(7) Generic or common NDT manual procedures not developed for a specific SB application.
c. When using “in accordance with” or “refer to” language in an SB, the DAH should include a note explaining the meaning of that language. For example:
“Note: These work instructions refer to methods, techniques, and practices described in other {specify DAH name} documents. When the words "refer to" are used and there are other acceptable methods, techniques, and practices (including tools, equipment, and test equipment) those acceptable methods, techniques, practices (including tools, equipment, and test equipment) may be used to complete the work. When the words "in accordance with" are included in the instruction, the methods, techniques, and practices specified (including tools, equipment, and test equipment) in the {specify DAH name} document must be used.”
2-10. Critical Task Differentiation. Steps that have a direct effect on detecting, preventing, resolving, or eliminating the unsafe condition in an AD should be identified in an SB with “RC.” Any substitutions or changes to RC steps will require an AMOC approval.
Differentiating these steps from other tasks in an SB will improve an owner’s or operator’s understanding of which steps in the SB must be done to comply with the AD and help provide consistent judgment in AD compliance.
a. When using critical task differentiation, a DAH should coordinate with the FAA early in the SB development process to determine if the SB might be IBR’d in an AD and if the RC steps are appropriately labeled using the guidance in this AC or other methods acceptable to the FAA.
(1) Step(s) labeled as RC apply solely to the SB that is IBR’d in the AD. The designation is not transferable or implied as applicable to any other document.
(2) A DAH must include a note in the SB to define RC. An example is:
“Note: Some steps in the accomplishment instructions are identified as Required for Compliance (RC). If this service bulletin is mandated by an airworthiness directive (AD), the steps identified as RC must be done to comply with the AD.
Steps not identified with RC are recommended and may be deviated from; done as a part of other actions; or done with accepted methods different from those given in SB if the RC steps can be done and the airplane returned to a serviceable condition.”
b. Sometimes an SB is issued before a decision is made by the FAA to reference the SB as the appropriate source of information for compliance with an AD. If an SB is published without tasks labeled with RC, the SB can be revised to include the RC label. Depending where 12
-- in the AD process the AD action is, the revised SB can be referenced in the final rule AD as the appropriate source of information for compliance or be FAA approved as a global AMOC to the AD.
c. In general, if any of the following items are included in an SB due to a design deficiency, manufacturing error, systemic maintenance error, or repair, and directly impact the detection, removal, prevention, or resolution of the unsafe condition, the item should be labeled with RC. For example:
(1) Inspection methods, techniques or practices that are necessary to detect the unsafe condition. This includes repetitive inspections or a terminating action such as a repair.
(2) Removal or installation of part(s), including any hardware necessary to support the new part.
(3) Steps required to directly accomplish a change to an aircraft or component to resolve an unsafe condition (e.g., parts, material, dimensions, methods, and processes).
(4) Steps such as application of corrosion inhibiting compound, application of sealant, cleaning of surfaces for proper bonding, replacing lubricant, etc. The step to use the material may be labeled RC or the specific type of material may be labeled RC. However, the SB may refer to standard practices to apply the material.
(5) Repair methods, techniques or practices, including steps that specify to contact the DAH for repair, modification, or testing instructions.
(6) Operational or functional test procedures or test criteria to ensure the repaired or modified system is operating properly. This includes any necessary corrective action if the test failed.
(7) Recording data (such as pressure readings, torque readings, temperature readings, gap measurements, dimensions, etc.) that is specifically required to properly complete the inspection, repair, or modification.
d. In general, if any of the following items are included in an SB and do not directly impact the detection, removal, prevention, or resolution of the unsafe condition, the items should not be identified as RC in an SB:
(1) Aircraft preparation steps (e.g., removing electrical power, opening and tagging circuit breakers, jacking and shoring, etc.).
(2) Access steps (e.g., removing access panels, removing sidewall panels, removing galleys or lavatories, etc.).
(3) Access restoration steps (e.g., installing access panels, sidewall panels, galleys or lavatories, etc.).
(4) Airplane restoration steps (e.g., restoring electrical power, closing circuit breakers, removing jacking and shoring, etc.).
(5) Steps such as cleaning, painting, trimming, etc., that do not directly remove, prevent, or resolve the unsafe condition.
(6) Steps to update maintenance records to show that the SB has been accomplished, which is already required by regulation.
(7) Steps to report results, such as inspection findings.
(8) Steps to perform operational test procedures because of interruption to other aircraft systems (e.g., disconnection of a hydraulic system to gain access to an area or a test of the hydraulic system after it is reconnected).
e. The RC label should be identified at the beginning of each step in the accomplishment instructions that must be completed to meet the requirements of the AD.
(1) If the accomplishment step labeled RC has substeps or tasks with no paragraph designation under the labeled RC step, then all of the substeps or tasks must also be completed.
For example, the substeps (3)(a)1 – 5 in figure 1 below must all be accomplished.
Figure 1. Example of Identification of Tasks Required within a Step
(3) RC - Do a detailed inspection of the inboard MLG door (1) as follows:
(a) Push the inboard MLG door (1) to the end of its travel limits, keep it in this position and do the steps that follow:
1. Inspect the forward inner skin (3) in the shaded area shown on View B for signs of cracks and/or deformation.
2. Inspect the forward member (2) in the shaded area shown on View B for signs of cracks and/or deformation.
3. Inspect the cross member (5) in the shaded area shown on View B for signs of cracks and/or deformation.
4. Inspect the aft member (6) in the shaded area shown on Views B and C for signs of cracks and/or deformation.
5. Inspect the aft inner skin (7) in the shaded area shown on View B for signs of cracks and/or deformation.
(2) If RC tasks state to do the work in accordance with a figure, drawing, or illustration, then all of the information in the figure, drawing, or illustration is mandatory.
(3) Steps in SBs using the terminology “in accordance with” as defined in paragraph 2-9 should use the RC label. The phrase “refer to” can be used in steps with and without the RC label. For example, when used with the RC label: “RC – Install placard xyz. Refer to DAH Standard Overhaul Practice Manual xx-xx-xx as an acceptable procedure.” The placard is required to be installed, but allows flexibility regarding how to install it.
(4) If options in the accomplishment instructions exist for a task labeled with RC, those options must be preceded by the phrase “Do one of the following.”
(5) The only tasks that need to be accomplished on a particular airplane group are the tasks labeled with RC that are applicable to that airplane group. For example, the tasks defined for aircraft having configuration 1 are not required to be accomplished on aircraft having configuration 2. See figure 2 below.
Figure 2. Example of Identification of Tasks Required for a Group or Configuration RC - For aircraft that have configuration 1 (P/N 601R12310-1) leading edge panel installed See Figure 2, View C and F.
(1) Between WS352 and WS366, on the shroud, drill three holes as follows:
a. Drill one hole to a diameter between 0.241 in. and 0.246 in (6.12 mm and 6.25 mm) at 1.35 in (34.3 mm) outboard of the access hole and 0.48 in. (12.2 mm) below the upper shroud edge (Refer to View C).
b. Drill one hole to a diameter between 0.241 in. and 0.246 in (6.12 mm and 6.25 mm) at 1.35 in (34.3 mm) outboard of the access hole and 1.60 in. (40.6 mm) below the upper shroud edge.
c. Drill one hole to a diameter between 0.241 in. and 0.246 in (6.12 mm and 6.25 mm) at 1.80 in (45.7 mm) outboard of the access hole and 0.63 in. (16.0 mm) below the upper shroud edge.
RC - For aircraft that have configuration 2 (P/N 601R12310-3 or -5 or -7) leading edge panel installed See Figure 2, View D and G.
(2) Between WS352 and WS366, on the shroud, drill three holes as follows:
a. Drill one hole to a diameter between 0.241 in. and 0.246 in (6.12 mm and 6.25 mm) at 1.35 in (34.3 mm) inboard of the shroud and 1.75 in. (44.5 mm) from the lower edge of the shroud (Refer to View D).
b. Drill one hole to a diameter between 0.241 in. and 0.246 in (6.12 mm and 6.25 mm) at 2.00 in (50.8 mm) inboard of the shroud edge and 1.10 in. (27.9 mm) from the lower edge of the shroud.
c. Drill one hole to a diameter between 0.241 in. and 0.246 in (6.12 mm and 6.25 mm) at 4.00 in (101.6 mm) inboard of the shroud edge and 1.75 in. (44.5 mm) from the lower edge of the shroud.
(6) If there are tasks not labeled with RC, but there are optional steps that could result in different type design configurations, the DAH must account for all of the configurations that might result in the type design drawings produced by the DAH (i.e., both the RC tasks and those not labeled as RC).
(7) If a step labeled RC requires installation of (improved) parts, the DAH may identify a specific part number or later FAA-approved design part number (e.g., install -3 or later FAA-approved part) that is eligible for installation on the aircraft, powerplant or higher assembly.
f. Once an SB using the RC concept is IBR’d in an AD:
(1) Any revision to the SB by the DAH will require an AMOC request. This applies even if the SB revision only changes steps that were not labeled RC.
(2) Any substitutions or changes made to the RC steps by owners and operators will require an AMOC (see FAA Order 8110.103, Alternative Method of Compliance, appendix A, paragraph 109). Owner and operator substitutions or changes made to non-RC steps will not require an AMOC if the RC steps can be completed and the aircraft returned to a serviceable condition.
2-11. Streamlining Development and Revision of SBs.
a. Each DAH should have systems in place to continuously monitor and implement process improvements in both the development and revision of SBs. The system should help improve processes involving the quality of SBs as well as reduce flow time to produce those SBs.
b. It is important to remember that any change to an SB, such as a partial or temporary revision, after the SB information is FAA-approved and IBR’d in an AD requires an AMOC approval.
c. Below are examples of process improvements implemented by various DAHs to reduce flow time and improve the quality of SBs. Each DAH should review the list of items and evaluate the feasibility of implementing items from the list, or identify alternatives or equivalents that would improve SB processes.
(1) Use of Checklists and Tip Sheets. Implemented to assist authors in making sure requirements are met before documents are sent for approval.
(2) Use of Templates. Implemented to standardize the location and content of text in SBs, which reduces variation.
(3) Dispute Resolution Process. An informal process where a DAH communicates early and often in the SB process with its regulatory counterpart(s) for early resolution of issues.
(4) Validation Process. A formal process used to validate that the procedures in SBs are accurate, and that hardware kits/parts are complete and can be accomplished per the accomplishment instructions.
(5) Partial Revision Process. A process in which only changed information in an SB is sent to affected customers.
(6) Temporary Revision Process. A process in which only changed information in a document is sent to affected customers. The information is later included in the next scheduled revision cycle for the document.
(7) Information Exchange Process. A process in which a DAH shares information used to develop service information. For example, posting the proposed solutions, proposed compliance times, estimated parts availability dates, and other information regarding plans for resolving an unsafe condition on the DAH website. Designated parties can then view the information and provide feedback to the DAH.
(8) Airworthiness Concern Coordination Process. A process in which a DAH, owners, operators, and a regulatory agency work together to develop actions and accomplishment instructions necessary to resolve an unsafe condition. For transport airplanes, a single airline (referred to as the lead airline) reviews the SB and provides comments or recommendations to the DAH prior to the SB publication process.
d. Another way to help facilitate the SB development and revision processes is to use the FAA delegation process. When authorized, a designee can recommend approval of the engineering aspects of an SB that will be the subject of an AD (see FAA Orders 8110.37, Designated Engineering Representative (DER) Handbook, and 8100.15, Organization Designation Authorization Procedures).
2-12. Ex Parté.
a. Ex parté is Latin for “one-sided.” Ex parté contacts are prohibited and can be any oral or written communication between a government employee and someone outside the government regarding the content of a specific rulemaking that excludes other interested parties and takes place before the final rule is published or the NPRM is withdrawn. If ex parté communication occurs, the FAA will place a record of the contact into the AD docket for all parties to view.
b. The FAA’s Airworthiness Directive Manual, FAA-IR-M-8040.1, chapter 3, and 14 CFR part 11, appendix 1, provide information on ex parté communication. Topics include the meaning of an ex parté contact and guidance the FAA must follow during the AD rulemaking process (i.e., prior to/after signatures on AD worksheet, during the comment period, after the comment period closes, and after a meeting is announced to the general public).
Chapter 3. Avoiding Overlapping and Conflicting Actions in SBs
3-1. General. This chapter provides a recommended process for DAHs to track AD-related SBs to ensure that they do not contain overlapping or conflicting actions that could lead to a non-compliance with an AD.
3-2. Tracking and Management Process. A DAH should develop a robust SB/AD tracking and management system using the following process to ensure overlaps and conflicts between new and existing SB actions are identified and addressed:
a. Search capabilities should include the following primary areas:
(1) Make/model or part number of affected product(s);
(2) Major aircraft elements (e.g., engine, strut, wing, etc.);
(3) ATA code;
(4) Maintenance zones;
(5) Service information (e.g., SB number);
(6) Airworthiness limitation sections;
(7) Previously issued ADs; and
(8) Planned ADs (i.e., action(s) that the FAA proposes to mandate in an AD).
b. When developing a new SB that will be associated with an AD, the DAH should search for any existing or planned ADs in or affecting the area of the new AD action and determine whether there are potential overlapping and/or conflicting requirements that could lead to non-compliance with any existing AD(s).
c. The DAH should document and maintain a record of its findings.
d. Upon review of the findings, the DAH should resolve any conflicting actions (e.g., the DAH might develop a new design and/or inspection).
e. Finally, the DAH should notify the FAA of the results of its review and resolution of any conflicting issues prior to certification of the new design or issuance of the SB.
Chapter 4. AMOCs
4-1. General. This chapter provides guidance to:
a. Owners and operators to share AMOCs with DAHs;
b. DAHs to review FAA-approved AMOCs for an AD to determine if those AMOCs are candidates for a global AMOC;
c. DAHs to consider a process for posting global AMOCs on a website accessible by owners and operators;
d. DAHs to address how to minimize the number of AMOC requests for ADs requiring part changes; and
e. DAHs to develop a process to provide 24/7 AMOC support.
4-2. Sharing AMOCs with DAHs. In order to assist DAHs in identifying AMOCs that might be candidates for a global AMOC, owners and operators requesting an AMOC should consider providing permission to the FAA to share the AMOC approval response (i.e., letter or email) with the product DAH. Written consent must be included in the AMOC proposal submitted to the FAA. The consent must include a statement allowing the FAA to provide the AMOC response to the DAH for consideration as a global AMOC. For example:
Operator XYZ grants the FAA approving office permission to share the AMOC approval response with the Design Approval Holder for consideration in proposing a global AMOC.
4-3. DAH Determination for Global AMOCs.
a. Certain AMOC proposals can be approved as global AMOCs—for example, to use industry best practices that were not previously specified in the AD or IBR’d SB, or to correct typographical errors. As more global AMOCs are FAA-approved and made widely available to owners and operators, their engineering and administrative resource expenditures can be reduced.
b. FAA Order 8110.103 requires the FAA to transmit to the DAH an AMOC approval response when the AMOC proposal includes a consent statement allowing the approval response to be shared. A DAH should review this information and determine if any are candidates for a global AMOC. Refer to 14 CFR 39.19 for information regarding applying for an AMOC (which includes global AMOCs).
(1) If there are similar AMOCs, the DAH should determine if a global AMOC is appropriate, and if so, submit a request for approval of a global AMOC.
(2) If no previous AMOCs exist, the DAH should determine whether the condition is likely to occur on other products of the same type design or in another operator’s fleet. If so, 19
the DAH should submit a request for approval of a global AMOC.
4-4. Posting Global AMOCs on Website. A DAH should consider posting global AMOCs for its products on a website that is accessible by all owners and operators. Making global AMOCs accessible will allow owners and operators to search previously approved global AMOCs that might apply to their product. The posting should include the following:
a. AD number;
b. Model effectivity; and
c. AMOC approval response or subject of AMOC, as appropriate.
4-5. Minimizing AMOC Requests for Part Changes. One way to minimize the number of AMOC requests for ADs requiring part changes is to use “later approved parts” language in the SB. This would allow—without an AMOC approval—installation of DAH parts for compliance with the AD that are FAA-approved after the release of the SB.
a. Use of such language should be on a case-by-case basis. Installation of parts produced by anyone other than the original DAH (e.g., owner or operator-produced parts) will require an AMOC approval.
b. Because owners and operators may not have easy access to information concerning the date a part is approved, SB language for the “later-approved parts” should include recognition that the part complies with the applicable AD. This will ensure owners and operators know which parts are acceptable for installation per the AD.
c. Use the following definition in SBs to define “later-approved parts”:
Later-approved parts are only those [insert name of DAH] parts that are approved as a replacement for the part specified in this service bulletin and approved as part of the type design by the FAA after the issuance of this service bulletin.
d. In order for owners and operators to use later-approved parts without an AMOC approval, the DAH must provide a statement, in writing, to the user of the part that the part’s design was approved after [select either the Original Issue or Revision (X)] of the SB.
e. The Instructions for Continued Airworthiness (ICA), including installation instructions, associated with the later approved part must be acceptable in accordance with 14 CFR 23.1529,
25.1529, 27.1529, 29.1529, 31.82, 33.4, or 35.4, as appropriate.
4-6. 24/7 AMOC Support.
a. In September 2010, the FAA implemented a process to support an urgent need for AMOC issuance after normal business hours to avoid significant air transportation disruptions or substantial impact to an operator. While a 24/7 AMOC support process is available, it is not 20
intended to be used to accommodate air carriers that have failed to adequately plan for AD compliance (see FAA Order 8110.103).
b. To help prevent grounding aircraft due to potential AD non-compliance, a DAH should develop a process for 24/7 AMOC support. Refer to AC 39-9, Airworthiness Directives Management Process, for information on the AD management process for aircraft operators.
Chapter 5. Maintaining Compliance with AD-Mandated Design Changes
5-1. General. This chapter provides guidance to DAHs for helping owners and operators and maintenance providers avoid inadvertently undoing or modifying AD-mandated type designs through routine maintenance practices.
5-2. Maintenance of an AD-Mandated Design Change. Once a product’s approved design is changed by an AD, owners and operators may perform routine maintenance if that maintenance does not result in changing the AD-mandated configuration. The maintenance can be performed using a combination of the methods, techniques, and practices prescribed in the DAH maintenance manuals or ICA, or a person’s own maintenance practices developed under 14 CFR 43.13(c).
a. The potential for undoing an AD-mandated configuration should be evaluated during all stages of design and development of SBs, maintenance documents, or ICA (e.g., during the review/approval of the SB, maintenance, and ICA; SB prototyping/validation; and NPRM comment period).
b. To decrease the chances that maintenance will inadvertently undo or modify an AD-mandated type design, the following actions should be performed by DAHs:
(1) During the design change and SB development stages, evaluate the need for changes to maintenance manuals or ICA to eliminate the potential for undoing an AD-mandated condition or configuration. U pdate any maintenance manuals or ICA to support the AD-mandated type design changes.
(2) Provide awareness to owners and operators regarding availability of updated ICA documents.
(3) When drafting SBs, use notes for flexibility and refer to standard practices as much as possible.
(4) When drafting SBs, avoid duplicating entire procedures and instructions that reside in maintenance or other ICA documents. The SB should only list the specific requirement which must be met, not the entire procedure. Internal flags should then be placed in the associated maintenance document where the requirement is located to indicate that it addresses an AD compliance requirement (see paragraph 5-5).
(5) Create an SB-to-AD cross-reference listing upon release of the AD (see paragraph 5-6).
5-3. Availability of Maintenance Procedures or ICA. A DAH should make new maintenance procedures or ICA3 or changes to them available as early as possible to owners and operators when an AD-related SB is issued (e.g., prior to the effective date of the AD).
Doing so helps ensure that owners and operators have the appropriate maintenance procedures 3 Refer to 14 CFR 21.50 22
I I I I or ICA necessary to maintain the product upon accomplishing or complying with the AD.
5-4. Allowing Flexibility. Include notes and refer to standard practices in S Bs when possible.
This will help prevent conflicting requirements or configurations from being created, and thereby reduce the likelihood that subsequent maintenance would de-modify the type design mandated by an AD.
5-5. Flagging Procedures. When an SB specifies requirements that exist in a maintenance manual (e.g., an AMM), or when the SB instruction includes language to accomplish a procedure “in accordance with” a manual (see paragraph 2-9) that is approved by a regulatory authority (e.g., the SRM), the requirement or procedure in the manual from which the requirement was duplicated, or the referenced manual, should be flagged by the DAH. The procedure should be flagged in a manner that identifies the procedure or requirement in the manual held by the DAH is mandated by an AD. The flagged language should:
a. Be visible to the maintenance documentation authors for their use (i.e., not on the maintenance documents provided to the owners and operators).
b. Contain a note similar to the following or list the SB and AD number once it becomes available:
“Note: This procedure is used for maintaining compliance with SB XYZ, which is subject to or mandated by an AD. Do not alter this procedure without obtaining a global AMOC approval.”
5-6. SB-to-AD Cross Referencing. An SB -to-AD cross reference listing with SB revision levels should be included in the front of the DAH’s maintenance manual(s) to help owner and operators identify which SBs are related to ADs (see figure 3).
Figure 3: Example of Aircraft Maintenance Manual SB-to-AD Cross Reference Number Incorporated Started/ Completed ATA Subject MD80-28-222 A MD80-28-226 AD 2011-01-16 A MD80 -28-229 No Effect AUG 01/2009 No Effect - SECTION 28-20 - FUEL – Fuel Quantity Indicating – Install Line Replaceable Unit Jumper Wires FUEL – Switch Fuel Level Float – Fuel Level Float and Pressure Switch In-Line Fuse Installation FUEL – Fuel Quantity Indicating – Replacement of Metric Instruments and Dripless Dipsticks with English Units 23