8900.1 CHG 239

VOLUME 6  Surveillance


Section 6  Safety Assurance System: Conduct Spot Inspection of a Program Manager/Operatorís Aircraft


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A.    Program Tracking and Reporting Subsystem (PTRS). For Aging Aircraft Inspections for Title 14 of the Code of Federal Regulations (14 CFR) parts 91 subpart K (part 91K) and 121, use the following activity codes:

    Spot Inspection: 3628, 5628.

    Structural Spot Inspection: 3647, 5647.

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B.    Safety Assurance System (SAS). For 14 CFR parts 121 (except Aging Aircraft Inspections) and 135, use SAS automation to develop a Custom Data Collection Tool (C DCT).

6-294    OBJECTIVE. This section provides guidance for observing and analyzing in‑progress maintenance operations for compliance with specific methods, techniques, and practices in the program manager/operatorís inspection and maintenance programs.

6-295    GENERAL.

A.    Definition. A work package is the job task control units developed by the program manager/operator for performing maintenance/inspections. A typical work package may include the following:

    Component change sheets;

    Inspection work cards;

    Nonroutine work cards;

    Appropriate sections of the maintenance procedures manual; and

    Engineering Change Orders (EO).

B.    Federal Aviation Administration (FAA) Inspection Personnel. It is important that Airworthiness aviation safety inspectors (ASI) are familiar with the type of aircraft to be inspected before performing the inspection. This can be accomplished through on‑the‑job training (OJT).

C.    Coordination Requirements.

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1)    For parts 121 and 135, follow SAS guidance for Modules 2 and 3 to request geographic inspector resources.
2)     Airworthiness ASIs possess various degrees and types of expertise and experience. An ASI who needs additional information or guidance should coordinate with personnel experienced in that particular specialty.


A.    Initiation. Spot inspections can be scheduled as part of the work program, but may be initiated whenever a problem is noted, including deficiencies noted during other types of inspections.

B.    Planning.

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1)    Spot Inspections Derived from the Planned Work Program or from SAS.
a)    The number of spot inspections in the work program depends on the type and number of program manager/operator aircraft. After determining the type of aircraft to be inspected, confirm the aircraft availability and scheduled maintenance functions with program manager/operator personnel.
b)    If the maintenance to be observed is known, review the program manager/operatorís maintenance procedures manual to become more familiar with the maintenance task. Review the following:

    Required Inspection Items (RII), if applicable;

    Forms used to document the maintenance task;

    Latest manual revision and date;

    Special tools and equipment used to perform the maintenance task; and

    Any other manual requirements relating to the maintenance task.

c)    For geographic requests, in which the maintenance procedures manuals are not in the office, review the applicable sections of the program manager/operatorís maintenance manual at the facility prior to performing this task.
d)    Examining previous inspection findings provides the ASI with background information regarding problem areas found during other spot inspections. This information can give an indication of how effective past corrective actions were in resolving previously identified problem areas.
e)    The FAA provides information such as Airworthiness Directives (AD), Service Difficulty Report (SDR) summaries, maintenance bulletins, surveillance data, and PTRS entries. This information should be reviewed, when available, to become familiar with current service difficulty information. While performing the spot inspection, ensure that any conditions described in this information do not exist on the aircraft.
2)    Spot Inspections Not Derived From the Planned Work Program. There are many situations while performing other surveillance activities that afford the opportunity to perform spot inspections. For example, if a discrepancy is found during the inspection that requires maintenance, a spot inspection of that maintenance function could be performed.

6-297    MAINTENANCE RECORDS. During performance of the spot inspection, special attention should be paid to the following areas, as applicable:

    ADís current status, including the method of compliance;

    Overhaul records, including documentation containing the overhaul details and replacement time;

    Major repair/alteration classifications and the use of approved data; and

    Replacement time of life‑limited parts.


A.    Selecting a Maintenance Task.

1)    Discuss with the maintenance supervisor what maintenance is currently being performed to determine what portions of that current maintenance/inspection should be observed.
2)    Special emphasis should be placed on observing maintenance tasks that involve RIIs. Problem areas to look at include the following:

    Persons performing inspections outside of their authorizations or limitations; and

    RIIs not being properly identified or accomplished.

B.    Performance Standards.

1)    Each program manager/operator has a maintenance/inspection program for their individual maintenance operations. For maintenance to be performed on the program manager/operatorís aircraft, there must be corresponding provisions and procedures in the program manager/operatorís maintenance manual.
2)    Each program manager/operator should have special procedures in the manual that ensure that persons outside of the organization perform maintenance in accordance with the program manager/operatorís maintenance manual.

C.    Discrepancies Noted During Surveillance. When deviations from accepted procedures are noted, it must be brought to the attention of maintenance management that corrective action must be taken immediately. Discrepancies noted during the inspection may require followup at a later time.


A.    Increased Surveillance. The Aging Airplane Safety Rule requires the FAA to validate the effectiveness of air carrier maintenance programs with regard to structural fatigue and corrosion. In response, the FAA uses the structural spot inspection to perform surveillance of transport category aircraft undergoing ďC,Ē ďD,Ē or similar ďheavy inspections.Ē Inspectors should coordinate and time their inspection activities with the certificate holder maintenance process.

B.     Inspection Area. During the observance of a ďheavy inspection,Ē ASIs must pick an inspection area where maintenance has been started and where there could be possible fatigue or corrosion problems (especially an area that is not usually open to inspection, such as under the galley or lavatories).

1)    If inspecting an area where maintenance is in progress, the following should be evaluated:
a)    While performing their job functions, are personnel accomplishing their job task per the work package?
b)    Does the Aging Aircraft/Corrosion Control program provide the necessary guidance to evaluate and respond in a timely manner to structural fatigue and corrosion?
2)    If inspecting an area where maintenance has already been accomplished, the following should be evaluated:
a)    Are there any structural fatigue or corrosion problems evident?
b)    If there are, were they identified by the person(s) responsible for that area?
c)      If they were identified, was corrective action initiated and completed?
3)    Is there an AD applicable to this problem? If there is an AD, what is the status of that AD?

NOTE:  While inspecting these areas that are not normally accessible, look for evidence of structural major repairs. If a major repair was accomplished, review the approved data for that repair.


A.    Prerequisites. Previous experience working with an operator/program manager with similar types of aircraft.

B.    Coordination.

1)    This task may require coordination between Avionics and Maintenance ASIs.
2)    Geographic inspector(s) must coordinate with the certificate-holding district office (CHDO) to obtain knowledge of the operatorís maintenance procedures and any other items of concern that may surface during routine inspections.


A.    References (current editions):

    Title 14 CFR Parts 39, 43, and 91K.

    Program Manager/Operatorís Maintenance Procedures Manual and Inspection Work Packages.

B.    Forms. None.

C.    Job Aids. None.

6-302    PROCEDURES.

A.    Initiate Spot Inspection (as applicable).

B.    Select Appropriate Aircraft for Inspection. Determine the following from the program manager/operatorís maintenance schedules:

    Aircraft availability;

    Aircraft type; and

    Type of maintenance being performed.

C.    Prepare for the Inspection. Review the following:

    Maintenance manual procedures for maintenance being performed (if available);

    Operations specifications (OpSpecs)/management specifications (MSpecs) time limitations, when applicable to the maintenance task;

    Previous inspection findings;

    Applicable maintenance alert bulletins;

    SDR summary at http://av-info.faa.gov/sdrx; and

    Any new regulation and/or AD requirements affecting the aircraft to be inspected.

NOTE:  If preparing for an Aging Aircraft Inspection, the ASI/Designated Airworthiness Representative (DAR)/Organization Designation Authorization (ODA) should select structural inspections, Corrosion Prevention and Control Programs (CPCP) tasks, or major repairs/modifications that are scheduled to be accomplished during this maintenance visit. If possible, supporting documentation for these tasks should be obtained before conducting the planned inspection.

D.    Perform the Spot Inspection.

1)    Identify the ASIs to the maintenance supervisor and discuss the nature of the inspection.
2)    Discuss the status of the selected maintenance task with the maintenance supervisor/person in charge.
3)    Select a particular maintenance task within the work package. If possible, include a maintenance task designated by the program manager/operator as an RII.
a)    Ensure that current maintenance procedures are available to the person(s) performing the work by accomplishing the following:

    Asking maintenance personnel for the maintenance procedures used to accomplish the work; and

    Recording the date of the maintenance procedures being used to perform the maintenance task for future comparison with the maintenance manual master copy.

b)    Ensure that the maintenance is performed according to established procedures by comparing actual performance to the program manager/operatorís approved maintenance/inspection manual procedures.
c)    Ensure the person performing maintenance is using the proper tools by accomplishing the following:

    Observing that the person performing maintenance is using special tools referenced in the maintenance manual; and

    Checking calibration due dates on precision tools, measuring devices, and testing equipment requiring calibration.

d)    Ensure that the program manager/operator has the facilities to properly perform the maintenance task.
e)    Ensure that systems being maintained are not exposed to environmental conditions that could contaminate or damage components.
f)    Ensure that the person performing maintenance accomplishes maintenance recording according to the operatorís recordkeeping system.
g)    Note any maintenance task deficiencies and include any copies of the documents that revealed the deficiencies.
h)    For those maintenance tasks involving RII functions, determine that the persons observed performing these functions are appropriately certificated, authorized, and qualified.

NOTE:  If performing an Aging Aircraft Inspection, the ASI/DAR/ODA should focus the inspection on the specific structural areas, tasks, and major repairs/modifications identified during the aircraft records review and scheduled to be accomplished during the maintenance visit.

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E.    Analyze the Findings. Evaluate inspection findings to determine if discrepancies exist and discuss the results with the principal inspector (PI)/program manager. For parts 121 and 135, follow SAS guidance for Module 5.

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A.    Complete the PTRS Record. When closing out a spot inspection, include the following information on FAA Form 8000-36, Program Tracking and Reporting System Data Sheet:

    The age of the aircraft (if applicable);

    If the operatorís inspection includes aging aircraft-related activities (if applicable); and

    The AD number, AD type, and inspection results, if an AD structural repair or modification was accomplished (if applicable).

NOTE:  If performing an Aging Aircraft Inspection, enter ďAGINGRIRĒ in the ďNational UseĒ block of Section I. Record aircraft times, cycles, inspection status, and other required data in the Comment block of Section IV.

B.    Complete the Task. Completion of this task can result in requested manual revisions.

C.    Document the Task. File all supporting paperwork in the program manager/operatorís office file.

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D.    Follow SAS Guidance. For parts 121 (except for Aging Aircraft Inspections) and 135.

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6-304    FUTURE ACTIVITIES. Based on the analysis of inspection findings, plan increased surveillance of problem areas, as applicable. For parts 121 (except Aging Aircraft Inspections) and 135, follow Volume 10, Safety Assurance System Policy and Procedures, to plan future risk‑based surveillance in SAS.

RESERVED. Paragraphs 6‑305 through 6‑319.