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Section 1  Safety Assurance System: Evaluating an Airworthiness Directives Management Process


A.    Safety Assurance System (SAS). Use SAS automation and the associated Data Collection Tools (DCT).

B.    Program Tracking and Reporting Subsystem (PTRS). For Title 14 of the Code of Federal Regulations (14 CFR) parts 91 subpart K (part 91K) and 125, use the appropriate PTRS activity code.

3-4750    OBJECTIVE. This section provides aviation safety inspectors (ASI) with information to evaluate a certificate holder’s Airworthiness Directive (AD) management process.

3-4751    GENERAL.

A.    AD Management Process. The AD management process explained in this section presents a tangible means an operator may assess and respond to ADs. However, individual operations and needs should determine an operator’s AD management process. When developing an AD management process, operators should consider their size, capabilities, resources, and equipment.

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B.    AD Process Evaluation. It is the ASI’s responsibility to evaluate the operator’s process and determine if all pertinent elements of an AD management process are defined. When deficiencies are detected, an ASI should address these matters with the operator. When the AD management process is part of a Continuous Airworthiness Maintenance Program (CAMP), the Continuing Analysis and Surveillance System (CASS) must include the performance and effectiveness of the AD management process. The CASS is responsible to identify and correct deficiencies within the AD management process. The ASI may require the operator to make necessary manual changes when determining compliance with the applicable Continuing Analysis and Surveillance (CAS) rule.

C.    Current ADs. In order to perform adequate oversight, ASIs should remain aware of new ADs. This may be done by subscribing to the links listed below. ADs are posted in the Federal Register (FR) both as a notice of proposed rulemaking (NPRM) and as a final rule. These documents are readily available via the following links:


    Flight Standards Information Management System (FSIMS) at http://fsims.avs.faa.gov (refer to the link to the Regulatory and Guidance Library (RGL) (http://rgl.faa.gov)).

NOTE:  Each Web site provides a subscription service, which will generate an email notification.

3-4752    BACKGROUND.

A.    Federal Aviation Administration (FAA) Authority. The FAA authority regarding civil aircraft may be found generally in Title 49 of the United States Code (49 U.S.C.) 44701. One of the ways the FAA implements its authority is through 14 CFR part 39. ADs authorized under part 39 are issued in accordance with the public rulemaking procedures of the Administrative Procedures Act (APA).

B.    AD Issuance. The FAA issues ADs when an unsafe condition is found to exist in a product and which is likely to exist or develop in other products of the same type design. ADs are used to notify aircraft owners and operators of unsafe conditions and the actions required to resolve those conditions.

NOTE:  To ensure continued airworthiness, concerns regarding ADs should be addressed in a logical and comprehensive manner. This can be accomplished by operators developing robust AD management processes, which should encapsulate all six elements discussed in the remaining paragraphs of this section.

C.    Service Bulletins (SB) Incorporated by Reference (IBR) into ADs. The following provides background and general information related to best practices for SB related to an AD. The action(s) specified in an AD are intended to detect, prevent, resolve, or eliminate the unsafe condition. Those actions can either be written directly into the regulatory portion (“body”) of the AD, or another document, such as a SB, can be referenced in the AD body and submitted to the Office of Federal Register (OFR) for IBR approval. Compliance with a SB that is IBR into an AD is mandatory.

1)    Safety Intent and Configuration Description. An SB IBR in an AD may contain paragraphs entitled “Safety Intent,” and for ADs that will change the configuration of a part, “Configuration Description.” These paragraphs are intended to enhance and focus awareness of the safety issue during the development and approval of the SB as well as during implementation and subsequent maintenance. The “Safety Intent” paragraph should explain what accomplishment of the SB is intended to do (i.e., prevent, resolve, or otherwise remove the unsafe condition). The paragraph should be a concise and clear statement of the specific technical objective of the instructions. If accomplishing the SB will change configuration, a “Configuration Description” paragraph should be included to provide a concise, high-level description of the design change that will result from accomplishing the instructions. The “Configuration Description” should be limited to the features that will prevent development or recurrence of the unsafe condition once the configuration has been implemented. The “Configuration Description” may guide, but cannot be used as the final determinant of compliance with an AD.
2)    Critical Task Differentiation. An SB IBR in an AD may identify steps that have a direct effect on detecting, preventing, resolving, or eliminating the unsafe condition, with “RC” (required for compliance). Any substitutions or changes to RC steps will require an alternative method of compliance (AMOC) approval. Differentiating these steps from other tasks in a SB will improve an owner/operator’s understanding of crucial AD requirements and help provide consistent judgment in AD compliance. In older ADs, the term “RC” is not used and all steps are mandatory. An AMOC is required for any substitution or change desired by the owner/operator.

3-4753    RECOMMENDED PROCEDURES FOR DEVELOPING AN AD MANAGEMENT PROCESS. There are many distinct internal processes, controls, and actions necessary for AD compliance planning, implementation, and auditing. The remaining paragraphs of this section describe common processes and practices to manage ADs. The AD management process can be categorized into six elements:







3-4754    PLANNING. The planning element ensures awareness and assigns responsibility for AD requirements. The planning element may include a review of:

    The AD.

    Referenced documents.





    Maintenance execution.

    Quality control (QC).

    Quality assurance (QA).

A.    AD Configuration Control Board (CCB). An operator’s planning element may include an AD CCB that has regular meetings, or equivalent, where action plans are reviewed, coordinated, and assigned. The plan should identify the details (i.e., who, what, when, where, and how) regarding affective AD compliance. These meetings may help ensure all affected departments of the operator are aware of their responsibilities and where acknowledgement of those responsibilities is recorded.

NOTE:  Some operators may have fewer resources than others; therefore, a single individual or department may conduct AD planning functions.

B.    AD Planning Meetings. The operator may request/invite ASIs to the AD planning meeting. Therefore, the operator may develop a process for notifying and inviting its certificate-holding district office (CHDO)/principal inspector (PI) or local Flight Standards District Office (FSDO) prior to AD planning meetings. When the operator brings forth issues, concerns, or clarification requests, the ASI serves as an observer and a coordinator, and ensures that the appropriate FAA discipline (e.g., Aircraft Evaluation Group (AEG), Aircraft Certification Office (ACO), and Engine Certification Office (ECO)) is consulted and their recommendations/guidance is provided as feedback to the operator.

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NOTE:  Participation of an ASI is at the request of the operator. The ASI does not provide concurrence/approval of an operator’s compliance decisions. However, the ASI may provide input on applicable FAA policy and share best practices, safety suggestions and/or concerns. The ASI must clearly state which input is regulatory and which is non-regulatory or advisory as required by Volume 14, Chapter 1, Section 2, subparagraph 14-1-2-9C and the current edition of FAA Order 2150.3, chapter 5, subparagraph 3b). If the ASI is unsure of his or her role or how to participate/respond, the ASI must work interdependently to clarify the role and/or input with his or her office management and/or other subject matter experts (such as the AEG) as needed.

C.    Identifying Risks. The planning element is an appropriate venue to determine what verification process may be needed to identify risk, which would ensure continued compliance with ADs. An effective planning element should determine if an AD is applicable to the operator. The planning element should also include a risk analysis that considers the conditions that could arise through implementation or configuration changes. These conditions, which could affect the probability of errors, may include:

    Operator’s dynamics.

    ADs with a high risk of change.

    AD complexity (complex or workload-intensive ADs may create greater error rates and higher risks).


    ADs with repetitive inspections.

D.    AD Verification Process.

1)    Once these risks are analyzed, a possible AD verification process may be developed to include:

    Physical verification,

    Verification of records,

    Meeting criteria for inclusion into a sampling program, and

    A required one-time verification (i.e., no future verifications are required).

2)    An effective planning element should identify ADs that have the highest risk for potential alteration(s) during normal maintenance. Once a risk assessment is accomplished, prioritized ADs should continually be verified through an operator-developed verification program.

E.    AEG Consultation. The planning element should include consultation with the AEG, which will coordinate with the ACO/ECO responsible for managing the AD if clarification is needed. Complex AD concerns should be brought forward at this time and clarification should be shared with the operator. This is also an opportune time to determine if the contemplated actions will comply with the AD.

F.    AMOC Policy. The extent and nature of appropriate AD compliance documentation and determining if an AMOC is required should be considered during the planning element. ASIs must determine that the operator has a defined policy and procedure to identify and determine if an AMOC is necessary. The operator’s AMOC policy should:

    Identify the specific requirements needed to obtain approval;

    When proposing an AMOC, consider making it for global distribution;

    When requesting design approval holder (DAH) assistance in obtaining an AMOC, provide permission to allow the DAH to pursue a global AMOC if appropriate;

    Identify personnel and their role in the process;

    Have a concise process to ensure deviations from AD requirements do not occur, unless the deviations have written approval (i.e., an approved AMOC); and

    Ensure AD compliance is recorded only after an approved AMOC has been accomplished.

NOTE:  AMOC proposals, which can be submitted at any time during the AD management process, must be processed through the cognizant ACO/designee and/or local FSDO/PI. The AD identifies the responsible ACO that approves/disapproves AMOC proposals. Refer to part 39,  39.19 and the current edition of FAA Order 8110.103, Alternative Methods of Compliance (AMOC), for more information.

G.    Communication. As part of an AD management process, it is recommended that operators/air carriers develop a process to coordinate AD compliance matters with their local FAA office. This process may reference a conflict resolution process for circumstances that need an immediate resolution. Before agreeing to such a process, the FAA local office will ensure that the FAA’s role, as defined in the process, is consistent with FAA policy.

H.    Additional Areas of Consideration. Some of the areas that an operator should consider during the planning element include:

1)    Careful review of the AD with particular focus on any unique aspects of the AD. Does it require specific parts or articles that require long lead times? Does it impact future inspection schedules?
2)    Determining any unique product or appliance aspects. Does the AD apply to the entire fleet or only particular products or appliances? Are there repairs or alterations on the product or appliance that might require an AMOC?
3)    Evaluating the method of compliance as annotated in the maintenance records (e.g., task cards, engineering orders, engineering authorizations, etc.) to ensure AD requirements will be met.
4)    Determining whether to use physical markings to identify areas where an AD is in effect.
5)    Determining whether AD-referenced service instructions have already been accomplished. Also, determine if any deviations occurred from the service instructions, which would require an AMOC.
6)    Determining whether there should be changes to the Aircraft Maintenance Manual (AMM), an Illustrated Parts Catalog (IPC), or a Wiring Diagram Manual (WDM) to ensure continued compliance.
7)    Ensuring rotable spares and work performed in the shop are AD compliant and that noncompliant spares are not installed on compliant aircraft.
8)    Determining the need for training and specific labor skills (e.g., avionics, Nondestructive Testing (NDT), structures, etc.).
9)    Determining the restriction of AD accomplishment to site-specific locations.
10)    Determining the need for an enhanced perspective (i.e., a second set of eyes) at the point of implementation.
11)    Determining when and how audit plans will be impacted for ADs that call for segmented actions.
12)    Determining whether prototyping is needed and, if so, the persons or departments that will accomplish that process.

3-4755    SUPPORT. The support element may consist of engineering, provisioning material, configuration control, etc. Not all operators will have in-house engineering capabilities; however, they will have personnel responsible for coordinating and auditing technical documentation. Staff responsible for technical documentation may also be responsible for reviewing and evaluating information associated with an AD. The operators may also employ or use outside engineering staff.

NOTE:  The term “engineering” is used as a generic reference to a department or individual that performs this function.

A.    Establish the Method of Compliance. The operator’s process should ensure that the AD method of compliance is concisely tracked and is included in maintenance records. Therefore, the operator should use the support element to establish the method of compliance with each AD requirement.

B.    Schedule Coordination. The support element regarding configuration control may involve confirmation of forecasts and schedules to accomplish the work of AD implementation. The schedule coordination should preclude changes to the direction that was determined (e.g., omissions or changes to task cards).

C.    Organizational Structure. Depending on the operator’s organizational structure, materials and scheduling/planning departments are responsible for ensuring the materials specified in the AD and engineering document are provided. Those departments should plan for adequate capacity and time to accomplish the AD requirement(s) in appropriate work environments with the required maintenance personnel.

D.    Deviations. During accomplishment of AD-mandated actions, it is sometimes necessary to use an AMOC to deviate from the provided work instructions. Deviations may be due to issues such as configuration differences, damage findings, oversize fastener requirements, material substitutions, or service instruction discrepancies. The operator should have a process in place, preferably during the planning phase of AD implementation, to support these alternative processes/procedures. This process often involves an engineering department capable of collecting and addressing the necessary changes and then coordinating those changes with the DAH, FSDO/certificate management office (CMO), and ACO/ECO, as required. In addition, having an engineering department as part of this process may identify potential fleet-wide compliance or safety concerns and allow industry-wide resolution.

E.    Engineering Review. The operator’s engineering review should include a side-by-side, paragraph‑by‑paragraph comparison of all AD requirements against any compliance actions developed by the operator. The engineering review should:

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1)    Ensure that the certificate holder’s method of compliance conforms to each element of an AD, or
2)    Identify if an AMOC is needed. (Refer to Order 8110.103.)

NOTE:  Obtaining direct input from the maintenance organization during the support element review of engineering-authorized documents can help operators eliminate a single-point failure risk.

F.    Prototyping. If prototyping is needed, the AD management process should provide instructions to perform prototyping assistance and monitoring. Silent prototyping (i.e., witnessing a technician accomplish the instructions) is recommended.


A.    Capabilities, Time, and Materials. The operator’s materials and scheduling/planning departments should ensure that the materials specified in the AD and/or AMOC are procurable and available at the scheduled time for AD accomplishment. A provisioning element should also ensure adequate time and capabilities are sufficient to accomplish the AD in an appropriate work environment with the required maintenance personnel, tooling, and equipment.

B.    Kitting. An operator may develop or be able to purchase from the Original Equipment Manufacturer (OEM)/DAH a kit that consists of all the AD-required parts and materials. This process is referred to as “kitting.” The accuracy of the kit contents should be verified. Special attention should be made to ensure that part or material substitutions are only made with written approval from the appropriate ACO/ECO/designee (refer to the AMOC process in Order 8110.103).

C.    AMOC Proposal. If AMOCs are required for parts or material substitutions, the AMOC proposal should be coordinated in a timely manner so that all provisions of the AD are in compliance by the due dates.

3-4757    IMPLEMENTING. The implementation element is the result of finalized actions involved in the planning, support, and provisioning elements.

A.    AD Work Instructions. Operators are responsible for accomplishing AD work instructions in accordance with their procedures. This is the sole responsibility of the operator regardless with whom they make arrangements for performing AD work instructions.

B.    Verify the Method of Compliance. The ASI’s presence during the implementation element is an opportune time to verify and validate an operator’s compliance method. However, the ASI does not provide concurrence/approval of an operator’s compliance method.

C.    AD Accomplishment. When evaluating an operator’s prototyping process, the ASI should pay attention to an ADs accomplishment with particular attention to determine whether the mechanic can understand and perform the actions required by the AD. If ASIs believe there is a problem during prototyping, they should address their concerns to the operator’s appropriate manager.

3-4758    RECORDING. The recording element should include the option of archiving all planning, supporting, provisioning, and implementing element documentation, as well as validation audits.

A.    Maintenance Records. Maintenance records establishing AD compliance must be maintained in accordance with regulatory requirements. Once a maintenance record is made showing AD compliance, the product must meet and continue to show compliance with required AD actions. When inspecting AD records, ASIs will review the documents for compliance requirements listed below.

1)    Identification of the particular airframe, aircraft engine, propeller, and appliance to which the AD is applicable.
2)    AD compliance requirements for part 91, 91.417(a)(2)(v), which states: “The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required.”
3)    AD compliance requirements for part 121, 121.380(a)(2)(vi), which states: “The current status of applicable airworthiness directives, including the date and methods of compliance, and, if the airworthiness directive involves recurring action, the time and date when the next action is required.”
4)    AD compliance requirements for part 135, 135.439(a)(2)(v), which states: “The current status of applicable airworthiness directives, including the date and methods of compliance, and, if the airworthiness directive involves recurring action, the time and date when the next action is required.”

NOTE:  Regarding the records for 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 service instructions permit the use of more than one method of compliance, the record must include a reference to the specific method of compliance used. When reviewing service instructions, place emphasis on the imbedded notes. If the operator 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 of the AMOC. For more guidance regarding recordkeeping, review the sections of this order that pertain to maintenance records.

B.    AD Record of Accomplishment. Listing the current status of an AD or method of compliance should not be confused with an AD record of accomplishment. The AD record of accomplishment is a description of the work and the person who performed it on the product.

3-4759    AUDITING. The main objective of an operator’s auditing element is to provide a comprehensive method for continual verification and validation of AD compliance.

A.    Compliance Validation. An effective auditing element of the operator should have a concise method of auditing ADs for continued compliance. This method may range from periodic compliance validation to a sampling program. The auditing element should also have a written process and procedure with specific intervals identified.

B.    Validation Checks. Validation checks are considered when there is a risk of altering mandated AD actions or when there are highly complicated requirements that cross many maintenance areas. Validation checks may include random sampling or physical validation. (Refer to the current edition of Advisory Circular (AC) 39-9, appendix 5, Sampling Program and Physical Verification.)

C.    Auditing Subelements. A comprehensive auditing element should include the following subelements:

1)    Audit Processing. A documented activity that assesses the effectiveness and efficiency of a series of related or sequential work activities.
2)    Audit Scheduling. A program that establishes a schedule of events (SOE) to be performed during a set calendar period.
3)    Audit Preparation. A plan that considers the resources needed to perform an audit (e.g., source documents, personnel, facilities, and access of equipment).
4)    Audit Performance. A documented activity that determines whether the objective evidence of applicable AD management process elements are implemented and documented.
5)    Audit Results Process. A process that includes:

    A method to identify noncompliance and/or unsafe conditions that should result in immediate reporting and corrective measures to resolve noncompliance;

    Describing audit findings and how they were discovered (results may be presented in terms of findings, concerns, observations, and recommendations);

    Analyzing evidence to determine the root cause(s) of the finding;

    Identifying planned corrective actions to take in response to the finding; and

    Establishing a timeframe for putting corrective actions in place.

D.    Documentation. Documenting all decisions made during the AD management process is encouraged so that appropriate measures can be taken and processes can be improved in case any issues arise.

NOTE:  To evaluate an operator’s CASS performance verification and auditing as it relates to AD compliance, see Volume 3, Chapter 44, Section 1; and refer to the current edition of AC 120-79, Developing and Implementing an Air Carrier Continuing Analysis and Surveillance System.


A.    References (current editions):

    Title 14 CFR Part 39, 39.19.

    Part 91, 91.417(a)(2)(v).

    Part 121, 121.373 and 121.380(a)(2)(vi).

    Part 135, 135.439(a)(2)(v).

    Title 49 U.S.C. 44701.

    AC 20-176, Design Approval Holder Best Practices for Service Bulletins Related to Airworthiness Directives.

    AC 39-7, Airworthiness Directives.

    AC 39-9, Airworthiness Directives Management Process.

    AC 120-79, Developing and Implementing an Air Carrier Continuing Analysis and Surveillance System.

    FAA IR-M-8040.1, Airworthiness Directives Manual.

    FAA Order 8110.103, Alternative Methods of Compliance (AMOC).

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    Volume 10, Safety Assurance System Policy and Procedures.

B.    Forms. None.

C.    Job Aids. None.

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3-4761    TASK OUTCOMES. Follow SAS Volume 10 guidance for Modules 4 and 5 for data collection; completes the Analysis, Assessment, and Action (AAA), and Action Item Tracking Tool (AITT).

3-4762    FUTURE ACTIVITIES. Follow SAS Volume 10 guidance to plan future risk based surveillance in SAS.

RESERVED. Paragraphs 3-4763 through 3-4774.