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8900.1 CHG 537

VOLUME 3  GENERAL TECHNICAL ADMINISTRATION

CHAPTER 43  EVALUATE A CONTINUOUS AIRWORTHINESS MAINTENANCE PROGRAM

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Section 2  Safety Assurance System: Evaluating the Required Inspection Program

3-3882    REPORTING SYSTEM(S).

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A.    Safety Assurance System (SAS). Use SAS automation and the associated Data Collection Tools (DCT) for Title 14 of the Code of Federal Regulations (14 CFR) parts 121 and 135. This section is related to SAS Element 4.3.2 (AW) Required Inspection Items (RII).

B.    Program Tracking and Reporting Subsystem (PTRS). For 14 CFR parts 91 subpart K (part 91K) and 125, use PTRS activity codes 3330, 3341, 5330, and 5341.

3-3883    PURPOSE. This section provides information and policy for evaluating the required inspection element of a certificate holder’s or program manager’s Continuous Airworthiness Maintenance Program (CAMP).

3-3884    GENERAL INFORMATION.

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A.    Required Inspection Programs.

1)    Certificate holders that elect to maintain their aircraft under a CAMP must have a required inspection program and a program covering other maintenance, preventive maintenance, and alterations (refer to part 121,  121.367 and part 135, 135.425). RIIs are part of a required inspection program, and involve the designation of certain items, maintenance, preventive maintenance, and alterations as “RII.” The certificate holder or program manager uses the required inspection to verify the proper performance of certain items of maintenance, preventive maintenance, and alteration that if performed improperly, or improper parts or materials are used, could result in a failure, malfunction, or defect that would endanger the safe operation of the aircraft. For the purposes of this section, proper maintenance means maintenance and alterations performed in accordance with the certificate holder’s or program manager’s manual.
2)    With few exceptions, parts 121 and 135 (10 or more) contain the same basic required inspection provisions and requirements. The differences pertain to their overall applicability and the regulatory language used. For example, under parts 121 and 135 (10 or more), required inspections apply to all certificate holders. However, under part 91K, required inspections only apply to certain program managers who maintain their aircraft under a CAMP as provided for in part 91, 91.1109 and 91.1411. Part 125 certificate holders elect which type of inspection program they intend to use per part 125, 125.247(e). The selected program, which is approved by the Administrator, becomes the certificate holder’s Approved Inspection Program (AIP), which includes the RII. Additionally, parts 121, 125, and 135 refer to a certificate holder, whereas part 91K refers to a program manager.

B.    Required Inspection Program Requirements. Unlike typical inspections that are subjective examinations or observations, the required inspection is a defined inspection that entails an objective “documented” instruction on how each specific inspection is to be performed, and what the inspector is focused on when performing that inspection. This description, which must be included in the certificate holder’s or program manager’s manual, depicts the specific procedure (including the method), standard, and limit for performing the RII inspection. Every RII established by the certificate holder or program manager requires this same level of detail. As such, each item designated as an RII by the certificate holder or program manager must have specific procedures for performing an inspection. Generalized instructions, including references to the aircraft manufacturer’s maintenance manual, or procedures intended to cover all RIIs do not meet the intent of the regulatory requirement.

3-3885    REQUIRED INSPECTION ORGANIZATION.

A.   Organization and Separation of Maintenance and Inspection Functions.

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1)    Sections 91.1423, 121.365, 125.245, and 135.423 contain the organizational requirements for the certificate holder or program manager, as applicable, that performs any of its maintenance (other than required inspections), preventive maintenance, or alterations; each person with whom it arranges for the performance of that work must have an organization adequate to perform that work.
2)    Paragraph (b) of the regulations cited above (excluding 125.245) requires the applicable certificate holder, program manager, and/or person with whom it arranges to perform inspections required by its manual, to have an organization adequate to perform that work. The inspection organization is responsible for determining that both the workmanship and materials used conform to the regulations and the certificate holder’s or program manager’s manual.
3)    Section 125.245 requires that each person with whom a certificate holder arranges to perform maintenance, preventive maintenance, alterations, and required inspections is to have an organization adequate to perform the work.
4)    Paragraph (c) of the regulations cited above (excluding  125.245) adds an additional organizational requirement for organizing the performance of the maintenance function and the required inspection function, so as to separate the inspection functions from the other maintenance, preventive maintenance, and alteration functions. The separation must be below the level of administrative control at which persons exercise overall responsibility for the required inspection function and other maintenance, preventive maintenance, and alteration functions. (See Volume 3, Chapter 43, Section 1.)
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5)    In making the determination of an adequate organization, it is important to note that the regulations do not specify the number of required inspection personnel the certificate holder, program manager, or other persons must have. Additionally,  121.365(c) and  135.423(c) recognize that the certificate holder, program manager, or other persons can use personnel for both maintenance and required inspections. In determining organizational adequacy, the certificate holder or program manager and aviation safety inspector (ASI) should consider the regulatory phrase, “adequate to perform the work.” The certificate holder or program manager and ASI should also consider the certificate holder’s or program manager’s legal requirement to perform its services with the highest possible degree of safety.
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NOTE:  The certificate holder or program manager should also consider the additional and related requirements of 91.1427, 91.1429(b), 121.369(a), 121.369(b)(7) and (8), 121.371(b), 125.245, 135.427(a), 135.427(b)(7) and (8), and 135.429(b), when making its determination of organizational adequacy.

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B.    Under the Supervision and Control of the Chief Inspector/Inspection Unit.

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1)    Sections 91.1429(b), 121.371(b), and 135.429(b) require that no person may allow any person to perform a required inspection unless, at that time, the person performing that inspection is under the supervision and control of the inspection unit. The certificate holder or program manager and ASI should note that the regulation directs compliance at the person with authority and responsibility for allowing (assigning or directing) another person to perform the required inspection. This person might be a manager, supervisor, or maintenance controller who assigns work. This person is responsible for ensuring that the person he or she assigns or allows to perform the required inspection is under the supervision and control of the inspection unit at the time he or she performs the required inspection. This requirement is normally not a problem for certificate holders, program managers, or other persons that have full-time or dedicated required inspection personnel. However, in cases where the certificate holder, program manager, or other person uses personnel for both maintenance and required inspection work, there must be an actual change in the control of that person from the control of the maintenance unit to the control of the inspection unit. Additionally, if the certificate holder or program manager allows its maintenance controllers to assign required inspection tasks, there must be a mechanism (control) in place that ensures that the person performing the inspection is under the supervision and control of the inspection unit and not the maintenance controller or maintenance unit. The certificate holder or program manager must describe in its manual how it and other persons will comply with this requirement. It is important for both management and maintenance personnel to know and understand this principle and recognize the authority and control of the inspection unit for required inspections.
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2)    The second part of the regulation pertains to the supervision of the person performing the required inspection by the inspection unit. Although the regulation does not specify a requirement for an inspection unit supervisor, it is both logical and apparent in the reading of the regulation. Additionally, it is supported by the requirements in 121.365(b) and 135.423(b) for an organization to be considered adequate to perform required inspection work. The supervisor can be the Chief Inspector or any other person the certificate holder or program manager chooses. However, it is important that the supervisor be separated from the maintenance unit in responsibility, authority, and interest to ensure the independent nature of the required inspection. The certificate holder or program manager must describe in its manual the requirements necessary to ensure compliance with this regulation for itself and other persons that perform required inspections for it.

3-3886    MANUAL REQUIREMENTS.

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A.    Organizational Chart or Description. Sections 91.1427(a), 121.369(a), and 135.427(a) require the certificate holder or program manager to put in its manual a chart or description of its required inspection organization required by 91.1423(b), 121.365(b), and 135.423(b), plus a list of persons with whom it has arranged for the performance of its required inspections, including a general description of that work. Section 125.249(a)(1) requires, “a description of the certificate holders maintenance organization, when the certificate holder has such an organization,” and 125.249(a)(2) requires the certificate holder’s or program manager’s manual to contain a list of persons with whom it has arranged for the performance of its required inspections, including their names and addresses. The respective certificate holders or program managers must keep this information current and available to the Federal Aviation Administration (FAA) for inspection. It must be readily available for use by certificate holder or program manager personnel that need this information to perform their jobs, such as persons involved in contract maintenance, with the repair of parts, with training, or auditing.

B.    Designation of Items of Maintenance and Alterations as an RII.

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1)    Sections 91.1427(b)(2), 121.369(b)(2), 125.249(a)(3)(ii), and 135.427(b)(2) require the certificate holder or program manager to designate items of maintenance and alteration that must be inspected (required inspections) as an RII, and list them in its manual. RIIs must include at least those items that, if not properly performed or if done with improper parts or materials, could result in a failure, malfunction, or defect that would endanger the continued safe flight and landing of its aircraft. When determining items of maintenance and alteration as RIIs, it is important that the certificate holder or program manager consider and account for the phrases, “at least those,” “that could result,” and “improper parts or materials.”
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NOTE:  Due to the varied maintenance systems used and different configurations of the same model of aircraft operated by the various certificate holders or program managers, the regulations do not include a listing of the items, which the certificate holder or program manager must inspect on each aircraft. Each certificate holder or program manager must determine the list of RIIs and include them in its manual.

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2)    A certificate holder’s or program manager’s designation of the RII should not be generalized in scope or described as a maintenance or inspection function, such as: replacing or rigging primary flight controls, replacing or rigging landing gear, engine installations, etc. This would identify the entire function as RII and does not specify an RII or step(s) in the function. While these functions are significant, such generalized listings do not meet the intent of the regulation since they do not identify the specific tasks within those functions that must be inspected as the RII. If the certificate holder or program manager lists a function as an RII, the certificate holder or program manager must identify the task(s) or step(s) within the function that is to be an RII.
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3)    RIIs relate directly to flight safety. Therefore, the certificate holder or program manager 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. The certificate holder or program manager should base its methods for determining its RIIs on regulatory requirements and sound principles. The certificate holder or program manager should identify the person(s) authorized and accountable for determining RIIs. These RII determinations must consider such things as failure consequences resulting from improperly performed maintenance or alterations, and the use of improper parts and materials. The certificate holder or program manager might consider using the expertise of the aircraft manufacturer and manufacturer’s instructions from the technical maintenance documents that are reflected in notes, cautions, warnings, comments, alerts, or otherwise identified as significant steps in the maintenance task. These are a good indication that there are aspects of the maintenance function that, if done improperly, could result in creating an unsafe condition. Additionally, the National Transportation Safety Board’s (NTSB) Aviation Accident Database and Synopses contains accident information relating to RII failures, which can be useful. However, the responsibility for determining and listing RIIs remains with the certificate holder or program manager.
4)    In order to maintain its significance, the list of RIIs should not be overinclusive. Instead, the certification holder should identify specific items of inspection for each aircraft (it is inappropriate to designate entire systems as RIIs).
5)    Some examples of items that may call for required inspections are:

    Proper torque and retainment device installation for engine and landing gear mounting hardware;

    Correct travel, cable routing, tensioning, hardware fitting/torque, and retainment device installation for flight control surfaces; and

    Certain emergency equipment installations for post-installation activation and rigging.

6)    Each operator must evaluate its maintenance program to identify RIIs. The operator may identify such items with the abbreviation “RII,” an asterisk, or any similar method.
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C.    Method of Performing Required Inspections. Sections 91.1427(b)(3), 121.369(b)(3), 125.249(a)(3)(iii), and 135.427(b)(3) require the certificate holder or program manager to include in its manual the method of performing required inspections. The method, technique, manner, or process used to perform the required inspection can be visual, functional, and/or operational; and can include such things as tests, checks, measurements, weighing, listening, feeling, tapping, and probing. The method must include any applicable inspection aids or equipment, such as a flashlight, mirror, magnifying glass, borescope, video equipment, rigging gauges, and measurement equipment.

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D.    Designation by Occupational Title. Sections 91.1427(b)(3), 121.369(b)(3), and 135.427(b)(3) require the certificate holder or program manager to include in its manual a designation by occupation title of personnel authorized to perform each required inspection. Examples of occupational titles are aircraft mechanic, aircraft inspector, aircraft maintenance supervisor, and aircraft maintenance foreman. Section 125.249(a)(2) requires, “a list of those persons with whom the certificate holder has arranged for performance of inspections under this part. The list shall include the persons’ names and addresses.”

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E.    Procedures for the Inspection of Work Performed Under Previous Required Inspection Findings (Buyback Procedures). Sections 91.1427(b)(4), 121.369(b)(4), 125.249(a)(3)(iv), and 135.427(b)(4) require the certificate holder or program manager to include procedures in its manual for the inspection of work performed under previous required inspection findings (buyback procedures). The certificate holder’s or program manager’s procedures should include how required inspection personnel will document a discrepancy found during the required inspection. Additionally, the procedures should include how maintenance personnel will document the work performed to correct the discrepancy. Finally, the procedures should include how required inspection personnel will inspect the work performed to correct the discrepancy. To ensure the performance of the inspection as required by 91.1427(b)(6), 121.369(b)(6), 125.249(a)(3)(iii), and 135.427(b)(6), the certificate holder or program manager should consider adding the procedural requirement to open or note a new required inspection requirement record for each discrepancy found during a required inspection. The certificate holder or program manager should be aware that a buyback event could be an indicator of a deficiency in the required inspection program. Therefore, buyback events should be input into the certificate holder’s or program manager’s Continuing Analysis and Surveillance System (CASS) for analysis.

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F.    RII Procedures, Standards, and Limits. Sections 91.1427(b)(5), 121.369(b)(5) 125.249(a)(3)(v), and 135.427(b)(5) require the certificate holder or program manager to include in its manual the procedures, standards, and limits necessary for required inspections and for acceptance and rejection of the inspected items. Section 121.135(a)(1) requires that the procedures include instructions and information necessary to allow the personnel concerned to perform their duties and responsibilities with a high degree of safety. The certificate holder or program manager must clearly define its procedures so that any inspector performing the required inspection will conduct it in a repeatable and consistent manner.

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1)    The certificate holder or program manager should establish when to perform the required inspection. If performed during a maintenance task or part of a scheduled maintenance check, the certificate holder or program manager should have controls in place to prevent any subsequent maintenance from invalidating the required inspection. It might be necessary to perform the inspection at a specified step in the maintenance task to prevent such things as skin, panels, or doors from covering the inspection item. Similarly, it might be better to perform the required inspection at the end of the task following completion of work. If performed at the completion of the work task, it is vital that the person performing the required inspection get a detailed hand-down from the person who performed the work rather than relying on just the maintenance signoff. Sometimes maintenance personnel move, disconnect, or disturb other things to gain access to the intended maintenance or alteration task. Although the required inspection is a focused inspection, the person performing it must be aware of the general condition of the work area. If the inspector is not aware of these things, improper maintenance can go unnoticed. The certificate holder or program manager should include in its manual its communication requirements for required inspection and maintenance personnel concerning work performed. Required inspection personnel should not assume that maintenance personnel performed proper maintenance until the inspector can verify the proper performance of maintenance. An example from NTSB accident data shows an aircraft accident resulting from a mechanic using only part of a procedure to perform the maintenance task without informing the inspector. Had the mechanic informed the inspector of exactly what he or she did, the inspector might have realized the problem and prevented the accident.
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2)    The certificate holder or program manager should clearly identify its RII requirements on work forms, job cards, Engineering Change Authorization/Orders (EA/EO), and the like, or by any other method consistent with its maintenance program. Certificate holders or program managers whose programs rely on the use of task cards or job cards to accomplish maintenance and inspections on flight control systems should ensure they base their procedures and any drawings on the aircraft manufacturer’s maintenance manual. Additionally, certificate holders or program managers should include discrete (separate or distinct) tasks with individual inspection signoff requirements for post‑rigging verification.
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3)    The certificate holder or program manager should have those procedures, standards, and limits necessary for the accomplishment of its required inspections and for the acceptance or rejection of each of its RIIs. As the certificate holder or program manager will not find RIIs or procedures, standards, and limits for RIIs in an Original Equipment Manufacturer’s (OEM) manual, it will have to develop these and put them in its own manual. The certificate holder or program manager should write its RII procedures for inspection personnel, and clearly state, at a minimum, what to look at (items of maintenance and alterations), how to look at it (method), what to compare it to (standard), and what is acceptable or not (limits).

G.    Procedures to Ensure the Performance of All Required Inspections.

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1)    Sections 91.1427(b)(6), 121.369(b)(6), 125.249(a)(3)(v), and 135.427(b)(6) require the certificate holder or program manager to have procedures in its manual for ensuring that all required inspections are performed. The certificate holder or program manager should specify who is responsible for completing each step of the required inspection process. The certificate holder or program manager should utilize controls in its required inspection program that ensure RIIs are identified, documented, and completed prior to releasing the aircraft to service, whether or not the certificate holder, program manager, or other persons authorized by the certificate holder or program manager perform the maintenance and inspection. The certificate holder’s or program manager’s procedures should state who is responsible for identifying and documenting an RII during both scheduled and unscheduled maintenance. Methods for identifying an RII for a maintenance task can vary, but the certificate holder or program manager should require, at a minimum:

    Early identification and documentation of the required inspection requirement, and

    A final review of the paperwork at the completion of work and prior to releasing the aircraft to service.

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2)    A job or task card that includes the RII requirement is a very useful and effective means of controlling the completion of the RII during scheduled maintenance. Procedures and controls also need to account for those instances when an unplanned required inspection is triggered by maintenance and alterations performed. In these cases, the certificate holder or program manager should consider the documentation of the required inspection requirement in the aircraft logbook.
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H.    Persons Who Perform Any Item of Work Cannot Perform the Required Inspection. Sections 91.1429(c), 121.369(b)(7), 125.249(a)(3)(vi), and 135.427(b)(7) require the certificate holder or program manager to include in its manual instructions to prevent any person who performs any item of work from performing any required inspection of that work. This includes any person who provides on‑the‑job training (OJT) to any person who performs an item of work. A primary concept of the RII function is that the person performing the item of work may not perform the required inspection on that item of work. The regulation recognizes the importance of the independent nature of the required inspection. As previously stated, it is important that the certificate holder or program manager identify required inspection requirements as early as possible during the maintenance task so that everyone is aware of the requirement, and supervision or management can take steps to assign an inspector independent of the maintenance task. Regulatory compliance problems are likely to arise during periods of unscheduled maintenance performed away from a company’s maintenance facility due to limited resources. Therefore, it is important that the certificate holder or program manager address these different situations in its manual and specify its method of control.

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I.    Countermand. Sections 91.1427(b)(8), 121.369(b)(8), and 135.427(b)(8) require the certificate holder or program manager to include instructions and procedures in its manual to prevent the reversal of any decision of an inspector regarding any required inspection by persons other than supervisory personnel of the inspection unit (subparagraph 3-3885B discusses supervisory personnel and the inspection unit). Additionally, a person at the level of administrative control that has overall responsibility for the management of both the required inspection functions and the other maintenance, preventive maintenance, and alterations functions may countermand an inspector’s decision. Volume 3, Chapter 43, Section 1 best illustrates the responsible person at the level of administrative control. The intent of the regulation is to ensure that only certain responsible and accountable persons countermand any inspector’s decision regarding a required inspection, if necessary. (See Volume 3, Chapter 43, Section 1, Table 3‑125, Air Carrier Maintenance Programs and Part 91 General Aviation Inspection Programs.) The certificate holder or program manager should include in its manual the positions (titles) it authorizes within its organization to countermand an inspector’s decision. Additionally, the manual should include procedures for documenting the countermand, including signatures and the basis or reason used for the countermand.

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NOTE:  Although regulations recognize countermand elements in the required inspection process, its use could be an indication of a serious problem or deficiency in the certificate holder’s or program manager’s organization. It could be an indication of such things as a poor safety culture, inadequate scheduling of maintenance, inadequate training or experience of inspection personnel, or deficient required inspection procedures. To ensure its proper use, the certificate holder or program manager should include the countermand event in its CASS.

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J.    Work Interruptions. Sections 91.1427(b)(9), 121.369(b)(9), 125.249(a)(3)(vii), and 135.427(b)(9) require the certificate holder or program manager to include procedures in its manual for ensuring the completion of required inspections interrupted because of shift changes or similar work interruptions before the release of the aircraft to service. Planned or unplanned interruption to required inspections poses a high risk to the safe operation of the aircraft. To mitigate the risk, the certificate holder or program manager should provide required inspection personnel with initial and recurrent maintenance resource management training that includes human factor (HF) training. Additionally, a simple but effective control for ensuring the completion of required inspections is the use of work forms designed for the recording of any interruptions during the required inspection. This form should be part of the certificate holder’s or program manager’s work package for the aircraft, and the persons performing work should review the form prior to releasing the aircraft to service. Another effective control for interruptions is the use of hand-downs, both verbal and written. Whatever method used, the certificate holder or program manager should have a documented process in its manual, and include the necessary provisions for other persons performing required inspections for the certificate holder or program manager.

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K.    Other Persons Performing Required Inspections. A certificate holder or program manager may arrange with other persons for the performance of required inspections on its aircraft. However, this does not relieve the certificate holder or program manager of its responsibility for compliance with required inspection regulations and its manual. Therefore, if the certificate holder or program manager uses other persons to perform required inspections, it must describe in its manual in sufficient detail how it will ensure compliance. There should be no differences in the certificate holder’s or program manager’s required inspection program and the required inspection program of the certificate holder’s or program manager’s maintenance providers. The certificate holder or program manager should consider listing each required inspection regulation and addressing it in its manual both for itself and for a maintenance provider, if applicable. The FAA highly recommends that the certificate holder or program manager use a written contract to document clearly and adequately its required inspection requirements with maintenance providers. The certificate holder or program manager should locate an adequate number of its qualified and authorized required inspection employees at the aircraft inspection site to monitor the performance of required inspections by others to ensure compliance with written instructions. Notwithstanding the importance of all required inspections, special attention should be given to required inspections involving flight control systems. The certificate holder or program manager should establish alternate procedures for those instances when a need arises for a required inspection at the worksite and the certificate holder or program manager representative is not available. The certificate holder or program manager should have a mechanism for the collection of data generated by the performance of required inspections by other persons for input into the certificate holder’s or program manager’s CASS to ensure the identification and correction of required inspection program deficiencies.

L.    Certificated, Trained, Qualified, and Authorized. The certificate holder or program manager should have requirements in its manual for selecting, training, qualifying, and authorizing required inspection personnel.

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1)    The certificate holder or program manager should establish criteria for the selection of required inspection personnel. Because of the required inspection’s connection to the safe operation of the aircraft, the certificate holder’s or program manger’s standards should be high. The certificate holder or program manager should establish a process for identifying and selecting inspector candidates. Mentor programs are useful in providing experience to personnel desiring to become inspectors. The process should focus on individual qualities normally associated with quality, such as responsibility, attention to detail, quality work habits, knowledge and experience, ability to focus and stay focused, and no history of mistakes or errors. The certificate holder or program manager must establish specific training requirements for required inspection personnel. Training must be specific to required inspection subjects. It should be a combination of formal classroom training, OJT, and recurrent training. It also includes such things as procedural training, inspection techniques, use of inspection aids or equipment, and HF training.
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2)    The certificate holder or program manager should closely monitor the new inspector for a period following the person’s training, qualification, and required inspection authorization. The certificate holder or program manager must include procedures in its manual for identifying and authorizing required inspection personnel, both within its organization and within organizations that perform required inspections on its behalf (refer to  91.1429(d), 121.369(b)(3), 125.251(a), and 135.427(b)(3)). The certificate holder or program manager must ensure it grants RII authorization only to persons trained, qualified, and holding an appropriate Airman Certificate.
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NOTE:  Even though an Airman Certificate is required by regulation, the person with the certificate performing the required inspection is not exercising the privileges of his or her certificate. The certificate holder or program manager must ensure the person it uses is appropriately certificated. The certificated person does not get the authority to perform the required inspection from his or her certificate. The authority comes from the certificate holder or program manager.

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3)    The certificate holder or program manager must formally notify each individual of his or her RII authorization as well as its scope (refer to 91.1429(d), 121.371(d), 125.249, and 135.429(e)). The regulations require that each certificate holder or program manager maintain, or determine that each person with whom it arranges to perform its required inspection maintains, a current listing of trained, qualified, and authorized persons who conduct required inspections. The certificate holder or program manager shall identify the person by name, occupational title, and the inspections he or she is authorized to perform. The certificate holder or program manager shall make the list available to the Administrator upon request. The certificate holder, program manager, or person with whom it arranges to perform its required inspection, shall give written information to each authorized person, describing the extent of his or her responsibilities, authorities, and inspection limitations. Some certificate holders or program managers issue cards to required inspection personnel that show the person’s authorization and any limitations. The use of cards has additional benefits in the control of inspectors, such as expiration dates and recurrent training requirements.
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M.    Persons Using Other Persons to Perform RII Inspections. Sections 121.371(a) and 135.429(a) specify that a person may not use another person to perform required inspections unless they meet certification and training requirements, and have been qualified and authorized to perform the inspection. The certificate holder or program manager shall provide the method and means for identifying RII inspection personnel meeting the regulatory criteria. The certificate holder or program manager shall identify the persons or job positions responsible for assigning or using RII inspection personnel in its manual. The certificate holder, program manager, or person with whom it arranges to perform its required inspections, shall give written information to each authorized person describing the extent of his or her responsibilities, authorities, and inspectional limitations.

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NOTE:  Compliance with 121.371(a) and 135.429(a) is directed at the person who uses (assigns or directs) any person to perform required inspection tasks. It applies to both the certificate holder’s or program manager’s organization, and other persons performing maintenance and required inspections for the certificate holder or program manager. The certificate holder or program manager that directs, assigns, or uses any person to perform required inspections is responsible for ensuring that the person it uses meets the regulatory and certificate holder’s or program manager’s requirements.

N.    Airworthiness Release Form or Log Entry. Part 43, 43.9(a) and 91.417(a)(1), 121.709(a), 125.411, and 135.443(b)(2)(ii) require the certificate holder, program manager, or person with whom the certificate holder or program manager arranges for the performance of the maintenance, preventive maintenance, and alterations to prepare, or cause to be prepared, an Airworthiness Release Form or Log Entry in the aircraft log. The Airworthiness Release Form or Log Entry must be prepared in accordance with the certificate holder’s or program manager’s manual. The airworthiness release certifies that, among other things, any required RIIs have been satisfied and determines the satisfactory completion of the work. Section 121.709(e) provides that, instead of stating the required inspection certification requirement, the certificate holder or program manager may state in its manual that the signature of an authorized certificated mechanic or repairman constitutes that certification.

O.    Part 135 Rotorcraft. Section 135.429(d) provides that in the case of rotorcraft that operate in remote areas or sites, the Administrator may approve procedures for the performance of RII by a pilot when no other qualified person is available, provided:

    The pilot is employed by the certificate holder;

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    It can be shown to the satisfaction of the Administrator that each pilot authorized to perform required inspections is properly trained and qualified;

    The required inspection is a result of a mechanical interruption and is not a part of a CAMP;

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    Each item is inspected after each flight until the item has been inspected by an appropriately certificated mechanic other than the one who originally performed the item of work; and

    Each item of work that is an RII and is part of the flight control system shall be flight tested and reinspected before the aircraft is approved for return to service.

Indicates new/changed information.

P.    Contract Maintenance. Although the regulations allow the certificate holder or program manager to use another person to perform its required inspections, it does not relieve the certificate holder or program manager of its responsibility for ensuring that other persons perform the required inspections in accordance with the certificate holder’s or program manager’s procedures. Based on accident investigation findings on failed required inspections, the FAA highly recommends that the certificate holder or program manager assign a qualified and authorized employee at the inspection site to oversee the performance of required inspections by other persons. In cases where the assigned certificate holder or program manager employee cannot be physically present at the worksite, such as during multiple shifts, there should be a method of contacting the assigned employee if any questions arise on a required inspection. There are additional requirements for certificate holders or program managers that contract out the performance of essential maintenance. Essential maintenance encompasses any on-wing accomplishment of any maintenance or alteration that the certificate holder or program manager has designated as an RII. Essential maintenance also includes the accomplishment of the required inspection itself. Essential maintenance does not encompass any off-wing maintenance. The certificate holder or program manager must perform required audits prior to using essential maintenance providers.

3-3887    REFERENCES, FORMS, AND JOB AIDS.

A.    References (current editions):

    Title 14 CFR Parts 91, 121, 125, and 135.

    Title 49 of the United States Code (49 U.S.C.) 46310, Reporting and Recordkeeping Violations.

    Advisory Circular (AC) 120-16, Air Carrier Maintenance Programs.

    FAA Order 8900.1, Flight Standards Information Management System (FSIMS).

    Volume 1, Chapter 3, Section 1, Safety Assurance System: Responsibilities of Aviation Safety Inspectors.

    Volume 10, Safety Assurance System Policy and Procedures.

    Volume 14, Chapter 1, Section 2, Flight Standards Service Compliance Action Decision Procedure.

B.    Forms. None.

C.    Job Aids. None.

3-3888    TASK OUTCOMES.

A.    Conduct Debriefing. Brief the certificate holder or program manager on the inspection results. Discuss all deficiencies, certificate holder or program manager corrective actions, and FAA actions. The ASI can find instructions for conducting briefings in Volume 1, Chapter 3, Section 1.

B.    Compliance and Enforcement Action. Investigate and gather the facts that led to any identified deficiencies. When debriefing the certificate holder or program manager, share information, discuss the facts, and identify the underlying root causes that led to the deficiencies. Review the certificate holder’s or program manager’s corrective actions and validate their effectiveness. Follow the process contained in Volume 14, Chapter 1, Section 2 to determine the appropriate FAA action.

1)    Compliance Action is the primary means of addressing safety concerns and regulatory noncompliance.
2)    Enforcement action when necessary is formal, administrative, and legal.

C.    Complete the Task.

1)    For parts 121 and 135:
a)    Follow SAS Volume 10 guidance for Module 4, Data Collection and Data Reporting. Upload items of proof supporting your “Inspector Actions Taken” into the DCT.
b)    Principal Inspectors (PI) follow Module 5, Analysis, Assessment, and Action procedures; upload supporting documents for your actions into the Action Item Tracking Tool (AITT). File any required supporting paperwork in the certificate holder’s office file.
c)    Update the SAS Configuration Module 1 Vitals Information, as required.
2)    For parts 91K and 125, complete the PTRS record.

3-3889    FUTURE ACTIVITIES.

A.    Parts 121 and 135. Follow SAS Volume 10 guidance to plan future risk-based surveillance in SAS for parts 121 and 135.

B.    Parts 91K and 125. Continue normal surveillance for parts 91K and 125.

RESERVED. Paragraph 3‑3890.