.
NOTE: “Responsibility” means the obligation to ensure a task or function is successfully carried out. Responsibility includes accountability for the action to carry out a task or function.
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4-3. REQUIRED AIR CARRIER MAINTENANCE ORGANIZATIONAL STRUCTURE.
a. Structure. We wrote the regulations defining an air carrier maintenance organization necessarily broad given the different types and sizes of air carriers. A single means of compliance or a single organizational chart that would apply to all the different types and sizes of air carrier organizations is not possible.
b. Accountable Manager. You should designate an individual or position as the accountable manager with the authority and the overall responsibility for managing and implementing your entire maintenance program, including all inspection functions. The individual you designate must meet the qualifications for the Director of Maintenance listed in § 119.67(c) or § 119.71(e), as applicable. The inspection functions and the required inspection functions are part of your maintenance program.
c. Organizational Functions. The FAA recommends your maintenance organization have three general organizational functions to ensure that you conduct all operations to the highest possible degree of safety. If you are a larger organization, you may have different departments for each level, while in the smallest organizations, you may carry out these functions through one or two individuals, maybe as a collateral duty. Generally, these three organizational functional levels include:
(1) Mechanics and/or inspectors performing the work at the first level (operations);
(2) Middle managers and supervisors at the second level (tactics); and
(3) The maintenance program accountable manager at the third level (strategy).
d. Authority and Responsibility. We expect you to assign clear authority and responsibility in your maintenance organization, including delegated responsibility, for the overall maintenance program and all of its elements and functions. You should include a position description that includes each position’s duties and responsibilities in your manual so that there is not a fragmented organizational system with a high risk for confusion over who is responsible for a given element, process, or task. Watch out for hidden duties and responsibilities where the duty and/or responsibility is shown in a process but not in the position description.
4-4. SEPARATION OF INSPECTION AND MAINTENANCE DEPARTMENTS.
a. Regulatory Requirements.
(1) If you perform maintenance (other than required inspections), §§ 121.365(a) and 135.423(a) require you to have an organization that is adequate to perform maintenance work. Additionally, if you perform required inspections, §§ 121.365(b) and 135.423(b) require you to have an organization that is adequate to perform required inspection work.
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(2) Don’t confuse your maintenance production department with your maintenance organization. Also, don’t confuse your inspection department, if you have one, with your required inspection organization. We have defined “maintenance” in § 1.1 as “inspection, overhaul, repair, preservation, and the replacement of parts, but excluding preventive maintenance.” We do not define required inspection in § 1.1. However, within the context of parts 121 and 135, the term “required inspection” has a very specific regulatory meaning and should not be confused with the general use of the word “inspection” throughout the regulations.
(3) While there is no regulatory requirement to separate the maintenance organization from the required inspection organization, there is a requirement when performing both maintenance and required inspection work to organize the performance of those functions so as to separate the maintenance function from the required inspection function.
b. Organization. Regulations require you to organize the performance of all maintenance functions, including inspection, repair, overhaul, and the replacement of parts, to separate the function of required inspections from the function of the other maintenance, preventive maintenance, and alteration activities. This organizational separation must be below the level of administrative control where you exercise overall responsibility for the required inspection functions as well as the other maintenance, preventive maintenance, and alteration functions.
Consistent with subparagraph 4-3b, your accountable manager exercises overall authority and responsibility over the required inspection functions, as well as the other maintenance (including inspection), preventive maintenance, and alteration functions. Refer to Figure 4-1, Maintenance Organizational Chart, for a representative organizational chart.
FIGURE 4-1. MAINTENANCE ORGANIZATIONAL CHART Maintenance Organization Accountable Manager Overall authority and responsibility for both RII and other maintenance and alteration functions Maintenance Department Responsible Manager Direct responsibility for maintenance, preventive maintenance and alteration functions Required Inspection Organization Responsible Manager Direct responsibility for RI functions Mechanic RII Inspectors Page 14 Par 4-4