U.S. Department of Transportation Federal Aviation Administration Advisory Circular Subject: Air Carrier Maintenance Programs Date: 11/15/12 Initiated by: AFS-300 AC No: 120-16F Change:
This advisory circular (AC) explains what the term “maintenance program” means. Our explanation describes the scope and content of air carrier aircraft maintenance programs. This is important as there is a significant difference between an air carrier maintenance program and an inspection program used in non-air carrier maintenance operations. We explain the background of these programs as well as the Federal Aviation Administration’s (FAA) regulatory requirements. We also describe and explain each of the 10 elements of air carrier maintenance programs. When we use “must” or “will” in this AC, we are referencing actual regulatory requirements. When we use “we,” “us,” or “our” in this AC, we mean the FAA. When we use “you,” “your,” or “yours,” we mean you, the air carrier. When we use the term “person,” it has the same meaning as that in Title 14 of the Code of Federal Regulations (14 CFR) part 1, § 1.1.
This AC is one method of compliance with the requirements of the regulations. Instead of following this method, you may elect to follow an alternate method, provided that your method is acceptable to us. Because the method of compliance that we present in this AC is not mandatory, the term “should” applies only if you choose to follow this particular method without deviation. You should tailor your maintenance program to your specific operation; therefore, we are not providing a single means of compliance that applies to all operators required to have a maintenance program. We have included information in this AC about our expectations regarding your implementation of an air carrier maintenance program. We based these expectations on our regulations. As required by 14 CFR part 121, § 121.367 and part 135, § 135.425, your maintenance program must ensure that each of your aircraft released to service is Airworthy and properly maintained for operations in air transportation; that you provide competent personnel, adequate facilities, and equipment; and that everyone who works on your aircraft follows your manual and your program.
In addition to strict compliance with the part 121 or 135 regulations, we encourage you to consider additional processes and methodologies for use in your maintenance program, such as industry best practices or other government guidance relevant to maintenance, preventive maintenance, and alteration activities.
ORIGINAL SIGNED by /s/ John M. Allen Director, Flight Standards Service
CONTENTS Paragraph Page
CHAPTER 1. GENERAL INFORMATION1
1-1. Purpose1
1-2. Cancellation1
1-3. Audience1
1-4. Legal Basis for Air Carrier Maintenance Programs1
1-5. Maintenance Program Authorization3
1-6. Air Carrier Maintenance Program Objectives3
1-7. Air Carrier Maintenance Program Elements3
CHAPTER 2. AIRWORTHINESS RESPONSIBILITY5
2-1. Responsibility for Aircraft Maintenance5
2-2. Differences Between Programs5
Table 2-1. Maintenance Program and Inspection Program Differences5
CHAPTER 3. AIR CARRIER MAINTENANCE MANUAL7
3-1. Air Carrier Maintenance Manual Requirement7
3-2. Role of Your Air Carrier Maintenance Manual7
3-3. Major Sections of the Typical Air Carrier Maintenance Manual7
CHAPTER 4. AIR CARRIER MAINTENANCE ORGANIZATION11
4-1. Maintenance Organization—General11
4-2. Required Maintenance Organi zation Management Positions11
4-3. Required Air Carrier Maintena nce Organizational Structure12
4-4. Separation of Inspection A nd Maintenance Departments12
Figure 4-1. Maintenance Organizational Chart14
CHAPTER 5. ACCOMPLISHMENT AND APPROVAL OF MAINTENANCE AND
ALTERATIONS15
5-1. Accomplishment of Maintenance15
5-2. Major Repairs and Alterations15
5-3. Airworthiness Release Form or Airc raft Log Entry and Approval for RTS16
5-4. Scope of Maintenance.....................................................................................................1 6
5-5. Parts and Appliances Maintenance Program17
CHAPTER 6. MAINTENANCE SCHEDULE19
6-1. The Maintenance Schedule19
6-2. The FAA’s Role in Relation to the Maintenance Schedule19
6-3. Maintenance Schedule Contents19
CONTENTS (Continued) Paragraph Page
6-4. Standards For Determining Maintenance Schedules20
CHAPTER 7. REQUIRED INSPECTION ITEMS23
7-1. RIIs23
Figure 7-1. Required Inspection Items24
7-2. RII Procedures, Standards, and Limits25
CHAPTER 8. MAINTENANCE RECORDKEEPING SYSTEM27
8-1. Reasons for Making and K eeping Maintenance Records27
8-2. Part 43 Requirements27
8-3. Work Performed by a Part 145 Repair Station27
8-4. Penalties for Improper Air Carrier Maintenance Recordkeeping28
8-5. Making And Keeping Required Records28
8-6. Required Air Carrier Maintenance Records28
8-7. When To Make Records Available to the FAA28
8-8. Responsibility for Making R ecords Available to the FAA29
8-9. Required Records29
8-10. Other Required Records and Reports32
8-11. Requirements for Reports of Major Alterations and Major Repairs34
8-12. Requirements for Historical or Source Records35
CHAPTER 9. CONTRACT MAINTENANCE37
9-1. Maintenance Providers....................................................................................................3 7
9-2. Responsibility for Maintenance Performed by Others38
9-3. Unscheduled Contract Maintenance Pe rformed Away from Regular Facilities38
9-4. Airworthiness Release Form or Aircraft Log Entry39
9-5. Evaluating New Maintenance Providers39
9-6. Continuing Maintenanc e Provider Oversight40
9-7. Using A CRS as One of Y our Maintenance Providers40
CHAPTER 10. PERSONNEL TRAINING41
10-1. Maintenance Program Training Requirements41
10-2. Types of Training41
10-3. Initial Training41
10-4. Recurrent Training41
10-5. Specialized Training42
10-6. Maintenance Provider Training42
10-7. Competency-Based Training42
Page v (and vi) CONTENTS (Continued) Paragraph Page
CHAPTER 11. CONTINUING ANALYSIS AND SURVEILLANCE SYSTEM45
11-1. Background of the CASS45
11-2. CASS is a Safety Management Tool45
11-3. Basic CASS Processes45
11-4. Risk-Based Decisions47
11-5. Scope of A CASS47
11-6. CASS Design Principles47
11-7. CASS Personnel Requirements48
CHAPTER 12. ADMINISTRATIVE49
12-1. Whom to Contact49
12-2. Regulatory References49
12-3. Other Related Regulations and Guidance Material49
12-4. Obtaining Reference Material (current editions)50
Par 1-1 Page 1 CHAPTER 1. GENERAL INFORMATION
1-1. PURPOSE. We describe the 10 elements that comprise air carrier maintenance programs and what you should include in your air carrier maintenance program. In this advisory circular (AC), when we say “air carrier maintenance,” we mean inspection, overhaul, repair, preservation, and the replacement of parts, as well as preventive maintenance. Consistent with regulations, inspection functions are an inherent and integral part of your maintenance program;
they are not separate. Your maintenance manual is the part of your air carrier manual that describes your maintenance program.
1-2. CANCELLATION. This AC cancels AC 120-16E, Air Carrier Maintenance Programs, dated September 11, 2008.
1-3. AUDIENCE. This AC applies to you if you are a Title 14 of the Code of Federal Regulations (14 CFR) part 119 air carrier conducting operations under 14 CFR parts 121 and/or 135. For part 135 operations, this AC applies only to those maintenance operations conducted under part 135, § 135.411(a)(2), 135.411(b) and 135.411(d). 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. We have defined the meaning of “person” in 14 CFR part 1, § 1.1 as “an individual, firm, partnership, corporation, company, association, joint-stock association, or governmental entity.” This regulatory meaning of “person” includes a trustee, receiver, assignee, or similar representative of any of them. Whenever we say “person” in this AC, we mean the same as that in § 1.1.
1-4. LEGAL BASIS FOR AIR CARRIER MAINTENANCE PROGRAMS.
a. Title 49 of the United States Code (49 U.S.C.). Title 49 U.S.C. § 44701 is the primary authority for all air carrier Federal aviation regulations. Title 49 U.S.C. § 44701 instructs us to promote the safe flight of civil aircraft in air commerce by prescribing regulations and standards in the interest of safety.
b. Air Commerce. When prescribing regulations and standards, Title 49 U.S.C. § 44701 also obliges us to consider your duty to provide service with the highest possible degree of safety in the public interest, to consider differences between air transportation and other air commerce, and to classify a regulation or standard appropriate to the differences between air transportation and other air commerce. Congress has defined the term “air commerce” 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. Regulations. Consistent with the requirements of 49 U.S.C. § 44701, we regulate aircraft operations at different levels of safety. Hence, we have prescribed those regulations that govern air carrier operations (air transportation) and the operations of other air commerce with a different structure to reflect the differences between these two segments of the aviation industry.
Establishing appropriate standards and regulatory requirements is a risk management (RM) process, and the underlying legal structure provides for more than one level of acceptable risk
Page 2 Par 1-4 appropriate to different types of flight operations. We have written air transportation regulations to be all-inclusive and stand-alone, whereas the regulations governing other air commerce are not. Similarly, we wrote the scope of responsibility for those in air transportation operations very broad and not shared, whereas in other air commerce we wrote the scope of responsibility relatively narrow and 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 14 CFR parts 43, 65, 91, and 145 do not necessarily reflect the highest possible degree of safety in the public interest. We have included more specific references to relevant regulations in subsequent paragraphs.
d. Performance-based Regulations. We wrote almost all of the parts 121 and 135 maintenance regulations in a performance-based format. We used the performance-based regulatory approach because it focuses on measurable outcomes, rather than on prescriptive processes, techniques, or procedures. Performance-based regulation leads to defined results without a specific direction or specific instruction in the regulation regarding how to obtain those results. This approach permits our regulations to apply to a wide variety of certificate holders and still have the same standards. For example, our performance-based regulations in part 121, § 121.367 and § 135.425 apply equally to the 1-airplane operator and the 900 airplane operator. The defined result is always the same: an Airworthy airplane that the operator has properly maintained for operations in air transportation. Performance-based regulation also permits the regulation to remain current in the face of advances in technology or methodology.
e. Acceptable Means of Compliance (AMC). The other half of writing performance-based regulation is to explain what constitutes an AMC. We wrote this AC to show you what acceptable methods of compliance with the performance-based maintenance program regulatory requirements are. In this AC, we have described processes, techniques, and procedures that will lead to the defined results in the maintenance regulations. None of the information in this AC is mandatory or constitutes a regulation. We have not included any material in this AC that imposes, reduces, or changes a regulatory burden on anyone. If you use the method of compliance presented in this AC, the term “should” used herein applies only if you choose to follow these particular methods. You should tailor your maintenance program to your particular and specific operation; therefore, we cannot provide a single means of compliance that applies to all certificate holders required to develop and implement an air carrier maintenance program.
f. Continuous Airworthiness Program (CAP). The Federal Aviation Administration (FAA) introduced the CAP in a final rule at 29 Federal Register (FR) 6522 on May 20, 1964. Since then, the CAP has become known, in a colloquial sense, as a Continuous Airworthiness Maintenance Program (CAMP). This 1964 rulemaking was our response to safety concerns and discoveries of weaknesses in the maintenance programs of some air carriers that we found during accident investigations and surveillance of operator maintenance activities. We designed the air carrier CAP to strengthen requirements for air carrier safety management activities. Each one of the air carrier maintenance program elements that we describe in this AC were a part of that 1964 rulemaking.
Par 1-5 Page 3
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.
Page 4 Par 1-7
• 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.