8-1 CHAPTER 8. CONTENT OF AN OPERATOR-DEVELOPED MEL
8.1 MEL Approval Under LOA D195. The MEL approved under LOA D195 consists of two documents: the LOA and the operator-developed MEL.
8.2 MEL Content. This chapter provides detailed content requirements to ensure the operator-developed MEL meets the requirements listed in LOA D195.
1. The MEL must contain the name(s) of the operator(s), aircraft serial and registration numbers (or “Fleet”), aircraft M/M/S, and the MMEL revision number on which the MEL is based.
2. Operators may copy the MMEL format outline directly into their MEL. An operator may also customize their MEL format, provided the format does not make the MEL in any way less restrictive than the MMEL. An MEL may contain corrections to MMEL typos, spelling, and punctuation errors.
3. The MEL must include specific content based on the items installed on the operator’s aircraft. The aircraft operator’s MEL may omit an MMEL item if the item or configuration is not installed or if the operator elects to not take relief.
4. If an operator elects to take relief for items listed in MMEL PLs with a current CG designation, STC Relief Approval Letter, or any design change approval described in Chapter 10, the MEL must comply with the requirements of paragraph 8.5 below for those items.
5. The MEL should incorporate the phraseology used in the MMEL, wherever appropriate, to ensure clarity and standardization.
8.3 MEL Required Sections. The operator-developed MEL must contain the following sections:
8.3.1 Table of Contents. The table of contents is a list of all sections/chapters in the MEL by title and the corresponding page identification. The format may vary due to operator preference.
8.3.2 L og of Revisions. The log of revisions contains the MEL revision identification (typically a number and/or letter) and the date of the MEL revision. At the operator’s discretion, it may also contain a list of the revised pages, a block for the initials of the person posting the change, and additional enhancements for use by the operator. The format may vary due to operator preference.
8.3.3 D efinitions . Definitions of the terms used in MMELs and MELs are found in MMEL PL-25. Operators must include all applicable definitions in their MEL. Not all of the MMEL PL-25 definitions are required to be in an operator’s MEL, as some are related to format issues, specific aircraft types, and certain types of operations. Certain portions of a definition may be edited or are not required, but the intent of the definition must be the same and must not be less restrictive than the definition in MMEL PL-25. Operators may download MMEL PLs from the “MMELs and AED Guidance Documents” section in DRS at https://drs.faa.gov.
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8.3.4 Preamble. The preamble contained in MMEL PL-36 is applicable to all § 91.213(a) MEL approvals under LOA D195. This preamble must be reproduced verbatim in the MEL.
8.3.5 C ontrol Pa ge (LEP). Control pages are used for tracking the status of the MEL and include a record of the revision status or the date of each page of the operator’s MEL. It may also be used as a means of conveying FAA approval of the MEL. The format may vary due to operator preference. At a minimum, control pages must contain:
• The name(s) of the operator(s);
• A listing of all of the pages in the MEL (individually or the range of applicable pages for a given section/chapter), including the date of all pages and their number or revision number; and
• The MMEL revision number on which the MEL is based.
8.3.6 ATA/JASC Coded System Sections. These sections are organized by aircraft system according to the ATA/JASC coded numbering system and include individual item sequence numbers, items, repair categories, number of items installed, number of items required for dispatch, remarks or exceptions, and (M) and (O) procedures. See paragraph 8.5 below for additional information.
8.4 MEL Optional Sections. The operator-developed MEL may include the optional sections listed below. The operator may also include additional sections containing information relevant to their MEL.
8.4.1 Cover Page. The cover page format and information may be the same as the MMEL.
8.4.2 Highlights of Change Page. This page list contains a summary of the changes made by the operator in each revision.
8.5 ATA/JASC Coded System Sections. The operator-developed MEL must be organized using the MMEL ATA/JASC coded numbering system. The MEL ATA/JASC coded system sections will include a list of individual items in the aircraft, together with requirements for operation when the items are inoperative. Each coded system section will be further broken down into individual item sequence numbers.
8.5.1 ATA/JASC System Code Numbers. Operators must use the ATA or JASC coded numbering system. The ATA/JASC numbering system provides an industrywide standard for numbering aircraft systems and is relevant for all aircraft.
8.5.2 I ndividual Item Sequence Number and Items. Individual item sequence numbers are the unique identification for each item within an ATA/JASC system category. The numbering scheme may be modified to align with the aircraft operator’s specific MEL format and may differ from the MMEL. They are not required to match ATA/JASC system item numbers.
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8.5.2.1 A triple asterisk (***) below the system number in column 1 of an MMEL indicates an item that is not required by regulation has been installed on some models of a particular aircraft M/M/S. An operator may not carry the “***” symbol over to the MEL. Operators omit the symbol and use a system sequence number when the item is installed on one or more of the operator’s aircraft.
8.5.2.2 An operator is not required to list all MMEL items in their MEL; however, if a particular item is not in the operator’s MEL, then the item must be fully operative at takeoff.
8.5.2.3 Operators may add limitations and restrictions to a particular item beyond what is required by the MMEL. An operator’s MEL limitations, conditions, and restrictions must never be less restrictive than the MMEL.
8.5.2.4 Operators will typically list an MEL item exactly as it is in the MMEL. If an MMEL uses a generic term to describe a particular item, an operator may use different terminology, provided the operator’s terminology is recognizable and easily identified with the corresponding MMEL item.
8.5.2.5 When an MEL item contains multiple components, those components may be listed separately following the item in the MEL.
8.5.2.6 Operators must not list duplicate items, or items listed individually elsewhere in the MMEL. For ease of use, cross-referencing is permitted.
8.5.2.7 Individual components of an MMEL or MEL item may not be listed as NEF.
8.5.3 Repair Categories. The repair category intervals indicated by the letters A, B, C, and D in column 1 of the MMEL are not applicable to an operator-developed MEL, but operators must comply with any provisos defining a repair interval (e.g., flights, flight legs, cycles, hours, days, etc.). At an operator’s discretion, repair category interval letters (e.g., A, B, C, or D) may be omitted from the MEL. If an operator chooses to include repair categories in their MEL, they may comply with the repair category intervals as a best practice, but they are not mandatory. Inoperative equipment in all cases must be repaired, replaced, removed, or inspected by qualified maintenance personnel at the next required inspection. Refer to § 91.405(c).
8.5.4 Number of Items Installed (Number Installed). The “Number Installed” column of an MEL lists the number (quantity) of the specified item installed on the aircraft.
8.5.4.1 Variable Number Installed. A dash (-) for the number installed indicates a variable number (quantity) of the installed item. The use of a dash (-) is common in fleet MELs where aircraft of the same M/M/S have differing numbers of specific items. A dash (-) is also used for MEL items that provide relief for fault messages (e.g., Crew Alert System (CAS), engine indicating and crew alerting system (EICAS), and electronic centralized aircraft monitoring (ECAM)). Additionally, operators may use a dash (-) if it is
8-4 impractical to show the actual number of the specific items (including but not limited to light bulbs, light-emitting diodes (LED), cabin storage compartments, and cargo lining panels) installed on the aircraft.
8.5.4.2 Items Listed on the MMEL but Not Installed on the Aircraft. An operator’s MEL does not have to list MMEL items not installed on the operator’s aircraft. For number continuity in an MEL, operators may choose to:
1. Simply omit the item from the MEL altogether. The option to either renumber the subsequent individual items or maintain the original MMEL sequence numbering is at the operator’s discretion.
2. List the item in the MEL and then show the “Number Installed” as zero (0). In this case, the “Number Required for Dispatch” would also be zero (0), and the remark “Not Installed” noted under “Remarks or Exceptions.” Additionally, in this case, the repair category designators would be omitted.
8.5.5 Number Required for Dispatch. The “Number Required for Dispatch” column of an MEL reflects the minimum number (quantity) of items required for flight, provided the conditions specified in the “Remarks or Exceptions” are met. The number of items required for dispatch in an MEL may differ from what is required in the MMEL under the following conditions:
1. The item is listed in the MMEL as optional and is not installed on the aircraft. In this c ase, a zero (0) may be shown as the number required, the “Number Installed” shown as zero (0), and the remark “Not Installed” noted under “Remarks or Exceptions.”
Note: An operator’s MEL does not have to list MMEL items not installed on the operator’s aircraft.
2. The “Number Required for Dispatch” is followed by a dash (-) in the MMEL. Where the MMEL shows a variable number (-) required for dispatch, the MEL may reflect the actual number required for dispatch or an alternate means of configuration control approved by the Administrator. An aircraft operator’s MEL may contain a dash (-) where the number required is based on the conditions of flight, such as adequate cockpit lighting. Fleet configuration differences (where applicable) and the dispatch requirements must be specified in the “Remarks or Exceptions” section.
3. The number required for dispatch in the MEL is not less restrictive than the MMEL.
8.5.6 Remarks or Exceptions. The “Remarks or Exceptions” column includes provisos, notes, “as required by 14 CFR” requirements and/or limitations, and (M) and (O) symbols.
Some MMEL “Remarks or Exceptions” are intentionally general to accommodate a variety of operators and operating rules. An MEL must expand upon these general MMEL “Remarks or Exceptions,” as required to adequately and safely address an operator’s particular operations and operating rules. See the examples in paragraph 8.6 below.
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8.5.6.1 Provisos. Provisos are conditions or limitations that must be complied with for operation with the listed item inoperative. The term indicates by association that an item may be deferred, provided that certain conditions are met. If more than one proviso applies, they will be listed separately by number or lowercase letter. For example, a proviso may allow an item to be inoperative provided the airplane is not operated in Extended Operations (ETOPS); and another proviso requires the aircraft only be operated under VFR when that same item is inoperative. In most instances, MEL provisos will be written verbatim from the MMEL, but there are cases where it is acceptable to deviate from the MMEL. However, in every case, the operator MEL will not be less restrictive than the MMEL or the relevant 14 CFR requirement. For example, deleting “established and” from the phrase “alternate procedures are established and used” would not be less restrictive since the inclusion of the procedure in the MEL meets the requirement to “establish” the procedure.
8.5.6.2 Notes. Notes provide additional information for flightcrew or maintenance consideration. Notes are used to identify applicable material intended to assist with compliance but do not relieve the aircraft operator of the responsibility for compliance with all applicable requirements. Additional notes may be added to the aircraft operator’s MEL, as appropriate. Some notes in the MMEL may not be appropriate in an aircraft operator’s MEL and may be amended or deleted. Notes are not a part of the proviso. Where more than one note is included, they will be numbered accordingly (e.g., NOTE 1, NOTE 2).
Notes are repeated, as necessary, following each applicable MEL sub-item.
8.5.6.2.1 Notes may contain a suggestion to aid with compliance such as: “The operator’s alternate procedures should include reviewing wind shear avoidance and wind shear recovery procedures.”
8.5.6.2.2 Notes may be more specific such as: “Flight level (FL) 310 or below must be maintained if normal operating pack fails,” or, “When FCMC 2 is inoperative, fuel quantity indication can have dashes on the two last digits.”
8.5.6.2.3 As appropriate, the operator includes the MMEL note in the MEL, or bases their (M) and (O) procedures on the information contained in the note.
8.5.6.2.4 The information within a note must remain within the scope of the definition of “notes” in MMEL PL-25.
8.5.6.3 As Required by 14 CFR. The MEL must address all items listed in the MMEL containing the statement “as required by 14 CFR,” or any similar statement, based on the items installed on the operator’s aircraft for which the operator desires MEL relief. If the phrase “as required by 14 CFR,” or any similar statement, is used in an MEL, it must accompany information that clearly specifies the regulatory requirement. The MEL will: (1) list the specific 14 CFR part and section (e.g., 14 CFR part 91, § 91.209) and the
8-6 operator must ensure the applicable 14 CFR section is accessible on board the aircraft, or (2) specify the requirements and/or limitations to conduct the flight in accordance with the appropriate 14 CFR regulations. MMEL PL-25 contains a list of regulatory references according to ATA chapter number.
This list is not all-inclusive.
Note: The term “14 CFR” has replaced “Federal aviation regulations (FAR)” as the current reference to Federal regulations pertaining to aviation. Many MMELs and MELs still contain the acronym “FAR” and should be updated to “14 CFR” as they are revised.
8.5.6.4 (M) and (O) Symbols and Procedures. The presence of either (M) or (O) symbols in the MMEL “Remarks or Exceptions” column indicates specific (M) or (O) procedures are required to be accomplished prior to operation with the listed item inoperative. The MEL must contain (M) and (O) procedures corresponding to the (M) and (O) provisos listed in the MMEL for all installed equipment for which the operator desires MEL relief.
8.5.6.5 MEL (M) and (O) Procedures. The MEL (M) and (O) procedures:
1. Must meet the intent of the (M) and (O) provisos in the MMEL.
2. Must never be less restrictive than the (M) and (O) provisos in the MMEL.
3. May be either manufacturer’s (M) and (O) procedures or operator-developed (M) and (O) procedures.
4. May be developed from the manufacturer’s (M) and (O) procedures or the guidance provided in the manufacturer’s AFM, RFM, or AMM, manufacturer’s recommendations, engineering specifications, and other appropriate sources. Operators are not required to copy the manufacturer’s recommended (M) and (O) procedures verbatim in their MEL. When a manufacturer-recommended procedure exists, the operator may use it as published or develop equivalent procedures for their MEL.
5. Must comply with all 14 CFR requirements and must not deviate from the AFM/RFM limitations, emergency procedures, or AD, all of which take precedence over the MEL.
6. Must specify suitable conditions and limitations in the form of placards, maintenance procedures, crew operating procedures, and other restrictions, which must be accomplished by the operator. As part of the review and approval process, the FAA may ask the operator to include additional instructions within the procedure to ensure that deferral procedures will continue to provide an ALoS.
7. May be presented in a variety of formats and locations at the discretion of the operator. For example, they may be placed in separate columns, below the MEL table or included in an appendix to the MEL. They may be
8-7 included in the “Remarks or Exceptions” column, but must be clearly distinct from the (M) and (O) provisos.
8. Are subject to FAA review and validation to ensure they are adequate for the relief sought.
9. May be fully depicted in the operator’s MEL or in another manual. If a procedure is contained in another manual, the MEL should provide a specific reference to that manual. See paragraph 8.5.6.6 below.
8.5.6.6 Reference to an FAA-Approved or FAA-Accepted Manual. An operator may include a reference to the appropriate FAA-approved or FAA-accepted manual that contains the procedure(s) required to address a particular MEL item. Only FAA-approved or FAA-accepted manuals may be referenced in the MEL. The following requirements apply when referencing these manuals:
1. Manual references must be preceded by either a proviso(s) or specific instruction(s) defining the action required. A single proviso or specific instruction may have more than one manual reference associated with it.
2. Manual references must direct the use of that manual, including adequate information (e.g., chapter, section, task, or paragraph references) for the user to find the proper procedure. The actual revision level/date of the manual is not required in the MEL.
3. The proviso or specific instruction and manual reference in the MEL is considered the means of compliance for MEL purposes and is FAA-approved. The actual procedure referenced is either FAA-approved or FAA-accepted depending on the status of the manual referenced.
8.6 Example Proviso, “As Required by 14 CFR,” and (M) and (O) Procedures.
Figures 8-1(a) through 8-4(c) demonstrate the differences between general information contained in the MMEL “Remarks or Exceptions” column and specific operator-developed MEL information. These are examples only and are not intended to be used or depicted as actual MMEL or MEL procedures.
8.6.1 E xample Provisos. When an MMEL contains general remarks , such as, “May be inoperative provided procedures do not require its use,” or “May be inoperative or missing if alternate procedures are established and used,” the operator must be specific in the MEL.
8.6.1.1 If there are no operator procedures that rely on the item listed in the MMEL, then the MEL may simply state, “Procedures do not require its use; may be inoperative,” or use a similar statement.
8.6.1.2 If there are operator procedures that rely on the item listed in the MMEL, then the MEL remark states the conditions or limitations which apply to operations with that equipment inoperative. For example, “May be inoperative provided overwater operations are not conducted,” or, “May be inoperative provided long-range communications procedures do not require its use.”
8.6.1.3 If there are operator procedures that rely on the item listed in the MMEL, but there is alternate equipment that could be used, then the MEL remark notes the use of that equipment (and thus, must be operative). For example, "HDG HOLD Mode. May be inoperative provided HDG SEL or LNAV autopilot/flight director mode(s) is operative."
8.6.1.4 There may be cases where the dispatch decision needs to be made by the PIC based on conditions at the departure or destination airport, or along the route of flight. These conditions could result from Notice to Air Missions (NOTAM) information or ground-based equipment outages. These situations would be known only to the pilot when preparing for specific flights;
therefore, a more general proviso would be appropriate. For example, "May be inoperative provided departure, en route, or arrival/approach procedures do not require its use."
8.6.1.5 Where the MMEL contains an unconditional statement, such as, "May be inoperative or missing," the MEL may leave the statement unmodified, or even omit the statement if the operator's procedures or operations do not require the item's use.
8.6.2 Example "As Required by 14 CFR" Statements.
Figure 8-1(a). Example MMEL General "As Required by 14 CFR" Statement
TABLE KEY
1. REPAIR CATEGORY AIRCRAFT: 2. NO. INSTALLED (insert aircraft make and model)
3. NO. REQUIRED FOR DISPATCH
4. REMARKS OR EXCEPTIONS
33. LIGHTS Change Sequence No. Item 1 2 4 Bar 33-07 Landing Light C As required by 14 CFR Figure 8-1(b). Example MEL Specific "As Required by 14 CFR" Regulatory Reference (The operator must ensure the applicable 14 CFR section is accessible on board the aircraft.)
TABLE KEY
1. REPAIR CATEGORY AIRCRAFT:
2. NO. INSTALLED (insert aircraft make and model) 3. NO. REQUIRED FOR DISPATCH
4. REMARKS OR EXCEPTIONS
33. LIGHTS Sequence No. Item 1 2 4 Change Bar 33-07 Landing Light 14 CFR Reference: 14 CFR 91.205(c)(4) and
91.205(d)(1).
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Figure 8-1(c). Example MEL Specific "As Required by 14 CFR" Requirement/Limitation
TABLE KEY
1. REPAIR CATEGORY (insert aircraft make and model) AIRCRAFT: 2. NO. INSTALLED 3. NO. REQUIRED FOR DISPATCH
4. REMARKS OR EXCEPTIONS
33. LIGHTS Sequence No. Item Change Bar 33-07 Landing Light The landing light must be operative for night flight operations if the aircraft is being operated for hire.
Note: Illustrated in the examples above, the MEL will: (1) list the specific 14 CFR part and section (and the operator must ensure the applicable 14 CFR section is accessible on board the aircraft), or (2) specify the requirements and/or limitations to conduct the flight in accordance with the appropriate 14 CFR regulations.
8.6.3 Example (M) and (O) Symbols and Procedures.
Figure 8-2(a). Example 1 MMEL General Maintenance (M) and Operations (O) Symbols and Provisos
TABLE KEY
1. REPAIR CATEGORY AIRCRAFT:
2. NO. INSTALLED (insert aircraft make and model)
3. NO. REQUIRED FOR DISPATCH
4. REMARKS OR EXCEPTIONS
78. Engine Exhaust Sequence No. Item Change Bar -30-01 Thrust Reverser 0 (M)(O) May be inoperative provided:
a) Affected thrust reverseris locked in the forward thrust position, and
b) Appropriate performance penalties are applied.
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Figure 8-2(b). Example 1 MEL Specific Maintenance (M) and Operations (O) Symbols and Provisos
TABLE KEY
1. REPAIR CATEGORY AIRCRAFT: 2. NO. INSTALLED (insert aircraft make and model) 3. NO. REQUIRED FOR DISPATCH
4. REMARKS OR EXCEPTIONS
78. Engine Exhaust Sequence No. Item → 28 MO) Maybe Change Bar -30-01 Thrust Reverser (M)(O) May be inoperative provided:
a) Affected thrust reverseris locked in the forward thrust position, and
b) Appropriate performance penalties are applied.
Figure 8-2(c). Example 1 MEL Specific Maintenance (M) and Operations (O) Procedures 78-30-01:
Maintenance (M) Procedure Lock affected thrust reverser in the forward thrust position in accordance with AMM 78-30-12.
Operations (O) Procedure Refer to AFM Performance Section, Thrust Reverser inoperative for applicable takeoff and landing penalties.
Note: AMM 78-30-12 and the AFM in the above example are FAA-approved or FAA-accepted manuals.
Figure 8-3(a). Example 2 MMEL General Maintenance (M) Symbol and Proviso
TABLE KEY
1. REPAIR CATEGORY AIRCRAFT:
2. NO. INSTALLED (insert aircraft make and model) 3. NO. REQUIRED FOR DISPATCH
4. REMARKS OR EXCEPTIONS
28. FUEL Sequence No. Item 2 4 Chang e Bar 28-21-25 XBP Crossfeed Valve 2 (M) One or more may be inoperative in closed position provided:
a) All Booster Pumps are operative,
b) Affected XBP Crossfeed Valve is secured in closed position, and
c) Repairs are made within 3 consecutive calendar-days.
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Figure 8-3(b). Example 2 MEL Specific Maintenance (M) Symbol and Proviso
TABLE KEY
1. REPAIR CATEGORY AIRCRAFT:
2. NO. INSTALLED (insert aircraft make and model) 3. NO. REQUIRED FOR DISPATCH
4. REMARKS OR EXCEPTIONS
28. FUEL Sequence No. Item 1 3 4 Change Bar 28-21-25 XBP Crossfeed Valve 2 (M) One or more may be inoperative in dosed position provided:
a) All Booster Pumps are operative,
b) Affected XBP Crossfeed Valve is secured in closed position, and
c) Repairs are made within 3 consecutive calendar-days.
Figure 8-3(c). Example 2 MEL Specific Maintenance (M) Procedure 28-21-25:
Maintenance (M) Procedure CROSSFEED VALVE IN CLOSED POSITION:
1. Open the door 170AB.
2. Check that the inoperative XBP crossfeed valve (400QS/410QS) is in close position ("C").
NOTE: If not, set the valve to close ("C") using the lever.
3. Disconnect the electrical connector.
4. Close the door 170AB.
NOTE: Place inoperative placard near MDU.
Figure 8-4(a). Example 3 MMEL General Operation (O) Symbol and Proviso
TABLE KEY
1. REPAIR CATEGORY AIRCRAFT:
2. NO. INSTALLED (insert aircraft make and model)
3. NO. REQUIRED FOR DISPATCH
4. REMARKS OR EXCEPTIONS
23. COMMUNICATIONS Sequence No. Item 1 2 4 Change Bar -43-01 Flight Deck to Ground B (O) May be inoperative provided Interphone System alternative procedures are established and used.
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8-12 Figure 8-4(b). Example 3 MEL Specific Operations (O) Symbol and Proviso F igure 8-4(c). Example 3 MEL Specific Operations (O) Procedure 23-43-01:
Operations (O) Procedure May be inoperative provided:
1. Verify to ground crew personnel before main cabin door is closed that ECAM message NW STRG DISC is displayed.
2. Use company hand signals as required. Refer to Ramp Operations Manual, Chapter 1, for a complete list of company hand signals.
Note 1: The Ramp Operations Manual in the above example is an FAA-approved or FAA-accepted manual.
Note 2: The proviso in the above MEL example was changed from the MMEL proviso because alternative procedures “are established.”