8900.1 CHG 526



Section 28  Safety Assurance System: Monitor Continuous Airworthiness Maintenance Program/Revision


A.    Program Tracking and Reporting Subsystem (PTRS). For Title 14 of the Code of Federal Regulations (14 CFR) part 91 subpart K (part 91K), use activity codes 3637 and 5637.

B.    Safety Assurance System (SAS). For 14 CFR parts 121 and 135 peer groups, use SAS automation. This section is related to all elements within aircraft technical operations of SAS. This section may be used in conjunction with Custom Data Collection Tools (C DCT).

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6-783    OBJECTIVE. This section provides guidance for ensuring that the operator’s Continuous Airworthiness Maintenance Program (CAMP) includes the maintenance/inspection tasks necessary to maintain its aircraft in an Airworthy condition.

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NOTE:  The Federal Aviation Administration (FAA) wrote this section primarily for inspecting parts 121 and 135 CAMPs. Aviation safety inspectors (ASI) can use this section to inspect a part 91K CAMP. However, the ASI should note that this section does not include the unique terms used in part 91K, such as fractional ownership, program manager, program aircraft, and operating manual. Additionally, because of the differences in the regulations for all three CAMP parts, ASIs must always refer to the current applicable regulation when verifying compliance.

6-784    GENERAL.

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A.    Authority to Conduct This Inspection. Title 14 CFR part 119, 119.59 is the regulatory authority for conducting this surveillance.

B.    Risk. Determining areas of high risk and prioritizing the surveillance of those areas is a Certificate Management Team (CMT) function and must be performed at the certificate-holding district office (CHDO) level.

C.    Data Collection Tool (DCT). ASIs use DCTs to collect data about the certificate holder’s CAMP. The DCT information helps the CMT assess the certificate holder’s or applicant’s system performance and design.

D.    Inspection Plan. If the ASI plans to include all 10 CAMP elements in the inspection, the ASI should consider developing an inspection plan based on risk assessment. Inspecting a CAMP in its entirety can be very complex; with a risk-based plan, the ASI is less likely to encounter unanticipated delays in the inspection.

E.    CAMP Elements. A CAMP contains 10 major elements. However, there are more than 10 CAMP regulations. CAMP regulations include all those listed in part 121 subpart L and part 135 subpart J. This section will cover each of the following 10 major elements:

1)    Airworthiness responsibility;
2)    Certificate holder maintenance manual;
3)    Certificate holder maintenance organization;
4)    Accomplishment and approval of maintenance and alterations;
5)    Maintenance schedule;
6)    Required Inspection Items (RII);
7)    Maintenance recordkeeping system;
8)    Contract maintenance;
9)    Personnel training; and
10)    Continuing Analysis and Surveillance System (CASS).

F.    CAMP Objectives. Operators operating under parts 121 and 135 (with operations specification (OpSpec) D072 authorization) are required to have a CAMP. A program manager operating aircraft under part 91, 91.1109(b)(5) may develop and maintain their aircraft under a CAMP. The CAMP must be detailed in the operator’s manual system and should contain specific maintenance and inspection tasks, including methods, standards, and techniques for accomplishing these tasks. The three CAMP objectives are:

1)    Maintenance, preventive maintenance, and alterations performed by the certificate holder or other persons are performed in accordance with the certificate holder’s manual.
2)    Competent personnel and adequate facilities and equipment are provided for the proper performance of maintenance, preventive maintenance, and alterations.
3)    Each aircraft released to service is Airworthy and has been properly maintained for operations under part 121, 135, or 91K, as applicable.

G.    OpSpecs/Management Specifications (MSpecs). The operator’s aircraft shall be maintained in accordance with the CAMP documents and limitations specified in OpSpec/MSpec D072.

NOTE:  OpSpecs/MSpecs are considered to be as legally binding as the regulations themselves.

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A.    References (current editions):

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    Title 14 CFR Parts 91K, 121, 135, and 43, 43.13(a) and (c).

    AC 120-16, Air Carrier Maintenance Programs.

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    AC 121-22, Maintenance Review Boards, Maintenance Type Boards, and OEM/TCH Recommended Maintenance Procedures.

    FAA Order 8900.1, Volume 3, Chapter 43, Section 1, Safety Assurance System: Evaluate a Part 121 and Part 135 Continuous Airworthiness Maintenance Program.

    Part D OpSpecs or MSpecs.

    Operator’s Maintenance Procedures Manual.

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B.    Forms. None.

C.    Job Aids. SAS DCTs.


A.    Prerequisites:

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    Familiarity with the operator’s maintenance procedures manual and OpSpecs or MSpecs;

    Familiarity with the type of aircraft being inspected; and

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    Familiarity with the Maintenance Review Board Report (MRBR) for the make, model, and series (M/M/S) of aircraft being operated by the certificate holder.

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B.    Coordination. This task requires coordination between the assigned principal maintenance inspector (PMI), principal avionics inspector (PAI), FAA supervisory personnel, the certificate holder, and, in some cases, the appropriate Aircraft Evaluation Group (AEG) and Aircraft Certification Office (ACO).


A.    Review the Operator’s OpSpecs or MSpecs. Determine what the applicable maintenance program requirements are.

B.    Review the Operator’s Manual. The manual system should define every facet of the CAMP.

C.    Review the CAMP for the Specific Aircraft Type. For air operators that have large, diverse fleets of aircraft, review the CAMP for the specific aircraft M/M/S that the CMT has chosen for this CAMP inspection.


A.    Airworthiness Responsibility.

1)    Consistent with part 121, 121.363 and part 135, 135.413, the certificate holder (as a part 119 certificate holder) is primarily responsible for the airworthiness of its aircraft and the performance of all of the maintenance, preventive maintenance, and alterations on its aircraft.
2)    ASIs should verify that the certificate holder retains primary responsibility for performing all maintenance, preventive 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).
3)    ASIs should be able to determine and verify who is responsible for what. While verifying the responsibilities, ASIs should be on the lookout for such things as:

    Gaps in responsibilities,

    Overlapping responsibilities,

    Undocumented responsibilities,

    Breaks in a chain of responsibility, and

    Ambiguities in procedures.

B.    Certificate Holder Maintenance Manual.

1)    The certificate holder’s manual must contain the CAMP in its entirety. This includes references to other documents containing portions of the program if not fully contained in the manual. A certificate holder may prepare its manual in any acceptable form, such as electronic or printed, on paper, on microfiche, or on microfilm. For more information on evaluating a manual, see Volume 3, Chapter 32, Section 11.
2)    Ensure the certificate holder has a maintenance manual; it is a required part of the certificate holder manual system. Some certificate holders call their maintenance manuals General Maintenance Manuals (GMM), and some use other terms.
3)    ASIs should verify that the certificate holder properly issues and controls manuals or parts of manuals. If the certificate holder chooses to use another person to perform maintenance, it should have well‑defined maintenance procedures in its manual for the maintenance provider to follow. This includes any parts of manuals the certificate holder might send to a maintenance provider performing unscheduled maintenance at an outstation. The certificate holder should have a process the ASI can verify for ensuring current, accurate, and complete information is sent to the provider.
4)    In some cases, especially with paper manuals, the certificate holder might use a temporary revision system. ASIs will verify temporary revisions the same way they verify a normal revision. The ASI should never find a case where the certificate holder is using a new policy or procedure before it is included in its manual either temporarily or permanently.
5)    The following are some other items the ASI can look for with paper manuals:

    Unauthorized or uncontrolled copies or parts of manuals,

    Physical condition of the manuals, and

    Unauthorized changes to manual content procedures (penciled-in writing).

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6)    Ensure technical manuals for performing maintenance are available. These manuals contain the standards for overhaul, repair, replacement, calibration, and other requirements to return the aircraft and its components to its original or properly altered condition. They consist of the current manufacturer’s maintenance/overhaul manuals and/or other standards developed by the operator and accepted by the FAA. (Refer to 121.369 and 135.427.)

C.    Certificate Holder Maintenance Organization.

1)    Verify that the certificate holder’s maintenance organization is 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 certificate holder 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.
2)    For operations conducted under part 121, ensure the certificate holder has qualified individuals serving full-time as the Director of Maintenance (DOM) and Chief Inspector, or in equivalent positions. If necessary for the certificate holder’s operation, the certificate holder can ask the FAA for a deviation from the types and numbers of required part 121 or 135 management positions.
3)    Check that the certificate holder states the duties, responsibilities, and authority of each of its management personnel in its manual. The certificate holder should state who has overall authority and/or responsibility, and who has direct authority and/or responsibility for a given process. In addition, the certificate holder must notify the FAA when it makes changes in its part 119-required management personnel or when it has a vacancy in one of those positions.
4)    ASIs should also verify that each person directly in charge (responsible for the work of a shop or station that performs maintenance, preventive maintenance, alterations, or other functions affecting aircraft airworthiness) is properly certificated, as specified in 121.378 and 135.423.

D.    Accomplishment and Approval of Maintenance and Alterations.

1)    Ensure the certificate holder has documented policies and procedures to perform maintenance on its own aircraft and to approve them for return to service. As a maintenance entity, the certificate holder has authorization to perform maintenance under 43.3(f), 121.379, and 135.437. In addition, 121.379 and 135.437 provide authority for the certificate holder to make arrangements with other persons to perform maintenance, preventive maintenance, and alterations, and under its certificate holder certificate, the certificate holder may also perform maintenance on behalf of other certificate holders that conduct operations under the same 14 CFR part as the certificate holder.
2)    ASIs should observe work in progress to verify that persons are performing maintenance, preventive maintenance, and alterations in accordance with the certificate holder’s manual.
3)    Check that each individual who makes an airworthiness determination on the certificate holder’s behalf holds an appropriate Airman Certificate, if required. Except for maintenance, preventive maintenance, alterations, and required inspections performed by a certificated repair station that is located outside the United States, 121.378 and 135.435 require that any individual whom the certificate holder puts directly in charge of performing maintenance and each person performing required inspections must hold an appropriate Airman Certificate. Sections 121.709(b)(3) and 135.443(b)(3) require that anyone whom the certificate holder authorizes to issue an approval for return to service holds an appropriate Airman Certificate. Refer to  121.709(c) and 135.443(c) for maintenance, preventive maintenance, or alterations performed by a repair station located outside the United States.
4)    Inspect engine, propeller, and appliances overhaul and repair facilities. This area concerns shop operations which, although they encompass scheduled and unscheduled tasks, are remote from the maintenance performed on the aircraft as a unit.
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5)    Instructions and standards for unscheduled maintenance should be included in the operator’s manual system. This includes manuals such as the aircraft Structural Repair Manual (SRM) and manufacturer’s maintenance manuals for aircraft, engine, propeller, and appliances. These manuals are a part of the CAMP and should be used when performing maintenance.
6)    Major repairs and alterations must be completed in accordance with technical data approved by the FAA. The certificate holder should have detailed major/minor classification procedures in its manual to evaluate each repair or alteration on a case-by-case basis.

NOTE:  For more information, see Volume 3, Chapter 43, Section 1. Additionally, all repairs and alterations categorized by the operator as “major” require that the work must have been done in accordance with technical data approved by the Administrator. Refer to 121.379(b) and 135.437(b).

E.    Maintenance Schedule.

1)    Sections 119.49 and 121.135(b) require the certificate holder to have maintenance time limitations, also called a maintenance schedule. The FAA authorizes the certificate holder maintenance schedule through the certificate holder’s OpSpecs.
2)    Verify through observations and maintenance record reviews that the certificate holder’s maintenance schedule provides a continuous succession of necessary or desirable scheduled maintenance tasks designed to maintain the certificate holder’s entire aircraft in an Airworthy condition.
3)    Certificate holders are authorized to use maintenance programs that they develop based on their operational environments. To ensure that the aircraft is maintained properly, ASIs should verify that, whatever combinations of inspection intervals are used (calendar time, cycles, or hours), the inspections are performed by whichever interval occurs first.
4)    After accumulating sufficient operating experience, certificate holders with an FAA-approved reliability program may make changes to their time limitations according to their program. Certificate holders without an FAA-approved reliability program also may revise their time limitations, but must first submit the proposal to the FAA CHDO for approval.
5)    ASIs should observe scheduled maintenance tasks that are accomplished concurrently with inspection tasks (i.e., Airworthiness Directive (AD) notes and Service Bulletins (SB)) that are not part of the scheduled inspection. Scheduled tasks include such items as:

    Replacement of life-limited items;

    Replacement of components for periodic overhaul or repair;

    Special inspection, such as x rays;

    Checks or tests for on-condition items; and


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6)    See the following Order 8900.1 sections for more information relating to the certificate holder’s maintenance schedule:

    Volume 3, Chapter 64, Section 1, Evaluate Proposed Adjustments to Task Intervals/Time Limitations for Maintenance Programs.

    Volume 6, Chapter 2, Section 31, Safety Assurance System: Inspect Approved Reliability Program.

    Volume 6, Chapter 11, Section 14, Safety Assurance System: Conducting Records Reviews and Aircraft Inspections Mandated by the Aging Airplane Rules for Parts 121, 129, and 135.

F.    Required Inspection Items (RII). This area concerns maintenance that, if performed improperly or if improper parts or materials are used, could result in failure, malfunction, or defect that would endanger the safe operation of the aircraft. They receive the same consideration regardless of whether or not they are related to scheduled or unscheduled tasks. The fact that an RII requirement arises at an awkward time or inconvenient location has no bearing on the need to accomplish it properly.

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1)    Sections 121.369(b)(2) and 135.427(b)(2) require the certificate holder to designate certain tasks as RIIs. Check that the certificate holder has identified specific items of inspection for each aircraft type as RII tasks.
2)    ASIs should verify the proper performance of an RII inspection by observing work in progress. A records review can only provide limited information on whether or not persons are actually performing RII inspections properly. ASIs should use the certificate holder’s RII inspection procedures in its manual as the standard for the inspection. Here is a list of things to look for when verifying the performance of an RII inspection:
a)    The person performing the RII inspection is appropriately certificated, and listed on the required list of persons who have been trained, qualified, and authorized to conduct the RII inspection on the certificate holder’s aircraft, including the person’s name, occupational title, and the RII inspections the person is authorized to perform. The certificate holder must provide the ASI with this list upon request. (Refer to  121.371 and 135.429.)
b)    The item of maintenance or alteration the person is inspecting is on the RII list in the certificate holder’s manual.
c)    The person performing the RII inspection is following the methods, procedures, standards, and limits for RII inspections in the certificate holder’s manual, including the acceptance or rejection of the RIIs to be inspected.
d)    The person performing the required inspection is under the supervision and control of an inspection unit, not the maintenance unit. (Refer to 121.371(b) and 135.429(b).)

G.    Maintenance Recordkeeping System.

1)    Ensure the certificate holder has a recordkeeping system, as required by 121.369(c) or  135.427(c). Check that the certificate holder recordkeeping system is documented in its maintenance manual and provides for the generation, storage, retention, and retrieval of accurate and complete certificate holder aircraft maintenance records. The certificate holder 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)    Each certificate holder shall keep the following records for the periods specified in 121.380(c) and 135.439(b):
a)    All the records necessary to show that all requirements for the issuance of an airworthiness release under 121.709 and 135.443 have been met.
b)    For part 121 certificate holders, the total time in service of the airframe. For part 135 certificate holders, the total time in service of the airframe, engine, propeller, and rotor.
c)    For part 121 certificate holders, except as provided in 121.380(b), the total time in service of each engine and propeller.
d)    The current status of life-limited parts of each airframe, engine, propeller, appliance, or rotor.
e)    The time since overhaul of all items installed on the aircraft that are required to be overhauled on a specified time basis.
f)    The identification of the current inspection status of the aircraft, including the times since the last inspections required by the inspection program under which the aircraft and its appliances are maintained.
g)    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.
h)    For part 121 certificate holders, a list of current major alterations to each airframe, engine, propeller, and appliance. For part 135 certificate holders, a list of current major alterations and repairs to each airframe, engine, propeller, appliance and rotor.
i)    For part 121 certificate holders, when an airworthiness release is prepared, the certificate holder must keep a record of it for at least 2 months (refer to 121.709(d)). For part 135 certificate holders, the record must be retained until the work is repeated or superseded by other work or for 1 year after the work is performed (refer to 135.439(b)(1)).

NOTE:  Section 119.59(c) mandates that the certificate holder must make its required maintenance records available to the FAA at any time when the FAA requires them. See Volume 6, Chapter 2, Section 36.

H.    Contract Maintenance.

1)    Currently, the trend in maintenance outsourcing is significant and underscores the need for effective FAA oversight. It is essential for certificate management personnel to have accurate information on who is performing maintenance, where that person is performing it, and the type of maintenance being performed. A risk-based system for oversight of aircraft maintenance, such as SAS, cannot be effective if it does not have complete and accurate information on the certificate holder’s contract maintenance program.
2)    Review the certificate holder’s airworthiness agreement with its maintenance provider(s) for the performance of maintenance. Verify that it meets the requirements specified in the certificate holder’s CAMP.
3)    See the following for information regarding oversight of a certificate holder’s contract maintenance program:

    Volume 3, Chapter 42, Section 1, Safety Assurance System: Initial and Continual Oversight and Evaluation of Essential Maintenance and Other Contract Maintenance Provider Programs and Contractual Agreements.

    Volume 6, Chapter 2, Section 40, Safety Assurance System: Inspect a Part 121 Certificate Holder’s Use of Other Persons to Perform Maintenance, Preventive Maintenance, and Alterations on its Aircraft.

I.    Personnel Training.

1)    ASIs will use the certificate holder’s training program as the standard for this inspection. A large part of the inspection involves reviewing training records for maintenance personnel to verify that training requirements have been met. ASIs should also observe training while it is being conducted. When reviewing records, the ASI should pay particular attention to persons authorized to perform required inspections and determine the adequacy of work performed. In addition to checking for completion of initial training requirements, ASIs should check recurrent training requirements. When observing training, ASIs should verify the following:

    The instructor is qualified to perform the training;

    The instructor is following a course syllabus;

    There is a means of measuring the student’s knowledge gained from the training; and

    The training is being conducted in an environment conducive to learning.

2)    This inspection answers the question: Is training being accomplished as stated in the certificate holder’s training program and is it ensuring that each person (including inspection personnel) who determines the adequacy of work done is fully informed about procedures, techniques, and new equipment in use and is competent to perform his or her duties? (Refer to 121.375 and 135.433.)

J.    CASS.

1)    Review the certificate holder’s CASS program, as described in the manual. Ensure that it contains policies and procedures for determining the effectiveness of the maintenance/inspection program and for corrective action of any deficiencies in those programs as required by 91.1431, 121.373, or 135.431.
2)    Ensure that the certificate holder’s manual describes a systematic method of reviewing operational data. It should determine the effectiveness of the maintenance/inspection program through:

    Surveillance: An information gathering/audit process you use to collect data to measure your program execution and measure your program results.

    Analysis: An analysis process you use to identify any maintenance program deficiencies and any necessary corrective actions.

    Corrective action: A planning process you use to ensure that your corrective actions are implemented.

    Followup: A performance measurement process that you use to verify that your corrective actions are effective. This is also an information gathering and analysis process, thereby closing the loop.

3)    Inspect the certificate holder’s system to audit the maintenance program. Contact the responsible person identified in the manual to determine what audits the operator accomplished in the past 12 months.
4)    Inspect audit functions by accomplishing the following:
a)    Sample a cross-section of the audit requirements identified in the manual and have the operator provide records of audit completion;
b)    Review the audit completion records to determine the scope and detail of inspection;
c)    Verify the results of the audit by performing spot checks of the audited facility;
d)    Verify that audits were performed within specified time periods;
e)    Determine whether persons who performed the audits have experience and expertise in the areas audited;
f)    Determine whether audit functions triggered by analysis are accomplished; and
g)    As applicable, verify that the certificate holder determined the root cause, developed corrective action, and conducted followup measurement using surveillance and analysis to verify that the corrective action has effectively corrected the deficiency.

NOTE:  See Volume 6, Chapter 2, Section 30, Safety Assurance System: Monitor Continuing Analysis and Surveillance System/Revision for Part 121/135 Certificate Holders and Part 91K Program Managers.

K.    Aging Aircraft and Corrosion Prevention and Control Programs (CPCP).

1)    ASIs should ensure that, as applicable, the certificate holder is in compliance with the following aging aircraft programs:

    Section 121.1107, Repairs Assessment for Pressurized Fuselages.

    Section 121.1109, Supplemental Inspections.

    Section 121.1111, Electrical Wiring Interconnection Systems (EWIS) Maintenance Program.

    Section 121.1113, Fuel Tank System Maintenance Program.

    Section 121.1115, Limit of Validity.

    Section 121.1117, Flammability Reduction Means.

2)    Verify that the certificate holder is accomplishing all parts of its CPCP, including the application of corrosion inhibiting compounds (CIC) when accomplishing each of the CPCP tasks.
3)    Most of the aircraft structural inspection programs are developed by the manufacturer. If the certificate holder has aircraft that are identified in a particular structural inspection document, verify that the certificate holder is accomplishing these additional age-related structural inspections as part of its CAMP.

L.    Special Maintenance/Safety Considerations.

1)    ASIs should verify that the Reduced Vertical Separation Minimum (RVSM) maintenance requirements and Extended Operations (ETOPS) maintenance requirements (if applicable) are imbedded into the CAMP. The ASI should request that the certificate holder show where in its CAMP the RVSM and/or ETOPS program requirements are located. ASIs might want to consider performing ETOPS surveillance separate from the CAMP inspection due to the complexity of the ETOPS program requirements.
2)    ASIs should ensure that the certificate holder’s CAMP includes Certification Maintenance Requirements (CMR) tasks. A CMR is a required scheduled maintenance task established during the design certification of the aircraft systems as an operating limitation of the type certificate (TC) or Supplemental Type Certificate (STC). CMRs should be appropriately identified as a limitation and cannot be deleted or escalated without ACO approval.
3)    The purpose of the critical design configuration control limitations (CDCCL) is to provide instructions to ensure these critical features are present throughout the life of the aircraft. ASIs should verify that CDCCL items are inspected, verified, and documented when alterations, repairs, or maintenance actions occur in the area. CDCCLs are a type of airworthiness limitation (AL), and 43.16 makes it mandatory for the certificate holders to comply with all ALs.
4)    MRBR tasks with safety Failure Effect Categories (FEC) 5 and 8 cannot be deleted or escalated without approval from the ACO.
5)    Check that the certificate holder’s program contains High Intensity Radio Frequency (HIRF) protection features, including wire shields, connectors, bonding jumpers, structural shielding, and terminal protection devices.
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6)    Aircraft must not be dispatched with pitot tubes, static ports, or any other aircraft sensory probe covers installed. ASIs should ensure that certificate holders have the following procedures in place:
a)    Procedures should exist for documenting, in the aircraft records, installation and removal of any covers, moisture-resistant paper, or any type of tape used to cover these openings;
b)    Certificate holders should use standardized, conspicuous covers with warning flags attached in any situation in which pitot static openings or any other aircraft sensory probes installed on the aircraft need to be covered for any reason; and
c)    Procedures should be in place to ensure the proper removal of any covers installed that may obstruct any pitot static opening or any other aircraft sensory probe installed on the aircraft for any reason.
7)    ASIs should review the certificate holder’s maintenance program to ensure the effectiveness of the inspection intervals for emergency and flotation equipment and to ensure regulatory compliance. The ASI should also ensure that the certificate holder’s CASS monitors the failure rate to determine if an adjustment to the inspection interval should be considered.
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M.    Coordinate the Findings. Due to the seriousness of any finding from this job task, discuss any deficiencies with the appropriate FAA supervisory personnel to verify the inspection findings.


A.    Complete the PTRS Record. For part 91K.

B.    Follow SAS Guidance for Modules 4 and 5. For parts 121 and 135.

C.    Complete the Task. Completion of this task may result in the following, as applicable:

1)    A followup letter informing the program manager of all inspection findings.
2)    Initiation of Compliance Action per Volume 14, Chapter 1.
3)    Information sharing, root cause analysis, corrective action development, and followup.

D.    Document the Task. File all supporting paperwork in the operator’s office file.


A.    Follow Up on Corrective Actions Taken by the Program Manager, as Applicable. For part 91K.

B.    Follow SAS Guidance. For parts 121 and 135.

RESERVED. Paragraphs 6-791 through 6-805.