Volume 3 GENERAL TECHNICAL ADMINISTRATION
CHAPTER 43 EVALUATE A CONTINUOUS AIRWORTHINESS MAINTENANCE PROGRAM
Section 1 Safety Assurance System: Evaluate a Part
121 and Part
135 Continuous Airworthiness Maintenance Program
3-3866 REPORTING SYSTEM. Use Safety Assurance System (SAS) automation. This section is related to SAS Element 4.2.1, Maintenance/Inspection Requirements.
NOTE: Due to the complex nature of a Continuous Airworthiness Maintenance Program (CAMP), other SAS elements may apply to this section.
3-3867 OBJECTIVE. This section provides the information, policy, and guidance that the inspector needs to evaluate a Title 14 of the Code of Federal
Regulations (14 CFR) part
119 certificate holder’s CAMP according to applicable 14 CFR
regulations and Federal Aviation Administration (FAA) policy. The FAA wrote this section to agree with Advisory Circular
(AC) 120-16, Air Carrier Maintenance Programs, because the AC is an acceptable
method of compliance with the regulations. For the purpose of this section, a CAMP, a Maintenance, Preventive Maintenance, and Alteration Program are the same.
NOTE: This order contains other sections for some of the CAMP elements. For example, inspectors can find guidance for evaluating required inspections both in this
section and in
Volume 3, Chapter 43, Section 2. When another section exists, the inspector must follow
the guidance in both sections, as applicable, when evaluating a CAMP.
A. Legal Basis of Air Carrier Maintenance Programs. To understand why 14 CFR parts
135 govern persons and the performance of all air
carrier maintenance while other regulations, such as part
145, do not, it is essential to understand Title 49
of the United States Code (49 U.S.C.). The following information on 49 U.S.C. helps explain the different standards used for developing regulations for air commerce and regulations for air
1) Title 49 U.S.C. Title 49 U.S.C. § 44701 is the primary authority
for all air carrier 14 CFRs. Title 49 U.S.C. § 44701 requires the FAA to promote
the safe flight of civil aircraft in air commerce by prescribing regulations
and standards in the interest of safety.
2) Air Commerce. When prescribing regulations and standards, § 44701 also requires the FAA to:
· Consider an air carrier’s duty to provide service with the highest
possible degree of safety in the public interest,
· Consider differences between air transportation and other air
· Classify a regulation or standard appropriate to the differences
between air transportation and other air commerce.
a) Title 49 U.S.C. § 40102 defines the term “air commerce” as:
· Foreign air commerce,
· Interstate air commerce,
· Transportation of mail by aircraft,
· Operation of aircraft within the limits of a Federal airway,
· Operation of aircraft that directly affects, or may endanger safety
in, foreign or interstate air commerce.
b) Operations in air commerce include almost every type of operation but air transportation.
3) Regulations. Consistent with the requirements of § 44701,
the FAA regulates aircraft operations at different levels of safety. Therefore,
FAA regulations that govern air carrier operations (air transportation) and
the operations of other air commerce have different structures to reflect the
differences between these two segments of the aviation industry. Establishing
appropriate standards and regulatory requirements is a risk management process,
and the underlying legal structure provides for more than one level of acceptable
risk appropriate to different types of flight operations. Air transportation
regulations are all-inclusive and stand alone, whereas the regulations governing
other air commerce are not. Similarly, the scope of responsibility for those
in air transportation operations is very broad and not shared (e.g., the air
carrier is responsible for the performance of maintenance and airworthiness
of its aircraft), whereas in other air commerce, the scope of responsibility
is relatively narrow and commonly shared (e.g., the owner/operator in 14 CFR part
91 is responsible for having maintenance performed
on its aircraft, and the mechanic is responsible for the performance of maintenance and airworthiness of the aircraft). The regulations in parts
135 relate directly to air carrier maintenance
programs and reflect the highest possible degree of safety in the public interest. The regulations in 14 CFR
145 do not necessarily reflect the highest possible
degree of safety in the public interest. This section contains specific references to relevant regulations in subsequent paragraphs.
4) Performance-Based Regulations. Most of the part
121 and part
135 maintenance regulations appear in a
performance-based format. The performance-based
regulatory approach focuses on measurable outcomes, rather than prescriptive
processes, techniques, or procedures. Performance-based regulation leads to
defined results without specifying directions or instructions regarding how
to obtain those results. This approach permits these regulations to apply to
a wide variety of certificate holders and still have the same standards. For
example, the performance‑based regulations at part
121.367 and part
135.425 apply equally to all operators, regardless of number of aircraft.
The defined result is always an airworthy aircraft that the air carrier has
properly maintained for operations in air transportation. Performance-based
regulation also permits the regulation to remain current in the face of advances
in technology or methodology.
5) Acceptable Means of Compliance. Performance-based regulation
also explains what constitutes an acceptable means of compliance. This section
shows acceptable methods of compliance with the performance‑based maintenance
program regulatory requirements, including descriptions of processes, techniques,
and procedures that will lead to the defined results in the maintenance regulations.
The air carrier should tailor its maintenance program to its particular and
specific operation; therefore, regulations cannot provide a single means of
compliance that applies to all certificate holders required to develop and implement
an air carrier maintenance program.
6) Continuous Airworthiness Program (CAP). The FAA introduced
the CAP in a final rule at 29 Federal Register (FR) 6522 on May 20, 1964. “CAMP”
is a colloquial term for “CAP.” This 1964 rulemaking was the FAA’s response
to safety concerns and discoveries of weaknesses in the maintenance programs
of some air carriers that the FAA found during accident investigations and surveillance
of operator maintenance activities. The FAA designed the air carrier CAP to
strengthen requirements for air carrier safety management activities. Each one
of the air carrier maintenance program elements described in this section was
a part of 29 FR 6522.
NOTE: Do not confuse the above acronym CAP for the Comprehensive Assessment
Plan (CAP) and/or corrective action plan (CAP) as used in other guidance.
7) Requirements for a CAMP. The regulations require a CAMP for
part 119‑certificated air carriers operating under parts
135 with aircraft that have a passenger-seating
configuration, excluding any pilot seat, of 10 or more seats. For part
135 operations, this guidance applies to any
aircraft using the maintenance program provisions of §
135.411(a)(2). It also applies to air carriers choosing to maintain its
aircraft under a CAMP as provided in §
135.411(b) and air carriers choosing to operate under §
135.364, Extended Operations (ETOPS), as provided in §
B. Maintenance Program Authorization. The FAA does not approve
air carrier maintenance programs because there is no regulation that requires
approval. However, the FAA issues air carrier operations specifications (OpSpecs)
to the air carrier, authorizing it to use a maintenance program and the air
carrier maintenance manual required by the FAA regulations. Tailored to the
air carrier’s specific operating context and the requirements of its individual
operations, the OpSpecs convey the general terms of regulations into specific
terms, conditions, and limitations. The FAA amends the OpSpecs as circumstances
dictate. Issued by the FAA, the OpSpecs are legally binding through specific
regulatory language (see part
119.33 for the applicable language). See
Volume 3, Chapter 18, Section 1 for additional information on OpSpecs.
C. Air Carrier Maintenance Program Objectives.
1) Program Objectives. The air carrier’s maintenance program
must ensure the following three specific program objectives stated in §§
135.425 in order to provide the highest possible level of safety in air
a) Maintenance, preventive maintenance, and alterations performed
by it, or by other persons, are performed in accordance with the certificate
holder’s maintenance manual;
b) Competent personnel, and adequate facilities and equipment are
provided for the proper performance of maintenance, preventive maintenance,
and alterations; and
c) Each aircraft released to service is airworthy and has been properly
maintained for operation under this part.
2) Continuing Analysis and Surveillance System (CASS). The air
carrier’s maintenance program must also have a system of continuing surveillance,
investigation, data collection, analysis, corrective action, and corrective
action followup that ensures all parts of its maintenance program are effective
and are being performed in accordance with the air carrier’s manual. “Effective”
means that the air carrier is achieving the desired results according to the
maintenance program objectives and the standards that the air carrier set. “Program
performance” means that all personnel, including air carrier maintenance providers,
are following the air carrier’s program as it has documented in its manual.
D. Air Carrier Maintenance Program Elements. The air carrier’s
maintenance program must include the following 10 elements. Individual explanations
of each of these elements appear in paragraphs 3-3869 through 3-3878.
· Airworthiness responsibility.
· Air carrier maintenance manual.
· Air carrier maintenance organization.
· Accomplishment and approval of maintenance and alterations.
· Maintenance schedule.
· Required Inspection Items (RII).
· Maintenance recordkeeping system.
· Contract maintenance.
· Personnel training.
3-3869 AIRWORTHINESS RESPONSIBILITY.
A. Responsibility for Aircraft Maintenance.
119 Certificate Holder Responsibilities.
Consistent with §§
135.413, the air carrier (as a part
119 certificate holder,) is primarily responsible
for the airworthiness of its aircraft and the performance of all of the maintenance or alterations
on its aircraft. A keyword in the previous statement is “primarily,” which recognizes
responsibilities associated with other persons that perform maintenance for
the air carrier. The air carrier’s certificate makes it a maintenance entity.
Under its air carrier certificate, it may accomplish its own maintenance, preventive
maintenance, or alterations, or it can use other persons who are not direct
employees to accomplish that work. Parts
135 govern each person that the air carrier uses or
that it employs for any maintenance, preventive maintenance, or alteration of its aircraft (see §§
135.1(a)(2)). Each person whom the air carrier uses must be under the air
carrier’s direction and control and must follow the air carrier’s maintenance program. Recognizing parts
135 as the governing regulations for the performance
of all air carrier maintenance by all persons is important to understanding why other regulations such as part
145 do not govern air carrier maintenance.
2) Maintenance Responsibilities. For any work completed on the
air carrier’s aircraft, the air carrier retains direct and primary responsibility
for performing and approving all maintenance and alterations, whether it accomplishes
that work or someone else does it for them (e.g. a maintenance provider, such
as a repair station). The air carrier always retains primary responsibility
for the performance and approval of the maintenance completed by that maintenance provider.
B. Differences Between Programs. The following table provides
a comparison of the differences between air carrier maintenance programs (air
transportation) and part
91 general aviation inspection programs (air
Table 3-125. Air Carrier Maintenance Programs and Part
91 General Aviation Inspection Programs
Use of a maintenance or an inspection program.
Required to use a maintenance program for its aircraft.
Required to use an inspection program.
Responsibilities within the relevant program.
Responsible for the performance of maintenance
in accordance with its maintenance program and manual, as well as the
airworthiness of its aircraft, including airframes, aircraft engines,
propellers, appliances, and parts thereof.
Responsible for maintaining the aircraft in an
airworthy condition (part
The wording in part
91 is deliberately different from the
wording in 14 CFR parts
135 and is consistent with the difference
between air carriers and other air commerce as described in 49 U.S.C. § 44701.
Responsible for the development and use of the
maintenance program and manual, determining the method of performing
maintenance, a required inspection list, a CASS, a maintenance organization
that can exercise operational control over maintenance operations, and
other items that collectively and systematically serve to ensure that
each aircraft has been properly maintained for operations in air transportation
and is airworthy.
Responsible for the selection of an existing inspection
program, scheduling aircraft for inspection, and ensuring that persons
authorized to perform and approve maintenance, preventive maintenance,
and alterations repair and approve discrepancies that occur between
Must determine what maintenance is required, how
to do it, when to do it, perform that maintenance, and approve its own
aircraft for return to service. May authorize another person to accomplish
the maintenance work, but the other person must carry out the maintenance
work according to the air carrier’s maintenance program and manual.
The air carrier retains the responsibility for the proper completion
of maintenance (part
121.363 or part
Must make the airplane available to authorized
and certificated person(s) who accomplish inspections and other maintenance.
Along with the FAA oversight, it is the primary
authority with regard to its maintenance program. Holds the primary
responsibility for the performance of maintenance in accordance with
its maintenance program and manual, as well as the airworthiness of
its aircraft, including airframes, aircraft engines, propellers, appliances,
and parts thereof.
The authorized and certificated person(s) has the
responsibility to perform the maintenance properly in accordance with
the manufacturer’s manual and to approve the aircraft for return to
service. The owner/operator does not have this responsibility. However,
the owner/operator is responsible for ensuring that maintenance personnel
make appropriate entries in the aircraft maintenance records indicating
that the aircraft has been approved for return to service.
A. Air Carrier Maintenance Manual Requirement.
1) Maintenance Manuals. The FAA regulations (§§
135.427) require the air carrier to have a maintenance manual. It is a required
part of the air carrier manual system. Some air carriers call their manuals
“specifications” and some use other terms. Traditionally, the air carrier has
geared its maintenance manual toward maintenance performed in-house by its employees.
If the air carrier chooses to use another person to perform maintenance for
it, it must have well-defined maintenance procedures in its manual for the maintenance
provider to follow.
2) Revising Maintenance Manuals. The air carrier’s maintenance
manual must be easy to revise and have procedures for keeping all parts of the
manual up to date. The manual may be electronic or in another form.
3) Current and Available. The air carrier must make copies of
its manual or appropriate portions of it (and changes or additions) available
to those persons required to comply with it. Additionally, the air carrier must
furnish its manual to principal inspectors (PI) assigned to the air carrier.
Each person who receives a manual or appropriate parts from the air carrier
must keep it up to date.
4) Interface Attribute. The air carrier’s maintenance manual
must interface with other air carrier manuals, such as those required by part
121 subpart G and §
135.21. Interfaces occur in a procedure where the responsibility for accomplishing
work is transferred from one person, work group, or organization to another.
(For example, if an aircraft discrepancy occurs during flight operations and
the discrepancy must be fixed, operations transfers control to maintenance.
When maintenance is finished, it transfers control back to operations.) Procedures
must be detailed to ensure the smooth transfer of work and information.
5) Other Related Regulations. Other regulations that relate to
air carrier manual requirements are
part 43, §
B. Role of the Air Carrier Maintenance Manual.
1) Standardization. The air carrier’s maintenance manual is its
key to standardized, consistent accomplishment and administration of its maintenance
program. The air carrier’s maintenance manual:
a) Identifies, describes, and defines its maintenance program.
b) Provides instructions and procedures to administer, use, manage,
and amend its program.
2) Organization and Format. The air carrier’s maintenance manual
is a company publication, and the air carrier has sole responsibility for its
organization and content; however, others may compile and publish it for the
air carrier. The air carrier’s maintenance manual may be electronic.
C. Major Sections of the Typical Air Carrier Maintenance Manual.
1) Organization of the Air Carrier’s Maintenance Manual. The
air carrier’s maintenance manual should have a practical organization. Typically,
it will have at least three sections covering administrative policies and procedures;
detailed instructions for the administration, management, and accomplishment
of the elements of its maintenance program; and technical data that describes
maintenance standards, methods, techniques, and procedures.
2) Administrative Policies and Procedures. The primary function
of this part of the air carrier’s manual is as a management and administrative
tool for organizing, directing, amending, and controlling its maintenance program.
Usually, the air carrier will place required organizational charts delineating
the functions, relationships, and lines of authority between its organizational
elements and personnel in its manual. The air carrier may list position descriptions,
duties, responsibilities, and specific authority and responsibility attributes
for each position within its maintenance organization in its manual. The authority
and responsibility attributes that the air carrier incorporates should show
who has overall authority and/or responsibility and who has direct authority
and/or responsibility for given functions.
3) Instructions for the Administration, Management, and Accomplishment
of the Maintenance Program.
a) This section contains detailed instructions for the air carrier’s
management of the various functions and interrelationships of each maintenance
program element, such as maintenance time limitations, recordkeeping, Airworthiness
Directive (AD) management, maintenance program management and oversight, contract
maintenance management and oversight, and personnel training. This section usually
includes a description of the air carrier’s scheduled maintenance tasks, procedural
information, and detailed instructions (or specific air carrier maintenance
manual references) for accomplishing its maintenance tasks. Additionally, the
air carrier should describe criteria for initiating functional evaluation flights (see §
91.407) in this part of the maintenance manual, along with procedural requirements
for them. In this portion of the air carrier’s manual, the air carrier should
also include criteria and procedural information for unscheduled inspections,
such as those associated with lightning strikes, tail strikes, exceeding engine
temperature, hard or overweight landings, and any very high-load event.
b) The air carrier should have a comprehensive process in the unscheduled
maintenance portion of its manual that addresses those rare, extremely high-load
events that occur to aircraft. Specifically, the air carrier should have inspection
processes that it should use following certain high-load events. These particular
high‑load events are those for which flight data might facilitate the subsequent
inspection process. The air carrier should consider the events listed below as most significant:
1. Flight Events.
· A severe turbulence encounter,
· Extreme maneuvers,
· Exceeding speed limitations, and
· Heavy stall buffet.
2. Ground Events.
· Hard landings,
· Overweight landings, and
· Drift landings resulting in excessive side/drag load.
· High Energy Wide Area Blunt Impact (HEWABI)
c) Typically, the Original Equipment Manufacturer (OEM) will include
detailed inspection instructions that the air carrier should follow after these
high-load events. The objective of these instructions is to detect aircraft
damage following an in-service flight or ground event. While there are many
conditions that can result in high loads on the airframe and subsequent structural
damage, the FAA considers the use of flight data in the air carrier’s inspection
process to be particularly beneficial for the events identified above.
d) The use of composites in aircraft structures and other components has increased fuel savings by reducing weight without sacrificing structural strength. These
characteristics are vital to meeting the demands of the aerospace industry.
However, damage from a HEWABI event may not be clearly visible. Air carriers
should include inspection procedures in their maintenance program to be utilized
when a HEWABI event has occurred. HEWABI events are impacts that are spread
over a large area of the composite structure and may cause considerable structural
damage with minimal external indications. A high energy impact is when the type,
force, or cause is significant with or without the result of damage you can
visually see. High energy impacts must be reported and addressed.
e) The air carrier’s processes for evaluating these events should
address an appropriate indication that an event has occurred, an evaluation
of the severity of the event, and coordination with the manufacturer, as appropriate.
f) The air carrier’s special inspection procedures for high-load events should:
· Identify that a very high‑load event has occurred;
· Assure that indications of structural damage are found in an initial inspection;
· Involve the OEM, if necessary;
· Provide a process for additional inspections that are designed
to identify all of the structural damage; and
· Provide a process for approval for return to service.
D. Technical Data That Describe Maintenance Standards, Methods, Techniques, and Procedures.
1) Program Management and Technical Data. This section of the
air carrier’s manual concerns detailed procedures for accomplishing specific
tasks (e.g., methods, techniques, technical standards, measurements, calibration
standards, operational tests, structural repairs). The air carrier should also
include procedures for aircraft Weight and Balance (W&B), jacking, lifting,
shoring, storage, cold weather operations, towing, aircraft taxi, and aircraft
cleaning. The air carrier can derive its maintenance manual contents from the
manufacturer’s publications. However, based on the air carrier’s particular
service experience, organization, and operating context, the FAA expects the
air carrier to continuously modify and customize its maintenance manual as necessary
for the continuing success of its maintenance program. This is one of the desired
outcomes of a well-functioning CASS.
2) ADs. The air carrier is required to accomplish the provisions of 14 CFR part
39 ADs. The air carrier should have a management
process in its manual for evaluating, accomplishing, and verifying ADs. The air carrier’s AD management process (see
Volume 3, Chapter 59, Section 1, Airworthiness Directive
Management Process and Alternative Method of Compliance) should contain the
following six elements: planning, support, provisioning, implementing, recording,
and auditing. The air carrier may not operate the aircraft that an AD applies
to except in strict compliance with the provisions of the AD. Therefore, it
is extremely important that the air carrier include in its AD process provisions to ensure that:
a) It reviews ADs for applicability to its aircraft;
b) If needed, it submits and receives FAA approval for an alternative method of compliance
c) It accomplishes the requirements of the AD within the time frame specified in the AD;
d) It keeps records of the accomplishment and current status of each AD that applies to its aircraft; and
e) Any subsequent maintenance or alteration to its aircraft does
not remove the maintenance or alteration that the AD mandated.
NOTE: If the air carrier does subsequently remove the AD-mandated maintenance
or alteration, it will be in violation of part
39 and may introduce an unsafe condition into its airplane. It would
also make the required records for that particular AD inaccurate.
3) Work Cards.
a) Work cards (task cards), while not a specific regulatory requirement,
have evolved as a best practice. The FAA considers work cards to be part of
the air carrier’s manual and the air carrier’s maintenance program. They are
the “what to do” and “how to do it” parts of the air carrier’s responsibility
to accomplish maintenance and alterations on its aircraft. An air carrier uses
work cards as a simple means of complying with regulations for performing maintenance
as well as maintenance recordkeeping. The air carrier’s work cards provide detailed,
concise procedural instructions that organize and control its maintenance activities
while providing a means to ensure that its maintenance activities comply with
its air carrier maintenance manual. It is an easy way for the air carrier to
make sure that its maintenance and other personnel are following its procedures.
The air carrier must document its process for developing and controlling work
cards in its manual. If the air carrier develops its own work cards based on
a manufacturer’s instructions, it must ensure that they have transcribed the
information completely and accurately.
b) The air carrier should give special attention to work cards involving
required inspections and flight control systems to ensure they are accurate,
and contain complete and relevant technical data and drawings. The air carrier
should include discrete (separate or distinct) tasks with individual inspection
sign-off requirements for post‑rigging verification. Another function of the
work card is to document the air carrier’s maintenance activities, providing
a means for the air carrier to comply with its air carrier maintenance recordkeeping
requirements. Work cards may also document the results of inspections, checks,
and tests for data collection and analysis. The air carrier conducts work‑in‑progress
audits of work card activities under its CASS to ensure that each individual
who accomplishes work on its aircraft is following its manual.
3-3871 AIR CARRIER MAINTENANCE ORGANIZATION.
A. General Organizational Requirements. The air carrier’s maintenance
organization must be able to perform, supervise, manage, and amend its program;
manage and guide its maintenance personnel; and provide the direction necessary
to achieve its maintenance program objectives. The regulations require the air
carrier to include a chart or a description of its maintenance organization in its manual. Part
121 subpart L, part
135 subpart J, and portions of part
119 subpart C discuss maintenance organization requirements. These
organizational regulations apply to the air carrier’s organization, as well as any other organization
that provides maintenance services for the air carrier. A chart is a good way
to show the air carrier’s assignment of overall and direct authorities and responsibilities.
B. Required Maintenance Organization Management Positions. Section
119.65 includes specific requirements for maintenance management positions for operations under part
121. A Director of Maintenance (DOM) and a chief inspector, or equivalent
positions, are required by the regulations; however, they are not all of the
management positions that the air carrier will need to administer and manage
its maintenance organization.
135 Required Positions. For operations conducted under part
119.65 requires the air carrier to have qualified individuals serving full-time
as the DOM and chief inspector, or in equivalent positions. If necessary for
the air carrier’s operation, the air carrier can ask the FAA for a deviation
from the types and numbers of required part
135 management positions.
2) Chief Inspector. For operations that the air carrier conducts under part
119.69 requires the air carrier to have a qualified individual serving in
the DOM management position, but there is no regulatory requirement for a part
135 chief inspector management position. However, in a practical sense,
the air carrier will have an individual in its part
135 maintenance organization that has direct responsibility for the RII
function, as well as those other duties, responsibilities, and functions normally associated with a part
121 chief inspector. Additionally, §
135.429(b) implies a supervisor for the air carrier’s inspection unit.
3) Management Personnel. The regulations require the air carrier
to state the duties, responsibilities, and authority of each of its management
personnel in its manual. The air carrier should state who has overall authority
and/or responsibility, and who has direct authority and/or responsibility for
a given process. In addition, the air carrier must notify the FAA when it makes
changes in its part
119 required management personnel or when it has a vacancy in one of
a) “Authority” means the power to design or change fundamental policy
or procedures without having to seek higher-level approval. Authority is permission;
it is a right coupled with an autonomous power to accomplish certain acts, or
to order others to act. Often one person grants another authority to act, such
as an employer to an employee, a corporation to its officers, or a governmental
empowerment to perform certain functions.
b) “Responsibility” means a person’s obligation to ensure the successful
completion of a task or function. Responsibility includes accountability for
the action to carry out a task or function.
C. Required Air Carrier Maintenance Organization Structure.
1) Structure. The regulations that define an air carrier maintenance
organization are broad given the different types and sizes of air carriers.
It is not possible for a single means of compliance or a single organizational
chart to apply to all the different types and sizes of air carrier organizations.
2) Accountable Person. The air carrier should designate a single
manager (person or position) to have authority, overall responsibility, and
accountability for managing and implementing the air carrier’s entire maintenance
program, including all inspection functions. The inspection functions and the
required inspection functions are part of the air carrier’s maintenance program.
3) Organizational Functions. The FAA recommends that the air
carrier’s maintenance organization have three general organizational functions
to ensure that the air carrier conducts all operations to the highest possible
degree of safety. If the air carrier is a larger organization, it may have different
departments for each level while in the smallest organizations, the air carrier
may carry out these functions through one or two individuals, possibly as a
collateral duty. Generally, these three organizational functional levels include:
a) Mechanics and/or inspectors performing the work at the first level (operations);
b) Middle managers and supervisors at the second level (tactics); and
c) The maintenance program accountable manager at the third level (strategy).
4) Authority and Responsibility. The FAA expects the air carrier to assign clear authority and responsibility in its maintenance organization,
including responsibility for the overall maintenance program and all of its
elements and functions. The air carrier’s manual should include a position description
with each position’s duties and responsibilities in order to prevent a fragmented
organizational system with a high risk for confusion over who is responsible
for a given element, process, or task. The inspector should watch out for hidden
duties and responsibilities where the air carrier shows a person’s duty and/or
responsibility in a process but not in the position description.
D. Maintenance and Inspection Organizations.
1) Regulatory Requirements. If the air carrier performs maintenance
and required inspections or if other persons perform these functions for the
air carrier, there is a clear regulatory requirement in §§
135.423 for a maintenance organization and a required inspection organization.
There is no regulatory requirement to separate these organizations. However,
there is a requirement to separate the functions that each organization performs.
NOTE: Do not confuse “inspection” with “required inspection” when evaluating
the air carrier’s organization. “Inspection” is normally associated with an
inspection department that performs scheduled type inspections on the aircraft
such as “C” and “D” checks. However, “required inspection,” when used within the context of part
121, has a very specific meaning. An air carrier is not required by
regulation to have an inspection department that performs scheduled inspections (although
this is desirable), but an air carrier is required by regulation to have a required
inspection organization that performs required inspections.
2) Organization. Sections
135.423(c) require the air carrier to organize the performance of all maintenance
functions (e.g., inspection, repair, overhaul, and the replacement of parts)
to separate the function of required inspections from the function of the other
maintenance, preventive maintenance, and alteration activities. This organizational
separation must be below the level of administrative control where the air carrier
exercises overall responsibility for the required inspection functions as well
as the other maintenance, preventive maintenance, and alteration functions.
See Figure 3-141 for a representative organizational chart.
Figure 3-141. Typical Part
121 Organizational Chart Showing the Organizational Separation of the
Required Inspection Items Function and the Other Maintenance, Preventive Maintenance,
and Alteration Functions
3-3872 ACCOMPLISHMENT AND APPROVAL OF MAINTENANCE AND ALTERATIONS.
A. Accomplishment of Maintenance.
1) Performing Maintenance. As a maintenance entity, the air carrier has authorization under 14 CFR part
43.7(e), and §§
135.437 to perform maintenance on its own air carrier aircraft and to approve
them for return to service without obtaining any other maintenance certification. In addition, §§
135.437 provide clear authority for the air carrier, under its air carrier
certificate, to perform maintenance on behalf of other air carriers that conduct operations under the same part as the air carrier.
2) Airman Certificate. Each individual who makes an airworthiness determination on the air carrier’s behalf must hold an appropriate airman certificate. Sections
135.435 require that any individual who the certificate holder puts directly
in charge of performing maintenance hold an airman certificate. Sections
135.435 require that any individual the air carrier authorizes to perform
its RII holds an appropriate airman certificate. Sections
135.443 require that anyone who the air carrier authorizes to issue an approval
for return to service holds an appropriate airman certificate. The air carrier’s
DOM and chief inspector must hold an airman certificate with Airframe and Powerplant
(A&P) ratings. All of these requirements for an airman certificate are imposed
on the air carrier, not the individual. The individual performing the function
is not exercising the privileges of his or her certificate because the privileges
of the airman certificate do not include the performance of part
121 requirements. Additionally, the authority to perform the required
121 function derives from the air carrier’s certificate, not the
individual’s airman certificate. The air carrier accomplishes all maintenance and approval
for return to service on its aircraft under its air carrier certificate by its
maintenance organization or persons authorized by it, not by any individual
or organization under their own individual certificate. There is, however, one
exception to the individual airman certificate requirement. It occurs if the
air carrier arranges for a certificated repair station (CRS) located outside
the United States to perform maintenance. At such repair stations, individuals
directly in charge of performing maintenance or required inspections are not
required to hold an FAA airman certificate.
B. Major Repairs and Alterations. Under §§
135.437(b), major repairs and alterations must be completed in accordance
with technical data approved by the FAA. Part
43 appendix A contains a list of repairs and alterations considered
major. However, the air carrier should not consider the list to be all-inclusive. Rather,
they should consider the list to be examples of major repairs and alterations.
The air carrier must also consider the definitions in 14 CFR part
1 for major
repairs and alteration when classifying repairs and alterations The air carrier
should have detailed major/minor classification procedures in its manual to
evaluate each repair or alteration on a case‑by‑case basis using such factors
as the certification basis of the aircraft; classification of the structure
as primary, secondary, or a primary structural element; or classification as
a fail-safe, safe-life, or damage-tolerant structure.
C. Airworthiness Release Form or Aircraft Log Entry and Approval
for Return to Service. After performing any maintenance on its aircraft,
the air carrier must approve it for return to service before the air carrier
may operate it. The air carrier must issue an approval for return to service under §
121.709 or §
135.443, as appropriate.
D. Scope of Maintenance. The air carrier must provide instructions
in its maintenance program and maintenance manual for maintenance and alterations
encompassing “what to do,” “when to do it,” how to do it,” and “was it completed
properly” in at least three major areas:
1) Scheduled Maintenance. Scheduled maintenance consists of all
the individual maintenance tasks performed according to the maintenance time
limitations (maintenance schedule). The air carrier’s scheduled maintenance
activities should include procedural instructions for the maintenance tasks
and requirements to record the results of the inspections, checks, tests, and
other maintenance. The air carrier’s procedures should also provide for time-related
activities such as recurring ADs, Certification Maintenance Requirements (CMR),
and life-limited parts retirement.
2) Unscheduled Maintenance. Unscheduled maintenance includes
procedures, instructions, and standards for maintenance that occurs on an unscheduled
or unforeseen basis. A need for unscheduled maintenance may result from scheduled
maintenance tasks, pilot reports, or unforeseen events, such as high-load events,
hard or overweight landings, tail strikes, ground damage, lightning strikes,
or an engine over-temperature. In the air carrier’s maintenance manual, the
air carrier should include instructions and standards for the accomplishment
and recording of unscheduled maintenance and detailed procedures for recording
all types of unscheduled maintenance.
3) Specific Maintenance Requirements for Major Aircraft Components.
a) Engine Maintenance Program. The air carrier’s engine maintenance
program should cover the maintenance of installed engines and off-wing engines
for each engine model it operates. If the air carrier’s aircraft have auxiliary
power units (APU), it may want to include APU maintenance as part of its engine
maintenance program. Usually, the installed engine or APU requirements will
be contained in the maintenance time limitations. In addition to procedural
information, the off-wing program described in the air carrier’s maintenance
manual should provide shop scheduling information or intervals for cleaning,
adjusting, inspecting, testing, and lubricating each part of the engine or APU
requiring that maintenance. The air carrier should include in its maintenance
manual the degree of inspection, the applicable wear tolerances, and the work
required when the engine or APU is in the shop.
b) Propeller Maintenance Program. If applicable, the air carrier’s
propeller maintenance program should cover the maintenance of installed propellers
and off-wing propellers for each model it operates. Usually, the installed propeller
system scheduled maintenance requirements will be contained in the maintenance
time limitations. In addition to procedural information, the off-wing program
described in the air carrier’s manual should provide shop scheduling information
or intervals for cleaning, inspecting, adjusting, testing, and lubricating each
part of the propeller system requiring that maintenance. The air carrier should
include in its maintenance manual the degree of inspection, the applicable wear
tolerances, and the work required at these periods. Some propeller manufacturers
make propellers of composite materials and, therefore, may require unique tools,
repair procedures, and specialized training for maintenance personnel.
E. Parts and Appliances Maintenance Program. For the most part,
this component of the air carrier’s maintenance program covers shop operations,
which may include both scheduled and unscheduled tasks. The air carrier may
conduct these shop operations at some location other than where it performs
maintenance on its aircraft. The air carrier’s parts and appliance maintenance
program should cover both installed parts and appliances and off-wing maintenance
for each part and appliance model that it operates. Usually, the installed part
and appliance scheduled maintenance requirements will be contained in the maintenance
time limitations. In addition to procedural information, the off-wing program
described in the air carrier’s maintenance manual should provide shop scheduling
information or intervals for cleaning, adjusting, inspecting, testing, and lubricating
each component of the part and appliance requiring that maintenance. The air
carrier’s maintenance manual should include the degree of inspection, the applicable
wear tolerances, and the work required when the part or appliance is in the shop.
F. Maintenance and Preventive Maintenance Personnel Duty Time Limitations. Within the United States, §
121.377 requires that the air carrier or the air carrier maintenance provider
relieve each person performing maintenance or preventive maintenance from duty
for a period of at least 24 consecutive hours during any 7 consecutive days,
or the equivalent thereof within any 1 calendar-month. There are no equivalent
duty time requirements in part
135. The general rule in §
121.377 is intended to reduce the likelihood of fatigue-related maintenance
errors in air carrier operations. The regulation also permits persons to work
continuously in any 1 calendar-month, provided they are given time off and away
from work equal to the actual hours they would have been relieved from duty
if had they worked 6 days with the 7th day off throughout the specific calendar-month
under consideration. The air carrier or maintenance provider must give relief
from duty in increments of no less than 24 consecutive hours. The air carrier
must document its control methods for duty time limits in its manual. It may
accept the air carrier maintenance provider’s methods of control; however, the
air carrier is primarily responsible and accountable for ensuring compliance.
The air carrier should document its process for verifying compliance with maintenance
duty time limits through its CASS audits.
3-3873 MAINTENANCE SCHEDULE.
A. Maintenance Schedule Overview. Sections
121.135(b) require the air carrier to have maintenance time limitations,
also called a maintenance schedule. These same rules permit the air carrier
to use standards for determining its maintenance time limitations. This language
is the regulatory basis of the FAA‑approved reliability programs developed in
the 1960s. The maintenance time limitations set out the what, how, and when
of the air carrier’s scheduled maintenance effort. Although in the past the
schedule included only basic overhaul limits and other general requirements,
today it includes a specific list of each individual maintenance task and its
associated time limit. The regulations are broad enough to permit the air carrier
to organize all of these individual tasks into a series of integrated scheduled
work packages of its own design that provide a continuous succession of necessary
or desirable scheduled maintenance tasks for the air carrier’s entire airplane.
Most aircraft manufacturers have a document, sometimes called a Maintenance
Planning Document (MPD) that incorporates Maintenance Review Board Report (MRBR)
items into scheduled checks for a particular model aircraft. The air carrier
can use this document as a basis for developing its own maintenance schedule.
B. FAA’s Role in Relation to the Maintenance Schedule. The FAA
authorizes the air carrier maintenance schedule through the air carrier’s OpSpecs,
and the air carrier’s CASS monitors that schedule to verify that it is effective
and producing the desired results. The air carrier’s CASS will be its principal
source of information that might indicate a needed change to its maintenance
schedule. The FAA expects the air carrier to correct any deficiencies in its
maintenance schedule. Under §§
135.431(b), if the air carrier does not make needed changes, the FAA can
require it to change its maintenance schedule or any other element of its maintenance
program found deficient.
C. Maintenance Schedule Contents—General. The maintenance schedule
should contain the following information:
1) What (Unique Identifier). This is the item that the air carrier
intends to maintain. In most cases, this is the item listed in the MRBR, which
was determined using Maintenance Steering Group—3rd Task Force (MSG-3) logic.
The air carrier’s identifier should be specific enough to allow the individual
that it assigns to do the scheduled maintenance task to identify the item easily
2) How (Task). The scheduled maintenance task to be completed
in order to maintain the item. A scheduled maintenance task is a maintenance
action that the air carrier performs at regular, scheduled intervals so that
it can ensure that the item can continue to perform its intended function within
its operating context; so that the air carrier can discover a hidden failure;
or to ensure that a hidden function is available. The air carrier should not
use terms such as hard-time (HT), On-Condition (OC), or Condition Monitoring
(CM) in its maintenance schedule. These terms represent obsolete 1960s methodology,
are vague, and do not describe the maintenance task the air carrier is performing.
If the air carrier’s maintenance schedule contains these terms, there is a risk
that the scheduled maintenance that it wants and needs may not be the maintenance
3) When (Frequency). Frequency is the time-in-service interval
between the times when the air carrier accomplishes a scheduled maintenance
task. The air carrier may measure time-in-service intervals in calendar-time,
operational hours, flight cycles, or any other appropriate parameter. In addition,
for task management, inventory, and audit purposes, the air carrier should identify,
on the maintenance schedule, the task or work card associated with each scheduled
maintenance task. This way, the air carrier can ensure that it accomplishes
all of its scheduled maintenance tasks according to its schedule.
4) Maintenance Schedule Objective. The air carrier’s overall
maintenance schedule objective is to do the correct tasks at the correct interval.
Keep in mind that more maintenance is not always a good idea, so if the air
carrier decides to decrease intervals or add tasks, it should go through the
same justification process as it would for any other change to the maintenance
D. Standards for Determining Maintenance Time Limitations. Sections
121.135 permit the air carrier to have standards for determining its maintenance
time limitations. In the past, we used this language as the regulatory basis
for FAA-approved reliability programs that evolved during the 1960s. These programs
were based on Airlines for America’s (A4A) (was Air Transport Association of
America, Inc. (ATA)) now obsolete process-based Maintenance Steering Group—2nd
Task Force (MSG-2) decision logic that focused on failure rates and maintaining
individual parts of the aircraft. Consistent with the continuous evolution of
aviation, MSG-2 became obsolete in 1980 with the advent of A4A’s task-based
MSG-3 decision logic. MSG-3 focused on aircraft systems and a loss of function
rather than on individual part failure. In any case, the management of these
MSG-2 process-based programs was actuarial analysis. Air carriers used the failure
rates of a part to determine, through a probability process, the likelihood
that the part would have a similar failure rate in the future. The standard
was the acceptable failure rate. Air carriers used a failure rate alert program
with upper control limits (UCL) and lower control limits (LCL) to track part
failure rates. The air carrier was obliged to take action only when the failure
rate deviated from the probability-based prediction (i.e., exceeded the UCL
or the LCL). If the part did not respond, the air carrier had authorization
to move the UCL or LCL to make the failure rate within the alert program limits.
1) Reliability Centered Maintenance (RCM). During the 1970s,
after collecting a large amount of operational data over time, the industry
came to the realization that using failure rates and alert programs was not
the most effective way of managing scheduled maintenance. Using the vast amount
of operational data that was available, United Airlines, Inc. (UAL) developed
and published a report in 1978 under a U.S. Department of Defense (DOD) contract
entitled “Reliability-Centered Maintenance (RCM).” This very significant document
was in stark contrast to the previous part failure rate focus. RCM focused on
the loss of function of an aircraft system. RCM determined that not everything
fails the same way; failures occur according to different failure patterns.
RCM also determined that not everything requires the same type of maintenance;
there are four different types of scheduled maintenance. RCM also took into
account the different consequences (safety, operational, and economic) of a
loss of function, as well as system functional redundancy and inherent design
safety when determining if scheduled maintenance was required. In some cases,
RCM determined that no scheduled maintenance was required. This resulted in
doing only required maintenance, and lowered the maintenance burden.
2) MSG-3 Decision Logic. The RCM document was the major basis
for the ATA’s development of the MSG-3 decision logic in 1980. Since then, most
aircraft manufacturers have used A4A’s MSG-3 decision logic to help them develop
scheduled maintenance requirements for their new products. Besides providing
organization and flow to the deliberative process, the primary attribute of
the MSG-3 process is that the user can develop initial scheduled maintenance
requirements without the operational data that are required to determine the
need for scheduled maintenance tasks. Using the techniques of the MSG-3 decision
logic, it is simple to decide what tasks are required to be included in an initial
scheduled maintenance program. However, the MSG-3 decision logic does not contain
task interval selection decision logic to help the user determine where to set
the task intervals, or how to adjust them after service is initiated. Using
the MSG-3 process, initial task intervals are set based on knowledge of the
design, and the best judgment of the working group members. As a result, validation
of initial interval selections must occur when the aircraft begins service and
starts generating the operational data that were not available when the initial
intervals were set.
3) Effective Scheduled Maintenance. An inherent function of the
air carrier’s CASS is to determine the effectiveness of its scheduled maintenance
effort through operational data collection and analysis activity. The air carrier
should use this important function to determine the level of scheduled maintenance
effectiveness and to make the changes necessary to achieve the standard of effectiveness
that the air carrier has set. Effective means that “it is producing the desired
results.” Thus, from an operational standpoint, an indicator of effectiveness
of the air carrier’s scheduled maintenance effort is the availability of its
aircraft for flight operations. If the air carrier’s aircraft are unavailable
for flight operations for maintenance reasons, then the air carrier’s scheduled
maintenance program may not be as effective as it should be. There are other
elements of the air carrier’s maintenance program besides the scheduled maintenance
element that may be deficient as well, but the air carrier’s CASS procedures
will identify the root cause and help it identify and make the adjustments/changes
necessary to achieve the level of flight operations availability (the result)
that it has set.
E. Maintenance Schedule Development. The aircraft’s MRBR is the baseline
document for the air carrier to use in developing its maintenance schedule.
Industry, manufacturers, and the FAA participate in the development of the MRBR
using the MSG-3 process. The aircraft manufacturer compiles, publishes, and
keeps current the MRBR for a specific aircraft model and series. The FAA approves
the MRBR for use by U.S. air carriers. The tasks and their frequencies are listed
in the report form part of the instructions for continued airworthiness (ICA)
required by 14 CFR part
25 appendix H. The FAA develops the MRBR to be compatible with
regulations and policies, and it will assist the air carrier and the inspector
in the development and evaluation process of the air carrier’s initial maintenance
program. The MRBR outlines the initial minimum scheduled maintenance/inspection
requirements for developing a maintenance schedule for the airframe, engines,
systems, and components of a particular aircraft model/series. It is important
to note that the FAA uses the MRBR as a baseline/starting point for a new entrant
air carrier in the development of its maintenance schedule. Therefore the latest
version of the MRBR or Maintenance Type Board Report (MTBR) must be used as
a basis for any application. Once the maintenance schedule is in place, the
air carrier’s experience and CASS will be the main determining factors for changes
to the schedule. It is also important to note that a revision to the MRBR alone
does not automatically constitute an approval basis for an air carrier to change
its existing maintenance schedule. See
Volume 8, Chapter 2, Section 7 for more information about the MRBR process.
F. Maintenance Schedule Acceptance or Approval.
1) Without an Approved Reliability Program. For the air carrier that does
not have or is not seeking FAA approval for a reliability program, the inspector
will verify that the air carrier has accounted for all of the applicable maintenance/inspection
requirements listed in the applicable MRBR. If differences exist, the inspector
will require the air carrier to properly substantiate and justify those differences.
The inspector may contact the airworthiness person assigned to the aircraft
at the appropriate Aircraft Evaluation Group (AEG) (https://avssp.faa.gov/avs/afsaeg/default.aspx)
for assistance. If the inspector finds the air carrier’s maintenance schedule
acceptable, the inspector will issue OpSpecs paragraph D089, Maintenance Time
Limitations Section in accordance with
Volume 3, Chapter 18, Section 6.
2) With an Approved Reliability Program. For the air carrier
that has or is seeking FAA approval for a reliability program, the inspector
will verify that the air carrier has accounted for all of the applicable maintenance/inspection
requirements listed in the applicable MRBR in its maintenance schedule. Since
the FAA considers the maintenance schedule to be part of the air carrier’s reliability
program, the inspector should review the schedule as part of the evaluation
of the air carrier’s reliability program in accordance with
Volume 3, Chapter 40, Section 1. The inspector should note that FAA policy
regarding the air carrier using the MRBR as a basis for determining its initial
time limitations also applies to the air carrier that has an approved reliability
program. However, once the FAA approves the air carrier’s reliability program,
the air carrier must make any changes to its maintenance schedule in accordance
with the policies and procedures (standards for determining time limitations)
contained in its approved program. If the inspector finds the air carrier’s
maintenance schedule acceptable, the inspector will issue OpSpecs paragraph
D074, Reliability Program Authorization—Entire Aircraft, or OpSpecs paragraph
D075, Reliability Program Authorization—Airframe, Powerplant, Systems or Selected
Items, as applicable in accordance with
Volume 3, Chapter 18, Section 6. The FAA does not issue D089 to air carriers
also issued OpSpecs D074 or D075.
1) Tasks as RIIs. Sections
135.427(b) require the air carrier to designate certain tasks as RIIs. The
air carrier must designate those items of maintenance and alteration that it
must inspect (required inspections), including at least those that could result
in a failure, malfunction, or defect that endangers the safe operation of the
aircraft if the person performing the maintenance or alteration does not do
it properly, or if they use improper parts or material. If the air carrier uses
a maintenance provider to perform maintenance and alterations for it, it may
authorize a provider’s employee to accomplish its RII requirement if the air
carrier’s manual satisfies the regulatory requirements as outlined in subparagraph
3-3874B. The air carrier must issue its authorization to an individual rather
than a group or company. Consistent with the regulations, the air carrier remains
primarily responsible for the performance of each RII accomplished by the other person.
2) Making RII Lists. The air carrier must identify specific items
of inspection for each aircraft type (it is inappropriate to designate entire
systems as RIIs). The FAA recommends that the air carrier adhere to a decision
process, similar to the recommended process shown in Figure 3-142, Required
Inspection Items (RII), when creating its list of RIIs.
NOTE: There is nothing preventing the air carrier from including additional
items in its RII list that are not required by regulation and do not result
from the recommended decision process in Figure 3-142. However, the air carrier
should consider and ensure that by doing so, it does not diminish the significance
of an RII (additional inspection given to maintenance performed on a safety
of flight item).
Figure 3-142. Required Inspection Items (RII)
3) RIIs and Safety. The RIIs relate directly to flight safety.
The air carrier should consider all of its RIIs with the same safety of flight
consideration and emphasis even if accomplishing an individual RII adversely
affects its flight schedule, relates to a scheduled or an unscheduled task,
or arises at an awkward time or at an inconvenient location.
B. RII Procedures, Standards, and Limits.
1) List of Other Persons. The air carrier’s manual must include
a list of persons with whom it has arranged for any required inspections (refer to §§
135.427(a)) both within its organization and within other organizations
that perform maintenance on the air carrier’s behalf. This listing must include
a designation by occupational title of the personnel authorized to perform each required inspection (refer to
§§ 121.369(b)(3) and
2) Certification. With consideration of the exceptions at §§
135.435(a), each individual that the air carrier grants an RII authorization
to must hold an appropriate airman’s certificate. This is an air carrier qualification
requirement; the individual does not exercise the authority and privileges of
that certificate when accomplishing the RIIs. The air carrier must formally
notify each of these individuals of their RII authorization as well as its scope
(refer to §§
3) RII Requirements. The air carrier should clearly identify
its RII requirements on work forms, job cards, and engineering orders or by
any other method consistent with its maintenance program. A primary concept
of the RII function is to prevent any person who performs any item of work from
performing any required inspection of that work (refer to §§
135.427(b)(7)). FAA policy includes any person who provides training to
another person on the work performed. Therefore, it is important that the air
carrier identify RIIs whenever possible so that everyone knows an RII is required.
The air carrier should also clearly state RII buy-back procedures (refer to §§
4) Standards and Limitations. The air carrier must set procedures,
standards, and limits necessary for required inspections and acceptance or rejection
of the RIIs (refer to §§
135.427(b)(5)). The air carrier should have those procedures, standards,
and limits necessary for the accomplishment of its required inspections. The
air carrier must also have those procedures, standards, and limits necessary
for the acceptance or rejection of each of its RIIs. As the air carrier will
not find RIIs or procedures, standards, and limits for RIIs in an OEM manual,
the air carrier will have to develop these and put them in its manual. The air
carrier’s manual must specify the method of performing required inspections (refer to §§
5) Procedures. The air carrier’s manual must include procedures to ensure that it performs and completes all required inspections (refer to §§
135.427(b)(6)) before it releases the aircraft to service (refer to §§
3-3875 MAINTENANCE RECORDKEEPING SYSTEM.
NOTE: Additional information and policy on the air carrier maintenance recordkeeping system is contained in
Volume 3, Chapter 31, Section 5 and
Volume 3, Chapter 32, Section 1.
A. Reasons for Making and Keeping Maintenance Records. The air
carrier’s primary reason to make and retain maintenance records is to show that
the U.S. Standard Airworthiness Certificate on its aircraft is effective and
that its aircraft is airworthy. The Airworthiness Certificate is effective on
the air carrier’s aircraft only as long as the air carrier performs the maintenance
and alterations according to the requirements of the FAA’s regulations. If the
air carrier’s required aircraft maintenance records are incomplete or inaccurate,
it can render its aircraft’s Airworthiness Certificate ineffective. Maintenance
actions, in almost all cases, become intangible or abstract after the fact.
Therefore, in order for the air carrier to make a maintenance action tangible,
it must make a record of that maintenance action. Additionally, making a record
of certain summary information supports identification of the current inspection
and airworthiness status of the air carrier’s aircraft.
43 Requirements. Section
43.9(a) contains the basic requirement to make a maintenance record; however, §
43.9(b) indicates that the governing requirements for an air carrier are found in part
121 or part
135. In other words, the recordkeeping requirements of part
43.9(a) do not apply to air carriers. However, the requirements of §
43.9(b) are consistent with the air carrier maintenance recordkeeping requirements of
§§ 121.369(c) and
121.380(a) and (c), or §§
C. Work Performed by a Part
145 Repair Station.
1) Retaining Records. Section
145.219 requires a CRS to retain certain records of maintenance that it
performs. It also requires the repair station to make those records available to the FAA. However, these §§
145.219 requirements do not apply when the repair station is accomplishing
any work on the air carrier’s aircraft.
2) Copies of Records. The wording of §
145.205 regulations as well as §§
135.1(a)(2) compel a part
145 CRS to follow the procedures and requirements of the air carrier’s
maintenance program and applicable sections of its maintenance manual when accomplishing any maintenance or alterations on the air carrier’s aircraft. Consequently, a CRS must use the performance standards of part
121 or part
135, including the recordkeeping requirements, instead of following the
provisions in part
145 and its repair station manual. This is consistent with the
requirements of The Paperwork Reduction Act, which does not permit the government to require
two separate but identical sets of records. The responsibility for retaining
records in accordance with the retention requirements of §§
135.439(b) rests with the air carrier, not the repair station. However, if a part
145 repair station wants to retain a copy of those records generated by
working on the air carrier’s aircraft, FAA regulations do not preclude them from doing so. Asking the part
145 repair station to keep the air carrier’s records for the air carrier
is consistent with regulations, although the air carrier is responsible for
retaining them and making them available to the FAA. This is consistent with
the requirements of §
D. Penalties for Improper Air Carrier Maintenance Recordkeeping.
1) Importance of Maintenance Records. Maintenance records are important for:
a) The air carrier to fulfill its responsibility to determine the
airworthiness status of its aircraft; and
b) The FAA to continue its review of aircraft maintenance records
as a direct means of determining the airworthiness and safety status of air
2) Reviewing Maintenance Records. Because reviewing maintenance
records is often the only direct means of determining the accomplishment of
required maintenance, federal law treats the act of intentionally failing to
make and keep, as well as the act of intentionally falsifying, mutilating, or
altering, air carrier aircraft records, as a criminal act subject to the imposition
of substantial fines and/or imprisonment.
E. Making and Keeping Required Records.
1) Recordkeeping System. FAA regulations (§
121.369(c) or §
135.427(c)) require the air carrier to have and use a recordkeeping system
for the preparation, storage, and retention of required aircraft maintenance
records. The air carrier must document its system in its maintenance manual.
The primary objectives of these systems are the generation, storage, retention,
and retrieval of accurate and complete air carrier aircraft maintenance records.
As stated earlier, the air carrier makes and retains these records to show the
FAA that its aircraft have an effective U.S. Standard Airworthiness Certificate
and are airworthy and capable of safe flight.
2) Record Locations. FAA regulations (i.e., §
119.59(b)(1)(ii)) also require the air carrier to make and keep a listing
that identifies the location of each record, document, and report that the air
carrier is required to make and keep, as well as a listing that identifies each
person who is responsible for each of those records, documents, and reports.
3) ADs. FAA regulations §§
135.439(a)(2)(v) also require the air carrier to keep a record of the current
status of applicable ADs, including the date and methods of compliance and,
if the AD involves recurring action, the time and date when the next action
is required. Sections
135.427(c) require the air carrier to have and use a recordkeeping system
for the preparation, storage, and retention of required aircraft maintenance records.
F. When to Make Records Available to the FAA. Section
119.59(c) mandates that the air carrier must make its required maintenance
records available to the FAA at any time when the FAA requires them.
G. Responsibility for Making Records Available to the FAA. Under §
119.59(b)(1)(ii), the air carrier must make a list of persons in its organization
that it has designated to be responsible for making each required maintenance
record, document, or report available to the FAA upon request. The air carrier
must make a list of the location of each record, document, or report. The air
carrier must keep this list current and make it available to the FAA at its
principal base of operations.
H. Required Records. The air carrier is required to make and
keep certain current status records. Sections
135.439 list current status recordkeeping requirements, which are explained as follows:
1) Total Time in Service. The total time in service of the airframe,
each installed engine, and each installed propeller is a record that contains
the time in service accrued since new or rebuilt, expressed in hours, landings,
or cycles. It is important for the inspector and the air carrier to know that
“rebuilt” does not have the same meaning as “overhauled” (see §
2) Current Status of Each Life-Limited Part. The current status
of each life-limited part of each airframe, engine, propeller, and appliance
means a record that contains at least the following information:
a) Time in service since new, expressed in the appropriate parameter
(e.g., hours, cycles, or calendar-time);
b) The time in service remaining to the specified life limit expressed
in the appropriate parameter (e.g., hours, cycles, or calendar-time);
c) The specified life limit expressed in the appropriate parameter
(e.g., hours, cycles, or calendar-time); and
d) A record of any action that alters the part’s life limit or changes
the parameter of the life limit.
NOTE: If the air carrier conducts operations under part
135, total time in service and the current status of life-limited parts
also includes rotors.
3) Time Since Last Overhaul. The listing of the time since last
overhaul means a record that contains at least the following information:
a) An identification of the item that requires overhaul and its associated
scheduled overhaul interval;
b) The time in service since the last overhaul was accomplished;
c) The time in service remaining until the next scheduled overhaul
is due; and
d) The time in service when the next scheduled overhaul is due.
NOTE: The listing of time since last overhaul refers to summary current
status information. The air carrier must not confuse it with an overhaul record,
which is a description of the work performed and the identification of the person
who performed and/or issued the approval for return to service.
4) Current Inspection Status of the Aircraft. The current inspection
status of the aircraft means a record that contains at least the following information:
a) A listing identifying each of the scheduled inspection packages,
each task, and their associated intervals required by the aircraft’s maintenance
b) The time in service accrued since the last accomplishment of each
of the scheduled inspection packages and tasks required by the aircraft’s maintenance
c) The time in service remaining until the next accomplishment of
each of the scheduled inspection packages and tasks required by the aircraft’s
maintenance program; and
d) The time in service when the next accomplishment of each of the
scheduled inspection packages and tasks required by the aircraft’s maintenance
program is due.
5) Current Status of Applicable AD. The current status of applicable
ADs means a record that contains at least the following information:
a) Identification of the particular airframe, engine, propeller,
appliance, or component to which the AD applies.
b) The AD number (and/or regulatory amendment number).
c) The date when a person accomplishes the required action and the
time in service expressed in the appropriate parameter (e.g., hours, cycles,
d) If the requirement is recurring, the date when the next action
is due, and the time in service expressed in the appropriate parameter (e.g.,
hours, cycles, and calendar-time).
e) With regard to an AD, the method of compliance means a concise
description of the action taken to comply with the requirements of the AD. If
the AD or its referenced manufacturer’s Service Bulletin (SB) permits the use
of more than one method of compliance, the record must include a reference to
the specific method of compliance used. If the air carrier uses an AMOC to comply
with an AD, the method of compliance means a description of the AMOC and a copy
of the FAA approval.
NOTE: The air carrier should not confuse the current status listing
of an AD or method of compliance with an AD record of accomplishment, which
is a description of the work and who performed it and/or issued the approval
for return to service. They are two separate and distinct records.
6) Current Major Alterations of Each Airframe, Engine, Propeller,
and Appliance. A “listing” means a record that contains at least the following
a) A listing identifying each major alteration, as well as the associated
item that has been altered; and
b) A description of, or reference to, the FAA-approved technical
data that the air carrier used to make the major alteration.
NOTE: If the air carrier conducts operations under part
135, this listing must include all current major repairs, as well as
major alterations, and it must include major repairs and major alterations to each rotor.
NOTE: The listing of the current major alterations in §
121.380(a)(2)(vii) refers to summary current status information record.
The air carrier must not confuse this with a major alteration report required by §
121.707, which should contain at least the identification of the altered
airframe, aircraft engine, propeller, or appliance. The report should provide
a means of positively identifying each altered item and its technical data approval
basis. The air carrier must not confuse this listing with the requirement to
submit a copy of each report of a major alteration to the FAA. There are two
different requirements: one for a major alteration current status listing, and
one for a report for each major alteration that the air carrier accomplishes.
7) Airworthiness Release Form. All the records necessary to show
that the air carrier has met all requirements for the issuance of an Airworthiness
Release Form support the use of an Airworthiness Release Form, which is not
part of the aircraft maintenance logbook. While the regulatory requirement for
these records does not provide a detailed list of these records, the FAA generally
accepts this requirement to mean:
a) Detailed records of all scheduled maintenance that has not been
superseded by work of equivalent scope and detail;
b) Detailed records of the last overhaul for items that required
c) Detailed records of all unscheduled maintenance that has not been
superseded by work of equivalent scope and detail; and
d) Copies of the Airworthiness Release Form covering the last 60
days of operation.
I. Other Required Records and Reports. The FAA regulations require
the air carrier to make other reports and records as discussed in this subparagraph.
The air carrier can use these records and reports to review its maintenance
operations to determine the adequacy of the maintenance portion of its air carrier
manual and the effectiveness of its maintenance program elements. These records
are one of the sources of information for the air carrier’s CASS. The FAA also
uses these reports in its continuous oversight of the air carrier’s maintenance
1) Maintenance Log. Sections
135.65 require any person who takes action in response to a reported or
observed failure or malfunction to make a record of that action in the maintenance
log of the aircraft. These air carrier maintenance log entries correspond to
the maintenance recording requirements of
§ 43.9(b). The air carrier also must ensure that each pilot in command (PIC)
ensures that all mechanical irregularities occurring during flight time are
entered in the maintenance log at the end of that particular flight time, consistent with §§
2) Airworthiness Release Form or Log Entry.
a) The air carrier’s Airworthiness Release Form or Log Entry required by §
§ 135.443 corresponds to the approval for return to service requirements of §§
135.437(b). Furthermore, parts
135 require the air carrier to prepare either an Airworthiness Release
Form or Log Entry before it can operate its aircraft after it performs any maintenance,
preventive maintenance, or alterations, whether it operates the aircraft in
air transportation or not.
b) The air carrier’s approval for return to service certification
and documentation required by
§ 121.709 or §
135.443 is a singular requirement, but the air carrier may execute it in
one of two ways:
1. The air carrier may complete an Airworthiness Release Form and give
it to the PIC. If the air carrier uses an Airworthiness Release Form, it must
keep it separate and distinct from the aircraft log. It is not included in the
maintenance recordkeeping requirements. The separate and distinct requirement
corresponds to the requirements in §§
121.709(d). In modern day environments, air carriers are most likely to
use the log entry method to comply with §
121.709 or §
135.443. Other than form or format, there is no legal or technical difference
between an Airworthiness Release Form and a Log Entry.
2. If the air carrier makes a Log Entry, it does not have to issue an
Airworthiness Release Form. To avoid confusion and to be consistent with the
regulations, the air carrier should not identify this entry in the aircraft
log as an airworthiness release. The FAA understands that few air carriers use
a separate Airworthiness Release Form.
c) Consistent with §§
135.443(d), the air carrier may include a statement in its manual that the
signature of an authorized, appropriately certificated individual in the aircraft
log constitutes an approval for return to service under the air carrier’s maintenance
program. The authorized signature constitutes the four certification statements in §§
135.443(b)(2) without restating each one of them. If the air carrier has
this provision stated in its manual, it is very important it maintains control
for its use. The air carrier must prepare its Airworthiness Release Form or
Log Entry in accordance with procedures in its manual and must include the following
four certifications consistent with statutory considerations for operations
with the highest degree of safety in the public interest.
1. The work was performed in accordance with the requirements of the
air carrier’s manual;
2. All items required to be inspected were inspected by an authorized
person who determined the work was satisfactorily completed;
3. No known condition exists that would make the aircraft non-airworthy;
4. So far as the work performed is concerned, the aircraft is in condition
for safe operation.
d) An appropriately certificated individual who the air carrier authorizes
to make the Airworthiness Release Form or Log Entry on its behalf must sign
the Airworthiness Release Form or Log Entry.
NOTE: An authorized mechanic or repairman on the air carrier’s behalf
under its part
part 135 certificate authorizations must sign the Airworthiness Release Form
or Log Entry. This is consistent with the requirements and authorizations of
121.379(b), or §§
121.709(b)(3), or §
NOTE: Consistent with regulations, no individual may issue an Airworthiness
Release Form or make a maintenance Log Entry unless the air carrier has authorized
NOTE: Because a part
145 repair station is not an individual, these same regulations preclude
accomplishment of the air carrier’s Airworthiness Release Form or Log Entry
by a part
145 CRS. With one exception, an authorized, certificated individual (as
described in §§
135.443) must execute the Airworthiness Release Form or Log Entry according
to the air carrier’s procedures. The repair station may employ the authorized
individual, but they are acting on the air carrier’s behalf, not on behalf of
the repair station. This is consistent with §§
121.1(b), or §
e) The air carrier’s maintenance manual should include detailed procedures
for accomplishing the Airworthiness Release Form or Log Entry after it accomplishes
any maintenance on its aircraft. The air carrier’s procedures should include
controls designed to ensure that it does not operate its aircraft after it accomplishes
any maintenance, preventive maintenance, or alteration unless it completes the
Airworthiness Release Form or maintenance Log Entry.
f) The air carrier’s maintenance manual should include detailed procedures
for qualifying and authorizing each individual that it uses to accomplish its §
121.709 or §
135.443 Airworthiness Release Form or Log Entry. These procedures should
include a positive, readily available means for the air carrier to document
and transmit the authorization to the individual, including the scope and limitations
of their authorization.
3) Service Difficulty Reports (SDR). (Also see
Volume 8, Chapter 5, Section 6.) The air carrier is required to make SDRs in accordance with §§
135.415. While analysis of these reports can help the air carrier to identify
deficiencies within its maintenance program, these reports are also the FAA’s
primary means of gathering information for their SDRs.
4) Mechanical Interruption Summary Reports (MISR). (Also see
Volume 3, Chapter 32, Section 14.) Sections
135.417 require air carriers to make MISRs. These reports document the inability
of the air carrier’s aircraft to arrive at its scheduled destination because
of mechanical difficulties. This is a prime indicator of deficiencies in the
effectiveness of the air carrier’s maintenance program. Moreover, root cause
analysis of these events is one of the air carrier’s most useful means of oversight
of the level of effectiveness of its maintenance program.
J. Requirements for Reports of Major Alterations and Major Repairs.
121 Major Repair and Major Alteration Reports. If the air carrier
operations under part
121.707 requires it to make a report of each major alteration and major
repair. The air carrier must submit the major alteration report and make the
major repair report available to the FAA for inspection. This falls under §
119.59 requirements. Air carriers do not have to use FAA Form
Repair and Alteration (Airframe, Powerplant, Propeller, or Appliance), to report
a major alteration or major repair that the air carrier or maintenance provider
135 Major Repair and Major Alteration Reports. If the air carrier
operations under part
135, there is no requirement that requires it to submit reports of major
alterations or major repairs. However, while a report is not required, the records
of aircraft maintenance or alteration are required and the air carrier must
make them available to the FAA when requested.
NOTE: The air carrier should not confuse these alteration and repair
reports with the current status listing of major alterations required under
121 or the current status listing of major repairs and alterations
K. Requirements for Historical or Source Records. The air carrier
does not have to keep historical or source records to prove that the required
records (e.g., current status records §§
135.439) that it must make, keep, and make available to the FAA are true
and accurate. Inherent with the requirements and objectives of an air carrier
maintenance program, the air carrier must have a system to prepare, store, and
retain its required maintenance records; it must monitor that system under its
CASS to ensure that it is following its procedures and that they are effective.
This ensures that the air carrier’s required records are true and accurate.
The air carrier does not need to indefinitely keep records such as the in-service
history of life-limited parts (traceability back to birth) or the accomplishment
of an AD. However, remember that there are severe criminal penalties for falsifying
or failing to make or keep air carrier records.
1) Acceptable Records. Consistent with the FAA regulations, unless
there is evidence to the contrary, an aircraft maintenance record produced by
the air carrier’s maintenance recordkeeping system should be acceptable by itself,
without other historical or source records. The important consideration here
is that the air carrier has a sound and properly working recordkeeping system.
The air carrier may wish to archive certain source documentation records that
it used to introduce parts or components into its maintenance system. These
records may include documents such as the manufacturer’s invoice for new parts,
export certificates of airworthiness, documentation of a major repair or alteration,
or other similar information that may be useful in the future. The air carrier
may also have business reasons to maintain historical records or may do so of
its own choice. The air carrier is only legally required to make, retain, and
produce for FAA review those records clearly outlined in 14 CFR.
A. Maintenance Providers. This section uses the following two
standardized terms to prevent confusion related to the meaning of various terms
such as contract maintenance, outsource maintenance, outsource contract maintenance,
outsource maintenance provider, and substantial maintenance.
· Contract maintenance. Contract maintenance means any maintenance,
preventive maintenance, or alterations accomplished by an air carrier maintenance
· Air carrier maintenance provider or maintenance provider. Air
carrier maintenance provider or maintenance provider means any person with whom
the air carrier has made arrangements for the accomplishment of any of its maintenance,
preventive maintenance, or alterations.
1) Essential Maintenance (Part
121 Only). Essential maintenance encompasses any on-wing RII
accomplished after any maintenance or alteration. This maintenance, if completed improperly
or if improper parts or materials were used, would result in a failure effect
that would endanger the continued safe flight and landing of the airplane. Essential
maintenance is the accomplishment of the air carrier’s designated on-wing inspection
item. Essential maintenance does not encompass any off-wing maintenance.
2) Maintenance Provider List. Maintenance manual regulations
require the air carrier to list in its manual each person it arranges for the
performance of maintenance, preventive maintenance, and alterations. This requirement
applies to all maintenance providers that the air carrier has (directly) arranged
for the performance of maintenance, preventive maintenance, and alterations
such as a repair station. It does not apply to persons who perform contract
maintenance for the repair station under §
145.217. This policy only applies to the list required by §§
135.427(a). It does not apply to any other regulation which contains any
form of the word “arrange.” The regulations also require the air carrier to
identify each of its maintenance providers by name, location, and a general
description of the work they perform.
3) Essential Maintenance Provider (EMP) List. The air carrier
should have a means to identify, within its maintenance provider list, those
maintenance providers who accomplish essential maintenance for it. The air carrier
should also identify the specific required inspection that it has authorized
each EMP to accomplish for it in its maintenance provider list.
B. Responsibility for Maintenance Performed by Others.
1) Air Carrier Maintenance. Consistent with §§
135.1(a)(2) and other sections, when the air carrier uses a maintenance
provider to accomplish all or part of the maintenance activities on its airplane
or its component parts, that maintenance provider becomes part of the air carrier’s
maintenance organization and under the air carrier’s control. However, §§
135.413 make it clear that the air carrier remains primarily responsible
for all of the maintenance performed by that maintenance provider on its aircraft.
The air carrier must determine that the maintenance provider has the capability
to do the air carrier’s work on its behalf, manage its work, and determine that
it does the work satisfactorily according to the air carrier’s manual and standards.
Because the maintenance provider must perform all work on the air carrier’s
aircraft in accordance with the air carrier’s maintenance manual and its maintenance
program, the air carrier must also provide the maintenance provider with appropriate
material from its maintenance manual for that work.
2) Air Carrier Policy and Procedures. The air carrier must ensure
that the maintenance provider follows the procedures in the air carrier’s manual
that it has provided. The air carrier should accomplish this through work-in-progress
audits while the maintenance provider is actually accomplishing the work. The
air carrier’s manual system should accommodate work performed for it by each
maintenance provider. The policy and procedures portion of the air carrier’s
maintenance manual should assign clear authority and responsibilities and outline
procedures for its personnel to administer, control, and direct all contract
maintenance. The air carrier should arrange the technical material that it provides
for the use and guidance of the maintenance provider.
3) Contract Maintenance. When possible, the air carrier should
have a written contract with anyone performing contract maintenance for it on
a continuing basis. This will help ensure that the maintenance provider addresses
the air carrier’s responsibilities. In the case of major operations, such as
engine, propeller, or airframe overhaul, the contract should include a specification
for the work. The air carrier should include or reference that specification
in its manual system.
C. Unscheduled Maintenance Performed Away from Regular Facilities.
Sometimes, the air carrier will need maintenance performed on its aircraft while
it is away from its regular maintenance facilities. The air carrier also may
need maintenance services on short notice. The air carrier’s maintenance manual
should include procedures for obtaining these services under these unanticipated
conditions. The air carrier should never use the term “emergency maintenance”
to describe short notice unscheduled maintenance, as such terms imply to the
air carrier’s employees and its maintenance providers that FAA regulations and
the air carrier’s procedures do not have to be followed. “Emergency” means that
a serious situation has occurred unexpectedly, involves a peril to life or property,
and demands immediate action (e.g., an out-of-commission aircraft parked on
an airport ramp could hardly constitute a peril to life or property). The air
carrier should outline the procedural steps that it will take to control and
direct the unscheduled maintenance accomplished by its maintenance provider.
Unscheduled, short-notice requirements for maintenance do not void the air carrier’s
responsibility to determine that its maintenance provider has the organization,
adequate facilities and equipment, competent personnel, and appropriate portions
of the air carrier’s manual for the work the maintenance provider needs to complete.
The air carrier must make these determinations before any maintenance provider
starts to work on its aircraft. These procedures and method of determination
should be in the air carrier’s manual.
D. Airworthiness Release Form or Aircraft Log Entry. Sections
135.437(b) authorize the air carrier to approve its aircraft, airframes,
aircraft engines, propellers, or appliances for return to service after it accomplishes
any maintenance, preventive maintenance, and alterations. These sections do
not authorize any person other than the air carrier to approve its aircraft
for return to service. Sections
135.443(b) outline requirements for those personnel making a Log Entry or
issuing an air carrier Airworthiness Release Form under part
121 or part
135 on the air carrier’s behalf. These regulations require a certificated
repairman, or certificated A&P mechanic that the air carrier authorizes,
to make the Log Entry or issue the Airworthiness Release Form for the air carrier.
These regulations clearly do not authorize a repair station certificated under part
145 or any other entity to make an Airworthiness Release Form or Log
Entry on the air carrier’s behalf. The regulations set forth clear personnel qualification
requirements for each individual the air carrier so authorizes. The approval
for return to service authority remains solely with the air carrier. An individual
may not issue an approval for return to service for the air carrier’s aircraft
unless the air carrier authorizes them to do so.
1) Log Entry or Airworthiness Release Form. The air carrier must
designate each individual authorized to execute the Log Entry or Airworthiness
Release Form for it by name and occupational title. The individual making the
Log Entry or Airworthiness Release Form acts as the air carrier’s authorized
agent. He or she certifies that they accomplished the maintenance according
to the air carrier’s maintenance manual and maintenance program procedures and
that no known condition exists that would make the aircraft non-airworthy. This
arrangement does not reduce the responsibility of maintenance personnel to accomplish
maintenance functions or tasks in accordance with the air carrier’s manual.
2) Procedures for Log Entry or Airworthiness Release Form. Consistent with §§
135.443(b)(1), the air carrier’s maintenance manual must include the procedures
for making an aircraft Airworthiness Release Form or Log Entry. Our regulations
require the air carrier to make a Log Entry or complete an Airworthiness Release
Form before it can operate its aircraft for any reason after the air carrier
has accomplished any maintenance. The air carrier is required to make a Log
Entry or an Airworthiness Release. Other than form or format, there is no legal
or technical difference between an Airworthiness Release Form and a Log Entry.
E. Evaluating New Contract Maintenance Providers. Before the
air carrier can use a maintenance provider for the first time, it must determine
that the maintenance provider candidate complies with pertinent requirements of part
121 subpart L or part
135 subpart J. In most cases, the air carrier would conduct an onsite
audit. The air carrier must demonstrate, through this audit or by some other means,
that the maintenance provider has an adequate organization, adequate facilities
and equipment, and competent personnel, and is capable of performing the work
consistent with the requirements of the air carrier’s program. The air carrier
should use a risk assessment process to determine whether or not to accomplish
an onsite audit. The air carrier’s risk assessment should take into account
what happens (the failure effect) when the aircraft part or aircraft system
that the maintenance provider works on fails. If the failure effect is safety,
the air carrier procedures should mandate an initial onsite audit along with
recurrent onsite audits, as well as the posting of an employee who is assigned
audit and oversight duties as resident at the maintenance provider’s facility.
NOTE: Since the failure effect of parts and systems that come under
essential maintenance relates to safety, the FAA expects the air carrier to
have policies and procedures to qualify, supervise, and control these maintenance
providers, which should include onsite audits.
F. Continuing Maintenance Provider Oversight. Ensuring that each
one of the air carrier’s maintenance providers is in continuous compliance is
a major function of the certificate holder’s CASS. The air carrier should use
its risk-based process for establishing a schedule for auditing and inspecting
each of its maintenance providers. Inherent with a risk-based process, the air
carrier may determine that some of its maintenance providers do not require
an onsite audit. Consistent with the “performance” wording of §
121.373 or §
135.431, the audits that the air carrier accomplishes should be primarily
work-in-progress audits that serve to determine that the air carrier’s maintenance
providers are following the air carrier’s manual. The audits should be accomplished
by trained auditors, and the results analyzed by trained analysts. The results
of the analysis should permit the air carrier to determine each maintenance
provider’s continuing compliance with part
121 subpart L or part
135 subpart J, as appropriate, and the air carrier’s maintenance
G. Using a CRS as One of the Air Carrier’s Maintenance Providers.
1) Repair Stations. If the air carrier decides to exercise its authority under §
121.379 or §
135.437 to make arrangements with other persons to accomplish contract maintenance
for it as provided in its manual, the air carrier may choose to make these arrangements
with an FAA-CRS, but these rules do not require the air carrier to do so. The
scope of the air carrier’s authorization to make arrangements for maintenance
is very broad; it can make arrangements for maintenance with any “person” as
that term is defined in part
1.1, as long as that maintenance provider
accomplishes the air carrier’s maintenance in accordance with its manual and
maintenance program. Although the §
1.1 term “person” includes a CRS, it also
includes anyone who does not hold an FAA certification.
2) Regulatory Requirements. The requirements that the air carrier
uses to qualify a maintenance provider that holds a current part
145 repair station certificate and a maintenance provider who does not
hold a current part
145 repair station certificate should be exactly the same. Consistent
§ 135.1(a)(2), each person, whether certificated or not, that is employed
or used by the air carrier for any maintenance, preventative maintenance, or
alteration of the air carrier’s aircraft is required to comply with the part
121 requirements and the air carrier’s maintenance program requirements,
3) Approval for Return to Service. The air carrier’s §
121.379(b) or §
135.437(b) authorization to approve its aircraft for return to service after
maintenance extends to the work accomplished under its §
121.379(a) or §
135.437(a) authorization to make arrangements with other persons for maintenance.
A. Maintenance Program Training Requirements. Certain sections of part
121 subpart L and
part 135 subpart J contain specific air carrier maintenance training
135.433 require the air carrier to have a training program that ensures
it informs each person (including inspection personnel) who determines the adequacy
of work completed for the air carrier about procedures, techniques, and new
equipment in use, and that each person is competent to perform his or her duties.
There is an additional implied training requirement in part
121 subpart L and part
135 subpart J based on the air carrier’s responsibility to provide
competent personnel for the proper performance of its maintenance program. A training
program is the logical means for ensuring maintenance personnel are competent.
FAA regulations allow the air carrier to develop a training program that fits
its particular needs.
B. Types of Training. Some of the possible types of training
in the air carrier’s training program are initial training, recurrent training,
specialized training, competency-based training, and maintenance provider training.
The air carrier should select the appropriate training for its personnel, including
its maintenance provider personnel, which the air carrier should base on an
assessment of training needs. This assessment is a reflection of the required
knowledge, skills, and ability to accomplish a given task or function properly
and the current capability of those whom the air carrier would assign a particular task or function.
C. Initial Training. The air carrier should provide initial training
right after it hires an employee, when its existing employees begin to work
on new equipment, or when the air carrier gives the employee a new assignment.
The air carrier’s initial training program may include subjects such as:
· Employee indoctrination or orientation,
· Maintenance department policies and procedures,
· Maintenance recordkeeping and documentation,
· Aircraft systems or ground equipment,
· Specific skills (e.g., avionics, composite repair, aircraft run-up and taxi),
· Skills upgrade,
· Human factors,
· Task-specific training,
· Hazardous materials (hazmats) or Environmental Protection Agency (EPA) regulations, and
· Occupational Safety and Health Administration (OSHA) regulations familiarization.
NOTE: The air carrier’s initial training should also include a competence-based
assessment of employees. This evaluates an employee’s previous training and
experience and helps identify his or her specific individual training needs.
The objective is to provide training that addresses the gap between required
competence and the competence an individual already has.
D. Recurrent Training. Recurrent training is education occurring
on a repetitive basis. The air carrier must provide maintenance personnel with
the information and skills necessary to maintain its standard of competence.
This training also accommodates the introduction of new aircraft; aircraft modifications;
new or different ground equipment; new procedures, techniques, and methods;
or other new information. The air carrier’s recurrent training, although occurring
on a repetitive basis, may not adhere to a defined schedule. The air carrier
should not provide repetitive information in recurrent training unless it is
required to maintain personnel at a desired degree of competence. The air carrier’s
recurrent training may include:
· Continuing competency training designed to maintain regulatory
and certificate currency requirements.
· Refresher training on a seldom-accomplished task or seldom-used
· Update training for particular tasks or skills. Update training
can include training bulletins, bulletin-board items, self-study tasks, and
computer-based instruction (CBI).
· Any other continuing education or training that it may not provide on a defined schedule.
E. Specialized Training. The air carrier’s specialized training
should focus on competence in specific tasks or areas of responsibility, such
as RII, borescope, nondestructive testing, or flight control rigging. The air
carrier might provide this training with initial or recurrent training. The
air carrier does not need to limit it to maintenance subjects, but instead may
include management skills training for new supervisors, computer skills, or
other training necessary because of a change in an individual’s duties and responsibilities.
F. Maintenance Provider Training. The air carrier’s training
program must provide appropriate information to each employee of a maintenance
provider about its specific program. The training should include function-specific
training appropriate to each person’s job assignment or area of responsibility.
The air carrier does not need to provide training to maintenance provider personnel
in areas that do not concern them. For example, training on aircraft log procedures
and minimum equipment list (MEL) procedures would not be required for aircraft
interior cleaners, but would be required for maintenance personnel assigned
to on call maintenance for the air carrier.
NOTE: If the air carrier’s maintenance provider has specific types of
training for its personnel, the air carrier does not need to duplicate that
training for those individuals. However, the air carrier must ensure that its
maintenance provider has actually provided the training and that the training
meets the air carrier’s own needs and training standards. This could be a CASS
G. Competency-Based Training. Although air carriers historically
have provided a specified number of maintenance training hours to ensure that
employees have the competencies needed for their jobs, studies have shown that
it may be better for the air carrier to train to a competency-based standard.
The air carrier does not have to perform this type of training on a defined
schedule or for a specific number of hours. Rather, the air carrier should test
each individual to evaluate what training he or she needs, and then use these
evaluations to identify those personnel who retain a high level of subject competence
and who may not require a particular block of instruction. Conversely, the air
carrier should also identify those individuals who require more training. Training
to a competence level permits the air carrier to tailor training programs to
the specific requirements of the air carrier’s individual maintenance personnel
and maintenance providers.
1) When to Require Competency-Based Training. The air carrier
could use competency-based training to raise an employee’s level of competence
to that level required by the individual’s duties and responsibilities. The
air carrier should have procedures to determine when an individual requires
competency-based training. The air carrier may determine the need for this type
of training through pre- or post-employment testing, or through the analysis
and corrective action functions of its CASS. If the air carrier uses competency-based
training, it should specifically address the lack of competence. In some instances,
competency-based training may consist of an appropriately knowledgeable person
simply reviewing procedures with an employee through on-the-job training (OJT).
The air carrier should design competency-based training to fix an immediate
knowledge or skill deficiency and the training may focus on one individual or
a small group. The air carrier may include competency-based training in its
initial or recurrent training requirements.
2) Competency Deficiencies. For those circumstances where the
air carrier identifies a competency deficiency through investigation of an event,
the air carrier’s competency-based training should show an individual what happened,
why it happened, and demonstrate, in a positive manner, how to prevent it from happening again.
3) Competency Improvement Training. The air carrier should orient
its competency improvement training toward correcting personnel competence deficiencies
that the air carrier has identified through its CASS.
A. Background of the CASS. Introduction of the CASS requirement
resulted from an FAA industry study of a series of maintenance-related air carrier
accidents occurring during the 1950s. The study found that, in many cases, the
primary causal factor of an accident was a fundamental weakness or weaknesses
in the air carrier maintenance program. The study found that, in some cases,
maintenance personnel did not follow the manual and failed to accomplish required
maintenance tasks or failed to accomplish the tasks correctly. In other cases,
the study found that the maintenance program, even when followed as planned
and documented, was not effective in preventing the situation that led to the
accident. It did not produce the desired results.
1) Regulations. Responding to this finding, the FAA introduced regulations (§§
135.431) that require the air carrier to establish and maintain a system
for the continuing analysis and surveillance of the performance and effectiveness of its maintenance program.
2) Correcting Deficiencies. These regulations further require
that the air carrier include a process in its CASS to correct any deficiency
identified in its maintenance program, regardless of whether the air carrier
did the work or had a maintenance provider do the work.
B. CASS is a Safety Management Tool. A CASS is the air carrier’s
system for managing safety as it relates to maintenance functions. As a tool
to manage safety, it is part of the overall structure of policies and procedures
that the air carrier uses to ensure its operations are to the highest possible
degree of safety. It is a structured, methodical process that helps the air
carrier reach its maintenance program objectives. CASS is the only management
system mandated by regulation. If the air carrier uses it properly, its CASS
becomes an inherent way of doing business for it and helps the air carrier to
promote a culture of safety in its company by providing a formal process for
its employees to identify and correct safety deficiencies. The objectives of
measuring and continuously improving the performance (program execution) and
effectiveness (program results) of a major function (maintenance) apply equally
to all safety-related maintenance program functions that the air carrier must manage.
C. Basic CASS Processes.
1) CASS Processes. The air carrier’s CASS is a risk-based, closed-loop
system that has four basic processes:
a) Surveillance. An information gathering/audit process the air carrier
uses to collect data to measure the air carrier’s program execution and results.
b) Analysis. An analysis process the air carrier uses to identify
any maintenance program deficiencies and any necessary corrective actions.
c) Corrective Action. A planning process the air carrier uses to
ensure that it implements its corrective actions.
d) Follow-up. A performance measurement process that the air carrier
uses to verify that its corrective actions are effective. This is also an information-gathering
and analysis process, thereby closing the loop.
2) Using an Audit Program. During the first step (surveillance)
the air carrier will gather and obtain data using an audit program to support
measurement of performance (program execution). The air carrier should have
a well-structured audit program based on risk assessment and accomplished by
individuals trained and skilled specifically at auditing. Consistent with the
wording of the regulation, the air carrier’s primary type of audit should be
work-in-progress audits that evaluate if the worker is following the manual.
The air carrier’s auditors would also look at areas such as manuals and other
maintenance technical data, aircraft condition, actual in-process maintenance
practices, training, publications, and ground operations. In addition, information‑gathering
to obtain data that will support the measurement of effectiveness (program results)
is generally a collection of flight operational data such as accidents/incidents,
mechanical delays and cancellations, in-flight engine shutdowns, unscheduled
landings, engine performance, pilot logbook write-ups, and unconfirmed components
or parts removals.
3) Data Analysis. In the second step, the air carrier will analyze
the data to identify indications of maintenance program weaknesses. Individuals
experienced and/or trained as analysts should accomplish the air carrier’s data
analysis. One of the air carrier’s key objectives here is not only to identify
a weakness, but also to determine its root cause. This is where the air carrier’s
knowledge of human factors becomes critical.
4) Developing Corrective Action. Based on the results of the
air carrier’s analysis, the third step is for the air carrier to develop a corrective
action, if necessary, taking human factors into account so that its corrective
action is likely to be successful. Once the air carrier determines what the
corrective action is, it will develop and implement a corrective action plan.
5) Conduct a Follow-up Measurement Process. To close the loop,
the fourth step of the air carrier’s CASS will have the air carrier conduct
a follow-up measurement process using surveillance and analysis to verify that
its corrective action has effectively corrected the deficiency that it identified.
The air carrier can design this follow-up data-gathering process specifically
for the issue of interest, or it can make it a part of its continuing surveillance
that is the first step of its CASS. Determining if the air carrier needs a special
information-gathering procedure is part of its analysis that it accomplished
in step three.
6) Aspects of Surveillance. Both the initial and follow-up surveillance
can and should have proactive and reactive aspects to them. In the case of audits
by auditing systems and procedures, as well as specific transactions, the analysis
of audit results can identify weaknesses in a process. Correcting these weaknesses
before a problem results is a proactive approach. An audit also may uncover
a missed or improper maintenance action. Investigating this finding and correcting
the immediate problem is a reactive process. Developing and implementing a corrective
action to prevent a similar future event is equally important for improving
the maintenance program, and the regulations require it. Similarly, the air
carrier’s analysis of operational performance data from a systems point of view
can result in identification of a system’s weakness before a specific unwanted
event (such as a cancellation) occurs, which is a proactive process. Investigating
and correcting an undesirable operational event related to the maintenance program
after it has occurred, though reactive, also is a necessary and desirable procedure.
D. Risk-Based Decisions. All effective CASSs take into account
the need to manage risk to an acceptable level, as well as the practical limitations
that the air carrier must face when addressing deficiencies. Consequently, the
air carrier must set priorities and make choices for planning audits and other
information‑gathering activities, analyzing data, and selecting and implementing
corrective actions. The air carrier should tie setting such priorities directly
to a risk assessment process, so that the resulting maintenance program achieves its objectives.
E. Scope of CASS. CASS monitors all 10 elements of the air carrier’s maintenance program:
· Airworthiness responsibility,
· Air carrier maintenance manual,
· Air carrier maintenance organization,
· Accomplishment and approval of maintenance and alterations,
· Maintenance schedule,
· Maintenance recordkeeping system,
· Contract maintenance,
· Personnel training, and
F. CASS Design Principles.
1) Attributes of System Safety.
· Clear authority,
· Clear responsibility,
· Specific written procedures,
· Effective controls,
· Performance measures, and
· Well-defined interfaces.
2) CASS Design. These six system safety attributes should be
the starting point for the design of the air carrier’s CASS. It should be clear
who in the air carrier’s organization is responsible for and has authority over
the CASS. The air carrier should not divide responsibility/authority into two
or more parts due to the likely possibility that activity such as auditing and
operations data analysis are poorly coordinated. Typically, in addition to an
individual with overall CASS responsibility, the air carrier should have a management
board or committee to ensure good communications and coordination of all CASS
functions and to maintain regular senior level management involvement. This
oversight group also can provide a form of control over critical aspects of
the air carrier’s CASS operation and measure the performance and effectiveness of the CASS itself.
3) CASS Interfaces. In addition to the many elements within the
air carrier’s maintenance organization, there are many interfaces between the
CASS and functions or organizational elements of a typical air carrier that
are outside maintenance. Some of the more obvious examples are engineering,
flight operations, purchasing, safety, and the FAA. It is also important that
the air carrier defines and coordinates its CASS relationships to its other
programs (if they exist) well, such as internal evaluation programs, flight
operations quality assurance (FOQA) programs, voluntary disclosures, and Aviation
Safety Action Programs (ASAP).
G. CASS Personnel Requirements.
1) Effective CASS Skills. An effective CASS requires certain
skills that the air carrier may not have readily available within its maintenance
organization. For example, auditing skills are not automatically inherent in
those skilled in accomplishing maintenance. Analysis skills, particularly those
related to root cause determination, risk analysis, and human factors, are specialized
skills and generally require specific training and experience.
2) Sharing Personnel. All operators, but particularly smaller
ones, can share required CASS personnel. The air carrier may choose to have
its personnel perform CASS functions as a collateral duty, and it may choose
to hire someone outside its organization to accomplish some or all of its CASS
functions. However, it is essential that the air carrier recognize the need
for knowledge and skills in its CASS that do not necessarily coincide with those
knowledge and skills resulting from many years of maintenance experience repairing airplanes.
H. Regulatory References. The regulations that underlie this
section are found in 14 CFR. A summary of specific regulatory sections follows.
1) Scope of Regulatory Applicability.
2) Air Carriers’ Responsibility for Airworthiness and for Performing Maintenance.
3) Air Carrier Maintenance Programs.
4) Maintenance Program Manual.
5) Maintenance Organization.
6) Maintenance Time Limitations.
7) Performance and Approval of Maintenance and Alterations.
8) Performance and Approval of Maintenance and Alterations Performed by Other Persons.
10) Personnel Training.
11) Maintenance Recordkeeping and Reports.
121 subpart V,
12) Maintenance Log.
16) Alteration and Repair Reports.
I. Other Related Legal and Guidance Material. For more information,
consult current editions:
· Title 14 CFR Parts
· Title 49 U.S.C. § 46310, Reporting and Recordkeeping Violations;
AC 120-79, Developing and Implementing a Continuing Analysis and Surveillance System;
AC 120-16, Air Carrier Maintenance Programs;
· FAA Order
8900.1, Flight Standards Information Management System (FSIMS);
· A4A MSG-3, Operator/Manufacturer Scheduled Maintenance Development; and
· DOD Automatic Distribution (AD)-A066-579, Reliability-Centered Maintenance.
RESERVED. Paragraph 3-3879 through 3-3881.