Appendix 1
e. AD Compliance Records. AD compliance records and the status of any applicable ADs are maintained in accordance with existing regulatory requirements. It is considered a best practice that any planning documentation, including applicable checklists, from AD meetings should be retained and should contain information on what decisions were made during the AD management process. Any compliance validations should also be captured and retained.
5. AUTHORING AIR CARRIER-SPECIFIC WORK CARDS FROM SERVICE INSTRUCTIONS. Service instructions mandated by ADs are often lengthy as they address multiple configurations. It is considered a best practice for an air carrier to process the design approval holder (DAH) instructions into work cards specific to an air carrier’s maintenance program. By doing so, the air carrier presents only pertinent information to the various departments responsible for taking action. It also allows the air carriers to address specific internal requirements, such as Required Inspection Items (RII), Extended Operations (ETOPS), Reduced Vertical Separation Minimum (RVSM), and any AMOCs necessary for their fleet or equipment. Below are some considerations for authoring internal work cards:
• Indicate on the compliance documents/work cards that a technician is working on an AD-related task with no deviations or substitutions allowed.
• To help the technician distinguish between mandatory steps with no changes allowed versus performing accepted procedures, mark the mandatory steps that should not be changed.
• Identify work steps that require special signature and/or qualification requirements, such as ETOPS and RIIs.
• Provide a feedback process for technicians to use in the event the AD instructions cannot be accomplished (e.g., who to contact, what steps to take in the event a portion of the AD has been accomplished, but all work instructions cannot be completed, etc.).
6. 24/7 AMOC SUPPORT.
a. After Business Hours. To avoid significant air transportation disruptions, there are occasions when an AMOC is urgently needed after normal business hours to support air carrier compliance with an AD. The air carrier should develop a methodology and process for handling issues that may require FAA participation to resolve such an emergency.
b. 24/7 Support Process. While a 24/7 support process is available, it is not intended to be used for AMOCs to accommodate air carriers that have failed to adequately plan for AD compliance (refer to the current edition of FAA Order 8110.103, Alternative Methods of Compliance (AMOC)). In addition, this is an FAA process that can be requested only by the ASI and not the operator/air carrier.
Appendix 2 APPENDIX 2. AIR CARRIER REPORTING/RECORDKEEPING AND TRACKING
FUTURE AIRWORTHINESS DIRECTIVE COMPLIANCE REQUIREMENTS
1. PLACEHOLDER MAINTENANCE TASK. Air carriers use various systems to track and schedule required maintenance tasks on their affected aircraft and components. For Airworthiness Directives (AD) with compliance requirements that are not due for many years, it is considered a best practice to create a placeholder maintenance task that tracks the AD’s timeframe requirements. By initiating a placeholder record within the air carrier’s tracking system far in advance of any due tasks, the AD requirements will be captured and may prevent AD noncompliance due to exceeding a specification (e.g., hours, cycles, days, etc.).
2. REPORTING REQUIREMENTS. Air carriers should consider any AD-mandated reporting requirements. It is considered a best practice to have a single department or individual responsible for collecting the necessary reports and submitting them to the FAA and/or design approval holder (DAH) within the mandated timeframe, which may be expressed in hours, cycles, calendar time, etc.
3. COLLECTING REPORTS. In order to help collecting reports, air carriers should build the necessary reporting information into their work cards with specific means to submit that data to the department/individual responsible for reporting. It is considered a best practice to document and electronically submit this data to allow faster reporting.
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Appendix 3 Page 1 (and 2) APPENDIX 3. AIR CARRIER TRAINING
1. AIRWORTHINESS DIRECTIVE (AD) AWARENESS. It is considered a best practice that air carriers consider AD training for both overall AD compliance policies and procedures, as well as AD-specific training. The air carrier should develop recurrent AD awareness training to address the air carrier’s specific policies and procedures in regards to compliance with AD requirements. This training should include the awareness of strict compliance with written instructions and the need to propose an alternative method of compliance (AMOC) when a deviation is required. When the air carrier determines that an AD’s complexity may impact its implementation, the air carrier should have a program in place where a risk analysis-based assessment is made to determine whether maintenance training is needed.
2. SKILL-SPECIFIC TRAINING. Training may also include skill-specific training for particular ADs. For example, an AD may require a new Nondestructive Testing (NDT) technique that requires training. In addition, the air carrier may use personnel with specific training for particular tasks. For example, an air carrier can use avionics-qualified technicians for wiring-related ADs. To measure the level of improvement regarding awareness and skills level of aviation personnel in wiring training, the air carrier, its repair station personnel, and Original Equipment Manufacturer (OEM)/design approval holder (DAH) personnel should have an electrical wiring interconnection system (EWIS) training in place that is consistent with the 2007 Enhanced Airworthiness Program for Airplane Systems (EAPAS) rule, and with the current edition of Advisory Circular (AC) 120-94, Aircraft Electrical Wiring Interconnection Systems Training Program.
Appendix 4 APPENDIX 4. AIR CARRIER PROTOTYPING
1. IMPLEMENTATION DOCUMENTATION. Air carriers should prototype their implementation documentation based on the results of the risk assessment performed during the compliance planning process. This will ensure the accuracy of the implementation document.
2. SILENT PROTOTYPING.
a. Purpose of Silent Prototyping. Air carriers should also use silent prototyping, in which a technician tests the compliance document without verbal assistance from the author. This method can determine whether a technician can accomplish the instructions as written without the need for interpretation. Air carriers may decide to only prototype their Airworthiness Directive (AD) compliance document on one aircraft, engine, or appliance at one location.
However, if the tooling and techniques are complicated, it may be necessary to prototype the AD compliance document at each maintenance facility that will be asked to comply with the AD document. If there are work steps that must be complied with at a component level, it may be necessary to prototype the AD-mandated actions at the component shop performing the modification, as well as the installation effort at the aircraft level. As part of its AD compliance best practices, the air carrier should invite its certificate management office (CMO)/ASI to the AD on-airplane prototype. This allows the air carrier to recognize that the CMOs/ASIs will decide which prototype invitation they will respond to.
b. Silent Prototyping Process. Air carriers should have or develop a prototyping process that allows them to develop and verify the documentation and accomplishment methods that can be used primarily to enhance implementation of complex or higher risk compliance procedures.
3. COMPLIANCE DOCUMENT ISSUE REPORTING. Some air carriers may not have the organizational structure to support on-site prototyping of the AD-related documentation. If affected parties cannot be present for prototyping, there should be a process for the technician to document and report any issues with the compliance documents to the document author. The process should include a way the technician may resolve paperwork and compliance issues before the aircraft returns to service (RTS).
4. KITTING. An air carrier may be able to purchase from the Original Equipment Manufacturer (OEM)/design approval holder (DAH) a kit that consists of all the AD-required parts and materials; this process is referred to as kitting. The accuracy of the kit contents should be verified through the prototyping process. The air carrier may assemble the kit independently.
In either case, the completeness and conformity of the kit contents should be verified and the air carrier should consider evaluating the kit in the prototyping process. Special attention should be made to ensure that part or material substitutions are only made with written approval.
5. PROTOTYPING PROCESS ROLES AND RESPONSIBILITES. While every air carrier has a different organizational structure, the prototyping process should include the following roles and responsibilities:
a. Maintenance Personnel. Technicians read AD compliance documents and accomplish the work steps. If AD compliance documents or manuals being used do not support the physical Page 1
Appendix 4 requirements, the technician should document and resolve these issues before an aircraft RTS.
This action can include:
• Work step sequencing,
• Verifying required materials,
• Tooling availability,
• Accessibility,
• Material substitutions not permitted by the provided documentation, or
• Any other issues that prevent compliance with the documentation as written.
b. Engineering Personnel.
(1) The author of the air carrier’s compliance document (or an authorized engineering representative) should be present during prototyping. If the air carrier is not staffed with an engineering department, the person responsible for AD compliance documents should be present.
The person’s role is to collect all necessary changes to the compliance document as well as to the supporting manuals. The person should also document all of the necessary data to support any alternative method of compliance (AMOC). Engineering should propose and obtain approval for all AMOCs required to return the aircraft to service. This responsibility includes providing feedback to the OEM/DAH of any documentation issues, such as a mandated service instructions, Aircraft Maintenance Manual (AMM), component maintenance manual (CMM), etc.
(2) Subsequent to prototyping, engineering or the responsible person should hold a debrief meeting with all of the participants in the prototyping process. The purpose of this meeting is to review the corrections, clarifications, or significant changes needed to AD compliance documents and to ensure that there is a clear understanding of any action items as a result of the prototyping process. Engineering or the responsible person should then revise AD compliance documents as needed so that future compliance efforts are correct. If the changes are significant, re-prototyping may be necessary.
c. Air Carrier Inspection Personnel. Air carrier inspectors may participate to ensure that the air carrier’s inspection process requirements are included in AD compliance documents and to perform any AD-mandated inspection requirements, such as Nondestructive Testing (NDT).
Like the technician, the inspector should document and resolve any issues before an aircraft RTS. This action can include:
• NDT tooling set up,
• NDT techniques,
• Tooling availability,
• Accessibility, or
• Any other issues that prevent compliance with the documents as written.
6. FEEDBACK FROM PROTOTYPING. Air carriers should perform a prototype as soon as possible after an AD is issued. Any changes identified as a result of prototyping can be implemented quickly across the industry. For example, if a fitting is being fabricated incorrectly and cannot be installed, it may be necessary for the OEM/DAH to produce redesigned parts with
Appendix 4 an extensive lead time. If prototyping happens late in the compliance window, there may be operational impact and a reduction of safety for the traveling public.
7. OUT-BRIEFING. The air carrier defines in their manual the person responsible for conducting the out-brief meetings. The out-brief meeting should be used to address any issues found during the prototyping process, such as corrections, clarification, and significant changes.
The meeting may produce a list of action items, action item owners, and estimated completion dates for the action items prior to AD implementation. This action would help ensure that there is a complete understanding by all participants regarding future actions necessary to bring documents into compliance with the necessary physical work steps, correct any documentation errors, and/or obtain any necessary AMOCs.
8. SUPPORT SYSTEM. While executing AD-mandatory work steps, there are different circumstances that arise that may require technical support. Air carriers should have a support system in place to respond to immediate technical concerns and the need for AMOCs. By having a support system in place, technicians will have the guidance needed to accomplish a task.
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Appendix 5 APPENDIX 5. SAMPLING PROGRAM AND PHYSICAL VERIFICATION
1. SAMPLING PROGRAM. A sampling program is an effective method of monitoring Airworthiness Directives (AD) for continued compliance. A sampling (i.e., AD re-verification) program would use a process audit procedure that utilizes an air carrier’s existing audit and reliability elements of their Continuing Analysis and Surveillance System (CASS) program. This would allow the air carrier to monitor AD compliance during specified maintenance intervals (typically at B-Check or C-Check inspection intervals). A sampling program should verify that an unintentional alteration has not occurred and ensure that the air carrier’s CASS audit sampling program verifies that ADs are evaluated, accomplished, and tracked. This appendix, as seen in Figure 1, Airworthiness Directive Compliance Physical Verification Flow Chart, and Figure 2, Instructions For Airworthiness Directive Compliance Physical Verification Analysis, of this advisory circular (AC) outlines an AD sampling program.
2. SAFETY MANAGEMENT SYSTEM (SMS). Each new AD should be evaluated for risk of future noncompliance using SMS principles as applicable in the current edition of AC 120-92, Safety Management Systems for Aviation Service Providers. Air carriers validate that risk assessments, upon implementing each new AD, should include developing and implementing preventative measures to eliminate and/or reduce the severity and/or frequency of possible AD alteration.
a. Practical risk management should include a program to ensure that potential hazards that could result from implementing a new AD are identified and controlled.
b. A safety assurance program should be implemented by the air carrier to evaluate the continued effectiveness of implemented control strategies. There should also be a program implemented that supports the identification of new potential hazards.
3. AT-RISK TASK. ADs identified in a sampling program that require verification should be assigned an inspection task on a representative number of aircraft, or the entire fleet, through the normal maintenance inspection intervals (e.g., B-Check or C-Check). The sampling program results should be incorporated in an air carrier’s maintenance and inspection program. The air carrier’s CASS program is responsible for:
• Measuring the performance and effectiveness of its inspection program and the program covering other maintenance, preventive maintenance, and alterations.
• Correcting any deficiencies in those programs, regardless of whether the air carrier or another person carries out those programs.
4. NEWSWORTHY COMPLIANCE ISSUES. Air carriers that are members of industry associations should consider using established processes for compliance issues that may be widespread and newsworthy. An established process may be seen in the Air Transport Association of America’s (ATA) Specification 111 or similar processes developed by other associations. Air carriers may need to coordinate with associations, regulatory authorities, and OEMs/DAHs to resolve compliance issues.
Appendix 5 FIGURE 1. AIRWORTHINESS DIRECTIVE COMPLIANCE PHYSICAL
VERIFICATION FLOW CHART AD Compliance Physical Verification Analysis Alteration Risk Assessment Is there a risk of alteration as a result of:
• The nature of the AD configuration? Is the FAA Issues configuration easily undone?
AD
• Incorporating standard practices during the accomplishment of routine and non-routine maintenance?
• Removing or relocating items to facilitate other maintenance?
Does the • Inadequate AD configuration information in the AD involve a Yes maintenance manuals. For example, are AD- configuration driven maintenance instructions or ICAs change? incorporated into the manuals?
• AD-required maintenance tasks that differ No significantly from, or are more complex than, the air carrier's standard maintenance program?
• Systemic issues such as prior noncompliance Physical problems with similar work?
verification of AD compliance is • Air carrier dynamics, e.g., contract work, unnecessary suppliers, MROs, experience level, or workmanship.
No •A lack of an existing maintenance program requirement to inspect the AD configuration?
Does assessment identify high alteration risks?
Yes Maintenance Program Task Analysis When determining appropriate tasks to physically verify the AD configuration, consider the following:
• Do any existing scheduled maintenance tasks provide an opportunity to verify risks?
Feedback
• Were any AMOCs incorporated that resulted in AD configuration differences within the fleet?
• Should the physical verification be applied to the Add/modify task entire population or a subset?
in air carrier
• What inspection frequency is adequate to maintenance mitigate risks?
program for re-verification Page 2
FIGURE 2. INSTRUCTIONS FOR AIRWORTHINESS DIRECTIVE COMPLIANCE
PHYSICAL VERIFICATION ANALYSIS 1 Preparation:
FAA issued Airworthiness Directive (AD).
Initiate analysis for newly issued ADs. This process may also be applied to previously accomplished Service Bulletins (SB) or ADs with known concerns.
Go to Step 2 2 Decision:
Does the AD involve a configuration change?
If the AD involves a configuration change, an alteration risk assessment should be performed. If the AD does not involve a configuration change, a physical verification maintenance task is unnecessary.
Yes, go to Step 3
No, go to Step 8 3 Assessment:
Alteration Risk Assessment.
Air carriers should develop their own risk-based assessment process to determine if the AD configuration under consideration exhibits a high risk of alteration through the course of normal maintenance. The analysis should be comprehensive enough to include, but not be limited to, the elements listed in the flow chart.
Go to Step 4 4 Decision:
Does the assessment identify high alteration risks?
Has the risk assessment identified high risks of altering the AD configuration, resulting in AD noncompliance? If yes, a maintenance program task analysis should be performed to identify the appropriate tasks to mitigate the identified risks. If no, a physical verification of the AD configuration is unnecessary.
Yes, go to Step 5
No, go to Step 8 5 Analysis:
Maintenance Program Task Analysis.
The air carrier should perform an analysis to identify maintenance tasks that would mitigate identified risks to continued AD compliance. The analysis should be based on an air carrier’s experience, operator systems, and the alteration risk, with consideration for, but not limited to, the items listed in the flow chart.
Go to Step 6 6 Outcome:
Maintenance task added to air carrier’s maintenance inspection program.
The alteration risk assessment has determined a need to add tasks to the maintenance program to physically verify AD compliance in regard to identified risks. The maintenance program task analysis has identified the appropriate tasks to mitigate identified risks.
7 Feedback.
The air carrier may include a feedback element to its AD compliance physical verification program. Events such as physical verification task results, maintenance program changes, or regulatory changes may trigger a re-evaluation of the analysis that was performed in Step 5. The design of the feedback element would depend on the air carrier’s organization and resources.
8 Outcome:
Physical verification of AD compliance is unnecessary.
The lack of a configuration change, or the alteration risk assessment of a configuration change, has determined that a physical verification of AD compliance is unnecessary.
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