8900.1 CHG 0



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

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A.    Program Tracking and Reporting Subsystem (PTRS). For Title 14 of the Code of Federal Regulations (14 CFR) parts 121, 129, and 135, use PTRS activity codes 3634, 5634, 3647, and 5647. If reviewing reports submitted by a Designated Airworthiness Representative (DAR)/Organization Designation Authority (ODA), use PTRS activity codes 3646 and 5646.

B.    Safety Assurance System (SAS). This section is related to SAS Elements 4.2.1 (AW) Maintenance/Inspection Requirements and 4.6.2 (AW) Maintenance Special Emphasis Programs, but not reported in SAS.

6-2487    OBJECTIVE. This section provides guidance on conducting aging airplane inspections and records reviews to accomplish the requirements of the Aging Airplane Safety Final Rule and the Aging Aircraft Safety Act of 1991 (the Act). The Act requires the Administrator to make inspections and to review the maintenance and other records of certain aircraft to decide whether they are maintained in an Airworthy condition. To accomplish this, the aviation safety inspector (ASI) will conduct structural spot inspections and aircraft records surveillance, as deemed appropriate. The air carrier, to accomplish the required aircraft records reviews and inspections, may use DARs and/or ODAs.

NOTE:  For the purpose of this function, “the Administrator” is defined as ASIs, DARs, ODAs, or other persons so designated to accomplish these inspections.

6-2488    GENERAL.

A.    Basic Requirement. The basic requirement is to inspect each aircraft and review its records; however, a sampling of these tasks and records for each airplane, along with routine surveillance of a certificate holder’s maintenance program, will ensure that each airplane and its age-sensitive components are properly maintained. This guidance is applicable to each airplane operated under part 121 (except those airplanes operated solely within the state of Alaska); part 135 multiengine, in scheduled service (except those airplanes operated solely within the state of Alaska); and U.S.-registered, part 129 multiengine aircraft. Special coordinating instructions for aircraft operated under part 135 on-demand rules can be found in subparagraph 6-2493A. Aircraft and records inspections are reported in PTRS for all 14 CFR parts.

B.    General.

1)    Records Review. The ASI/DAR/ODA will review/sample the following records for each airplane described in subparagraph A above to ensure confidence that the carrier is maintaining adequate/reliable records:
a)    Total years in service.
b)    Total flight hours of the airframe.
c)    Total flight cycles of the airframe.
d)    Date of last records review and inspection required by part 121, § 121.1105; part 129, § 129.105; and part 135, § 135.422.
e)    Current status of life-limited parts of the airframe.
f)    Time since last overhaul of all structural components required to be overhauled on a specific time basis.
g)    Current inspection status of the airplane, including the time since the last inspection required by the inspection program under which the airplane is maintained.
h)    Current status of the following, including method of compliance:

    Airworthiness Directives (AD), and

    Inspections and procedures required by § 121.1109 and § 129.109.

NOTE:  The effective date of these rules is December 20, 2010.

i)    A list of major structural alterations.
j)    A report of major structural repairs and the current inspection status of those repairs.
2)    Aircraft Inspections. The intent of the Act will be met by accomplishing structural spot inspections as outlined in Volume 6, Chapter 2, Section 6, Safety Assurance System: Conduct Spot Inspection of a Program Manager/Operator’s Aircraft.
3)    Federal Aviation Administration (FAA) Inspection Personnel. FAA ASIs who perform these inspections must possess a Mechanic Certificate with an airframe rating. It is important that ASIs are familiar with the type of aircraft and records system of the air carrier before performing these inspections. ASIs possess various degrees and types of experience. An ASI who needs additional information or guidance should coordinate with personnel experienced in that particular specialty. This can be accomplished through on-the-job training (OJT) provided by the office with responsibility for oversight of the air carrier the ASI will be inspecting.
4)    Coordination Requirements.
a)    It is essential for the certificate-holding district office (CHDO)/certificate management office (CMO) to coordinate with the operators and geographic inspectors to ensure that no unnecessary delays are incurred as a result of records reviews and aircraft inspections if inspections are to be accomplished using geographic ASIs.
b)    Geographic inspectors may be needed to assist the CHDO/CMO in performing these inspections/reviews. Coordination is required to transmit all inspection results and/or recommendations to the CHDO/CMO including a list of discrepancies found.
c)    The CHDO/CMO will be responsible for notifying the certificate holder that the inspection/review has been completed.


A.    Initial Notification.

1)    Sixty-Day Notification to the FAA. The rules require that the operators notify the FAA at least 60 days before the airplane and its records will be available for inspection and review. Operators should be encouraged to provide advanced planning schedules of aircraft undergoing heavy maintenance. Principal maintenance inspectors (PMI) should work closely with their operator during this period to address any issues that could delay the records review and inspection or prevent the airplane from returning to service as scheduled.
2)    Unforeseen Scheduling Conflict. The rules provide for a 90-day extension to the 7-year interval for repetitive records reviews and aircraft inspections. Should an unforeseen operator scheduling conflict occur, the CHDO/CMO may approve an extension of up to 90 days, provided the operator presents written justification for the scheduling conflict. Electronic, facsimile, or other forms of notification may be accepted. Operators should be encouraged to provide ample time for the CHDO/CMO to respond to the extension request.

NOTE:  Extensions may only be approved for the 7-year repetitive inspection intervals. In all cases, the initial compliance threshold to the applicable rule must be met.

NOTE:  An extension can only be granted by the CHDO/CMO.

B.    Heavy Maintenance Check. The Act states that the records reviews and inspections will be carried out as part of the operator’s heavy maintenance check. For the purpose of complying with this statute, a heavy maintenance check is defined as a “C” check or segment thereof, a “D” check or segment thereof, or other scheduled maintenance visits where structural inspections are accomplished.

C.    Planning. The records review(s) can be, and usually will be, accomplished separately from the aircraft inspection. This is because many operators perform maintenance in one location while the records may be maintained in a different location. If the records review and aircraft inspection are conducted separately, the operator should provide a summary of any additional records entries at the time of the aircraft inspection, such as ADs accomplished and major repairs accomplished.

D.    Records Reviews and Inspections. Records reviews and airplane inspections for parts 121, 129, and 135 scheduled operators will be similar.

1)    Records Review.
a)    The operator may provide actual “hardcopies” of the records or summaries of compliance as per its approved recordkeeping program.
b)    The ASI/DAR/ODA should plan to sample the records to verify accuracy.
2)    Aircraft Inspection.
a)    Confirm the aircraft is available. Schedule the inspection when the aircraft has been sufficiently prepared for inspection (i.e., opened/cleaned).
b)    The ASI should be familiar with the aircraft type and inspection program the aircraft is maintained under.
c)    Based on the records review and the planned maintenance, the ASI/DAR/ODA should select several structural inspection items to sample, if practical. Included in the items selected for sampling should be job task cards that indicate the:


    Method of compliance,

    Tooling required, and

    Required signoffs.

3)    Air Carrier Notification. The CHDO/CMO must notify the operator that the records reviews and inspections are complete. Because the aircraft records reviews and/or inspections may be accomplished by different inspectors in different geographic locations, coordination of these efforts is essential. Final notification to the operator will be made by the CHDO/CMO.


A.    Prerequisites.

    Familiarity with the aircraft type and inspection program the aircraft is maintained under.

    FAA Course 27100061, Flight Standards Aging Airplane Safety Rule (AASR).

B.    Coordination. This task requires coordination between ASIs, DARs, and ODAs. It also requires coordination between CHDO/CMO and operators/geographic units.


A.    References (current editions). FAA Order 8900.1, Volume 6, Surveillance:

    Chapter 2, Parts 121, 135, and 91K Inspections,

    Section 6, Safety Assurance System: Conduct Spot Inspection of a Program Manager/Operator’s Aircraft,

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    Section 35, Safety Assurance System: Inspect Section 135.411(a)(1) (Nine or Less) Certificate Holder’s Maintenance Records, and

    Section 36, Safety Assurance System: Inspect Parts 91K and 121/135 (10 or More) Operator’s Maintenance Records; and

    Chapter 4, Part 129 Inspections: Monitor Maintenance Program for U.S.-Registered Aircraft Operated by a Foreign Operator Under Part 129; and

    Chapter 11, Section 24, Safety Assurance System: Evaluate/Inspect Parts 121 and 129 Operators’ Electrical Wiring Interconnection Systems Maintenance Program.

B.    Forms. None.

C.    Job Aids. None.


A.    Receive the Records. The certificate holder will coordinate with the FAA to provide the location and the status of the records required by §§ 121.1105, 129.105, and 135.422. Volume 6, Chapter 2, Sections 6, 35, and 36; and Volume 6, Chapter 4 provide necessary guidance for evaluating the required air carrier maintenance records.

B.    Conduct the Review. The ASI/DAR/ODA will review/sample the records identified in subparagraph 6-2488B1).

NOTE:  The records review and airplane inspection may be carried out by different ASIs/DARs/ODAs in different locations. This will require coordination among the inspectors to ensure discrepancies noted in either the records review or the airplane inspection are investigated to ensure compliance with regulations.


A.    Plan the Inspection. The ASI will coordinate with the certificate holder as to the scope and extent of the planned inspection. Volume 6, Chapter 2, Section 6 provides necessary guidance for accomplishing structural spot inspections.

1)    The ASI/DAR/ODA should select structural inspections, Electrical Wiring Interconnection Systems (EWIS), 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.
2)    While performing these inspections, every effort should be made to avoid interfering with, or inconveniencing, the planned/scheduled maintenance.

B.    Observe Maintenance Tasks. Observe maintenance tasks to ensure that:

    Work instructions provide sufficient detail to accomplish the scope of the required maintenance task;

    Required tooling and materials are available and used; and

    Work is accomplished by properly trained and qualified personnel.

6-2494    TASK OUTCOMES.

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A.    Complete the PTRS Record. Complete the PTRS record to track the accomplishment of these inspections. Use activity code 3647 or 5647 for the aircraft inspection and 3634 or 5634 for the records review. Use activity code 3646 or 5646 when reviewing reports submitted by a DAR/ODA. Enter “AGINGRIR” in the “National Use” block of section I. In section IV, the “Comment” block, record airplane times, cycles, inspection status, and other required data.

B.    Complete the Task. Successful completion of this task will result in the following:

1)    The cognizant PMI will be notified of any significant findings.
2)    ASIs, designees, or the operator will notify the cognizant PMI electronically or verbally upon completion of the records review or aircraft inspection so that no delay will be incurred in notifying the operator.
3)    The PMI will notify the certificate holder of any findings through standard office procedures.
4)    The PMI will notify the certificate holder that the records review and inspection have been accomplished for a specific airplane. This will be accomplished via electronic, facsimile, or other accepted forms of notification.

NOTE:  Because records reviews and the structural spot inspections may be completed on different dates, therefore the date of notification to the operator of completion of the records and aircraft inspection will be used to determine the due date of the next required inspection.

5)    If DARs/ODAs accomplished the records reviews and aircraft inspections, they shall submit a report to the CHDO/CMO indicating the aircraft inspected. This report may be provided directly from the DAR/ODA or from the operator. The information provided must include the following:

    Identification number of the aircraft,

    Total years in service,

    Total flight hours of the airframe, and

    Date of last records review and inspection required by the aging airplane rules.

6-2495    FUTURE ACTIVITIES. ASIs assigned to parts 121, 129, and 135 certificate holders will accomplish structural spot inspections and aircraft records surveillance, as required by the Act.

RESERVED. Paragraphs 6-2496 through 6-2515.