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.”
9-1 CHAPTER 9. MEL REVISIONS
9.1 General. MEL revisions may be initiated by either the FAA or the operator. The revision to an operator’s MEL must comply with the conditions and limitations of the operator’s MEL LOA.
• MEL revisions for an MMEL used as an MEL under LOA D095 consist of using the latest mandatory MMEL revision and revising the procedures document, as required.
• MEL revisions for an operator-developed MEL under LOA D195 consist of revising the operator-developed MEL.
9.1.1 O perator Responsibility to Obtain MMEL Revisions. It is the responsibility of an operator to obtain the latest revisions to their MMEL, applicable STC Relief Approval Letter, and applicable MMEL PLs. Operators may download these documents from the “MMELs and AED Guidance Documents” section in DRS at https://drs.faa.gov.
Note: Operators may keep informed of MMEL revisions by subscribing to receive automatic email notifications for their aircraft. To subscribe, visit https://service.govdelivery.com/accounts/USFAAMMEL/subscriber/new.
9.1.2 Submission of Revised Operator-Developed MEL to the FAA for Approval. Operators must submit revisions to an operator-developed MEL under LOA D195 to the responsible Flight Standards office for approval. An electronic copy is preferred. The revised MEL may not be used prior to FAA approval. Holders of LOA D095 are not required to submit a revised procedures document to the FAA.
Note: M EL revisions solely for the purpose of documenting the inappli cability of a mandatory MMEL revision, or to incorporate revised MMEL PL-25 or PL-36 content, are not required to be submitted to the FAA. If the control page is revised, the operator will retain the previous FAA-signed MEL control page(s) or LEP within the MEL.
9.2 F AA- Initiated MEL Revisions. An FAA-initiated MEL revision may be due to an MMEL revision, MMEL PL revision, AD, or deficiencies discovered in the MEL.
9.2.1 MME L Revision. There are two types of MMEL revisions: nonmandatory/interim, and mandatory/standard.
9.2.1.1 N onmandatory/Interim MMEL Revision. A nonmandatory/interim MMEL revision means that revision to an operator’s MEL is optional and not required. If the relief granted by the nonmandatory/interim MMEL revision is applicable to an operator’s aircraft operations, then it is advisable the operator revise their MEL to incorporate the MMEL revision. If the nonmandatory/interim MMEL revision is not applicable to an operator’s aircraft operations, they may disregard the MMEL revision altogether. For example, a nonmandatory/interim MMEL revision is issued to provide for optional equipment such as logo lights, which are not installed on all aircraft
9-2 of a particular type. Operators operating an aircraft without logo lights may simply ignore the MMEL revision. Operators operating an aircraft with logo lights may choose to incorporate the MMEL revision if the operator would like MEL relief for inoperative logo lights.
1. A nonmandatory/interim MMEL revision is identified by the current standard revision number plus a lowercase letter. For example, a nonmandatory/interim revision following revision 5 will be identified as revision 5a. There may be subsequent interim revisions to the same standard revision. These subsequent revisions carry the next lowercase letter (e.g., 5b, 5c, or 5d).
2. The operator’s MEL revision number does not have to match the MMEL revision number. Operators may use their own revision numbering system.
3. If an MMEL revision results in a change to the system number, sequence item number, repair interval, or proviso, the operator does not need to modify or close an open MEL item and reinitiate it. Instead, the item may continue to be tracked under its original deferral until the item is repaired and the deferral cleared.
9.2.1.2 Mandatory/Standard MMEL Revision. A mandatory/standard MMEL revision means that revision to an operator’s MEL is required. A mandatory/standard MMEL revision includes changes applicable to all operators using an MEL for a specific aircraft type.
9.2.1.2.1 A mandatory/standard MMEL revision is identified by the next successive change to the basic MMEL revision number. For example, the next mandatory/standard revision following nonmandatory/interim revision 6a, 6b, or 6c is revision 7. The next mandatory/standard revision following revision 7 is revision 8.
9.2.1.2.2 The operator is required to review the mandatory/standard MMEL revision to determine if the more restrictive revised content is applicable to their aircraft and operation. If so, the operator must revise their MEL as follows:
1. For an MMEL used as an MEL under LOA D095: Within 90 calendar days of the date of the MMEL revision, the operator must revise their procedures document. The revision must address (M) and (O) or “as required by 14 CFR” procedures, as applicable. If no changes are determined to be applicable to the aircraft or operator, then the operator is not required to update the procedures document. However, the FAA recommends the operator make a statement in the procedures document that the mandatory revision has been reviewed and determined not to apply. Regardless, the procedures document must contain the MMEL revision number on which the MEL is based.
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2. For an operator-developed MEL under LOA D195:
a. If the revised content of the mandatory/standard MMEL revision is applicable, the operator must revise their MEL and incorporate applicable changes and submit it to the responsible Flight Standards office for approval within 90 calendar days of the date of the MMEL revision. The revised MEL may not be used prior to FAA approval.
b. If the revised content of the mandatory/standard MMEL revision is not applicable, within 90 calendar days of the revision, the operator must document its inapplicability. Revise the MEL control page(s) or LEP to indicate the MEL is in compliance with the required MMEL revision. The operator will retain the previous FAA-signed MEL control page(s) or LEP within the MEL.
c. Irrespective of applicability, the operator-developed MEL must contain the MMEL revision number on which the MEL is based.
9.2.1.2.3 If an MMEL revision results in a more restrictive proviso, the operator does not have to close and reinitiate an existing open MEL item affected by the revision. Existing MEL items may remain open in accordance with the original proviso under which the item was initially deferred until such time as the item is repaired or replaced and the MEL item is closed.
9.2.1.2.4 If an MMEL revision results in a change to the system number or sequence item number, the operator does not need to modify or close an open MEL item and reinitiate it under its new number. Instead, the item may continue to be tracked under its original item number until the item is repaired and the deferral cleared.
9.2.2 Revisions as a Result of an MMEL PL with a GC Designation. An operator may revise their MEL based on relief available in an MMEL PL with a current GC designation. An operator is not required to include GC designation relief in their MEL. See paragraph 2.6 above for detailed information on MMEL PLs with a GC designation.
9.2.3 R evisions Initiated by the Responsible Flight Standards Office. The responsible Flight Standards office may initiate an MEL revision for reasons such as the issuance of an AD, upon discovery of deficiencies in the operator’s MEL (including (M) and (O) procedures), or upon discovery that the operator has modified their aircraft.
9.2.3.1 The responsible Flight Standards office will inform the operator of the need to revise their MEL in writing and provide the reasons why the revision must be accomplished.
9.2.3.2 The responsible Flight Standards office will allow the operator 90 calendar days to complete the revision process. An operator may request an extension for developing an MEL revision. If the responsible Flight Standards office determines the safety of flight could be affected (e.g., AD), they may specify a shorter period of time.