Appendix 1
• Changes to manuals, e.g., Ilustrated Parts Catalog (IPC), Wiring Diagram Manual (WDM), minimum equipment list (MEL), Airplane Flight Manual (AFM), or other affected documents.
• Determining the need for specific labor classification/skills (e.g., avionics, structures, etc).
• Possible restriction of AD accomplishment to site-specific locations based on the need for specialized skills.
• Existence of delivered configurations not addressed in AD service instructions.
c. Prototyping the Documentation. Once air carriers have produced their internal documentation to comply with AD requirements, they should consider prototyping the documentation with the first airframe, engine, or component to be accomplished. The air carrier should consider performing silent prototyping. Determining whether prototyping the documentation is needed should happen during the planning process. This determination involves reviewing the paperwork, materials, and processes used to comply with the air carrier’s AD work document at the time of execution on the first aircraft, engine, or appliance to which the AD applies.
d. Reviewing Documentation and Action Items.
(1) Once the air carrier finalized its compliance plan, it is considered a best practice to meet again to review the final documentation and ensure all action items are addressed. The meeting’s purpose is to review:
• The compliance documents,
• Associated work cards,
• Tracking system set-up,
• Affected manual revisions,
• Required AMOCs,
• Planning schedule,
• Materials, and
• Continued compliance plan.
(2) On a regular basis the air carrier should perform validation checks; which may range from sample validation required, as with structural repairs with low risk of altering AD requirements, to physical validation at lower level maintenance visits for ADs with a higher risk of not continuing to meet AD requirements. Any action items should be addressed prior to accomplishment on the first aircraft, engine, or component.
(3) It is considered a best practice to invite the FAA certificate management office (CMO) or Flight Standards District Office (FSDO) to participate in the review meeting. This would help identify any regulatory issues that the air carrier may have missed, as well as inform the FAA of the air carrier’s overall compliance plan. FAA participation in this or any other air carrier meeting does not remove the air carrier from the sole responsibility for compliance with the AD requirements and any applicable AMOCs.
Appendix 1 NOTE: Participation of an ASI is at the request of the air carrier. The ASI does not provide concurrence/approval of an air carrier’s compliance decisions.
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.
7. SBs INCORPORATED BY REFERENCE INTO ADs. This section discusses several best practices for SBs related to an AD. These, and other, best practices are documented in the current edition of AC 20-176, Design Approval Holder Best Practices for Service Bulletins Related to
Appendix 1 Page 5 (and 6) Airworthiness Directives. The FAA issues an AD when it finds an unsafe condition exists in a product and the condition is likely to exist or develop in other products of the same type design.
The intent of the action(s) specified in an AD is to detect, prevent, resolve, or eliminate the unsafe condition. Those actions can either be written directly into the regulatory portion (“body”) of the AD, or another document, such as an SB, can be referenced in the AD’s body and submitted to the Office of the Federal Register (OFR) to be incorporated by reference (IBR) approval. Compliance with an SB that is IBR into an AD is mandatory.
a. Safety Intent and Configuration Description. An SB IBR in an AD may contain paragraphs entitled “Safety Intent,” and, for ADs that will change the configuration of a part, “Configuration Description.” The intent of these paragraphs is to enhance and focus awareness of the safety issue during the development and approval of the SB as well as during implementation and subsequent maintenance. The “Safety Intent” paragraph should explain the intended purpose of accomplishing the SB (i.e., prevent, resolve, or otherwise remove the unsafe condition). The paragraph should be a concise and clear statement of the specific technical objective of the instructions. If accomplishing the SB will change configuration, the AD should include a “Configuration Description” paragraph to provide a concise, high-level description of the design change that will result from accomplishing the instructions. The “Configuration Description” should be limited to the features that will prevent development or recurrence of the unsafe condition, after implementation of the configuration. The “Configuration Description” may guide, but cannot be the final determinant of, compliance with an AD.
b. Critical Task Differentiation. An SB may identify steps that have a direct effect on detecting, preventing, resolving, or eliminating the unsafe condition in an AD with “RC” (required for compliance). Any substitutions or changes to the RC steps will require an AMOC approval. Differentiating these steps from other tasks in an SB will improve an owner/operator’s understanding of crucial AD requirements and help provide consistent judgment in AD compliance.
Appendix 2 Page 1 (and 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.
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 RESPONSIBILITIES. 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
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 Page 3 (and 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.