8900.1 CHG 657



Section 7  Evaluate Part 125 Airplane Inspection Program and Maintenance


A.    Maintenance: 3341, 3342.

B.    Avionics: 5341, 5342.

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NOTE:  Aviation safety inspectors (ASI) must use Google Chrome to download the PTRS Work Activity Guide from the Federal Aviation Administration (FAA) Enhanced Flight Standards Automation System (eFSAS) at https://employees.faa.gov/org/linebusiness/avs/it/portal/efsas/media/ELECTRONIC-WORK-ACTIVITY-GUIDE-TABLES.pdf.

2-842    OBJECTIVE. This section provides guidance on how to evaluate and approve an operator/applicant‑submitted Airplane Inspection Program (AIP) and an engine maintenance program or revision.

2-843    GENERAL. This job task provides for interaction between the operator/applicant and the FAA from initial inquiry to approving the program/revision. It ensures that programs, systems, and intended methods of compliance are thoroughly reviewed, evaluated, and tested.

A.    FAA Approval. The FAA must approve an inspection program selected by an operator/applicant under Title 14 of the Code of Federal Regulations (14 CFR) part 125. Part 125, § 125.247(e) lists inspection programs that may be approved for use under this part. The FAA reviews the program to ensure that it meets regulatory requirements, is complete, and is appropriate for the intended operation.

B.    Airworthiness ASIs. ASIs should have as much knowledge of the operator/applicant’s operation as possible. This includes areas of operation, type of equipment, operating history, and maintenance/inspection organization(s).

NOTE:  An AIP is authorized for use in operations specifications (OpSpecs) and cannot be transferred.


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A.    Continuous Airworthiness Maintenance Program (CAMP). A part 125 operator may use a continuous inspection program that is a part of a current CAMP used under 14 CFR part 121 or 135. However, issuance of OpSpec D072 Continuous Airworthiness Maintenance Program (CAMP) authorization is not an option for part 125 certificate holders. Section 125.247(a)(3) requires the airplane, including airframe, aircraft engines, propellers, appliances, and survival and emergency equipment, and their component parts, be inspected in accordance with an inspection program approved by the Administrator. A CAMP may provide the basis for an OpSpec D073 “approved inspection program,” which will identify the approved inspection program document name and the specific airplane to which it applies. Caution: a CAMP is an all-encompassing program that includes ten primary elements. All of these elements are closely related and use of only the CAMP inspection program part may be ineffective as a stand-alone program. Lack of maintenance and loss of quality control that are integrated parts of a CAMP could have negative effects.

B.    Manufacturers’ Inspection Programs. The operator may use inspection programs currently recommended by the manufacturer of the airplane, aircraft engines, propellers, appliances, or survival and emergency equipment. The manufacturer’s inspection program might not cover survival equipment and avionics equipment. Additionally, the inspector should consider aircraft use before approving a manufacturer’s program. Many manufacturers offer a low-use program if the normal aircraft use falls below certain parameters.

C.    Program Developed by a Certificate Holder. The operator/applicant may use an inspection program developed by a certificate holder operating under part 125.

2-845    ENGINE MAINTENANCE. The operator/applicant must maintain engines in accordance with the overhaul intervals that the manufacturer recommends or a program that the administrator approves.

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NOTE:  Advisory Circular (AC) 125-1, Operations of Large Airplanes Subject to 14 CFR Part 125, defines proration as a procedure for determining the overhaul time expended under one maintenance system and to establish the time remaining to overhaul under a new program. Thus, proration permits further use of an affected item without need for immediate overhaul.

A.    Manufacturer-Recommended On-Condition/Trend Analysis Program. If the manufacturer does not have a recommended overhaul interval, the Administrator may approve a maintenance program that the manufacturer recommends as an on-condition/trend analysis program.

B.    Operator-Developed Program. The operator/applicant may develop an on-condition or overhaul program for approval by the Administrator.


A.    Operator-Initiated Changes. The operator may request approval to amend inspection or overhaul intervals.

1)    The operator must justify the request using past operating experience, environmental conditions, airplane use, and other data necessary to substantiate changes.
2)    Teardown reports, manufacturer recommendations, and the operator’s experience may justify engine maintenance programs and overhaul intervals.
3)    Operator-initiated time changes require revisions to both the AIP and OpSpecs.

NOTE:  Limitations specified for life-limited items and Airworthiness Directives (AD) shall not be amended or extended unless authorized in writing by the appropriate FAA Aircraft Certification Office (ACO).

B.    Manufacturer Escalations.

1)    If a manufacturer extends the recommended inspection or overhaul interval, the operator may request approval to use the extension by submitting a revision to the AIP. The manufacturer’s recommendation must accompany the request.
2)    ASIs should not automatically approve a time escalation the manufacturer recommends, but should consider the operator’s airplane use and experience to ensure that the escalation will not compromise safety. For example, the operator could consider sampling programs to justify time escalation requests.

2-847    POLICY AND PROCEDURES MANUAL (PPM). The operator’s PPM must include the AIP. The operator should submit a manual revision (in accordance with manual revision procedures) at the same time the AIP/revision is submitted for approval. This allows the FAA to approve the AIP/revision and accept the manual concurrently, thus expediting the implementation of the program.


A.    Prerequisites.

    Knowledge of the regulatory requirements of part 125,

    Previous experience with complex maintenance/inspection programs, and

    Successful completion of the airworthiness inspector indoctrination course(s), or equivalent.

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B.    Coordination. This task may require coordination with and/or assistance from Operations ASIs and/or the Air Carrier Maintenance Division.


A.    References (current editions):

    Title 14 CFR Parts 25, 39, 43, 45, 47, 65, and 91;

    Aircraft Maintenance Inspection Notes;

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    Aircraft Type Certificate Data Sheet (TCDS);

    AC 20-42, Hand Fire Extinguishers for Use in Aircraft;

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    AC 20-53, Protection of Aircraft Fuel Systems Against Vapor Ignition Caused by Lightning;

    AC 20-136, Aircraft Electrical and Electronic System Lightning Protection;

    AC 91-56, Continuing Structural Integrity Program for Airplanes; and

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    AC 125-1, Operations of Large Airplanes Subject to 14 CFR Part 125.

B.    Forms. None.

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C.    Job Aids. Job Task Analyses (JTA): 2.3.49, 3.3.201.

2-850    PROCEDURES.

A.    Schedule and Conduct Preliminary Meeting with Operator/Applicant, if Necessary.

1)    Advise the applicant of regulatory requirements and policies.
2)    For an existing operator, remind the operator that the PPM must include the AIP/revision.

B.    Plan and Coordinate Task.

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1)    Determine if the airplane meets eligibility requirements (§ 125.1).
2)    Review the operator/applicant file to identify any information concerning the AIP/revision and to determine its effect on other programs or procedures that the operator/applicant uses.
3)    If this task is performed as part of an original certification, review the Schedule of Events (SOE) to ensure that the task can be accomplished in accordance with the schedule.

NOTE:  When evaluating the program, ensure that all information is clear and easy to understand. It must identify the scope of each task and provide detailed, step-by-step procedures.

C.    Evaluate Proposed Program/Revision.

1)    Evaluate the instructions, procedures, and standards for conducting inspections.
a)    The inspection program must include:


    Aircraft engines,



    Survival and emergency equipment,

    Component parts for the above items, and

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    Alterations to the airplane and how to incorporate those into the inspection program.

b)    When establishing an inspection program for an aircraft to comply with § 125.247, the program should include installed avionics and instrument systems (appliances). These systems are not always installed by the aircraft manufacturers and may not be included in their recommended inspection programs.
c)    Inspection standards, procedures, methods, instructions, or other technical data may be included in the program by reference, eliminating the need to reprint them. Such references may be either the airframe manufacturer’s or the appliance manufacturer’s service data. However, when both the airframe manufacturer and the appliance manufacturer provide inspection data, that of the airframe manufacturer should be used. In this case, the inspector should ensure that the airframe manufacturer’s inspection data is applicable to the actual systems and equipment (make and model) installed on the aircraft.
d)    The avionics and instrument systems inspection should include a visual and functional check. Therefore, these definitions should be included in the program:

1.    Visual Check. A visual examination of an interior or exterior area, installation, or assembly to detect obvious damage, failure, or irregularity. This level of inspection is made from within touching distance unless otherwise specified. A mirror may be necessary to enhance visual access to all exposed surfaces in the inspection area. This level of inspection is made under normally available lighting conditions, such as daylight, hangar lighting, flashlight, or drop-light, and may require removal or opening of access panels or doors. Stands, ladders, or platforms may be required to gain proximity to the area being checked. Basic cleaning may be required to ensure appropriate visibility.

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2.    Operational Check. A task to determine that an item is fulfilling its intended purpose. This check does not require quantitative tolerances. This is a failure-finding task.

3.    Functional Check. A quantitative check to determine if one or more functions of an item performs within specified limits. This test may require the use of appropriate test equipment.

e)    The avionics and instrument systems inspections should be incorporated into the basic airframe program. The visual inspection of the avionics and instrument systems should be accomplished at an interval corresponding to the airframe inspection interval (e.g., inspect avionics and instrument equipment, wiring, connectors, bonding straps, circuit breakers, and switches forward of the instrument panel) at the same interval that flight controls and other structural inspections are performed in that area.
f)    Functional checks of the avionics and instrument systems, using appropriate ramp test equipment, should be performed at intervals as a function of the aircraft operating environment (i.e., 1 year of the manufacturer’s design specifications). The term “avionics” means aviation electronics and includes the following systems:





    Lights, and

    Autopilot/flight director system.

g)    The program should include maintenance/inspection requirements for protection of applicable electric/electronic systems from High Intensity Radio Frequency (HIRF) and lightning hazards. Such systems include, but are not limited to, power distribution and generating equipment and electromechanical devices, systems that use data buses for critical functions, electronic engine and flight controls, and associated interconnecting wiring or cables.
h)    All required tests and checks recommended by the aircraft or equipment manufacturer must be addressed.
2)    Identify the individuals responsible for performing the work.
3)    Ensure that the instructions, procedures, and standards are clear and easily understood. They must identify the scope of each task, provide a detailed outline of each step that must be accomplished to perform the inspection, and ensure that established standards are met.

D.    Evaluate Procedures for Controlling Life-Limited Parts. The program must contain provisions to ensure that records are current. Life limits must be expressed by one of the following measures:

    Length of time in service,

    Number of cycles,

    Number of landings,

    Calendar time, or

    A combination of the above measures.

E.    Evaluate Procedures for Scheduling Inspections. The program must list inspection intervals and describe personnel responsibilities for scheduling and performing inspections.

F.    Evaluate Procedures to Ensure Inspections Performed by Properly Certificated Personnel. Procedures must ensure that inspections are performed by properly certificated, qualified, trained, current, and authorized personnel. The program must identify, by title, the person responsible for ensuring that inspection personnel meet FAA requirements. The manual must list those persons whom the operator has arranged for inspection performance under part 125. The list must include the names and addresses of these persons.

G.    Evaluate Engine Maintenance/Overhaul Intervals. Ensure that engine overhaul periods correspond to the recommended overhaul intervals in the engine manufacturer’s manuals and/or Service Bulletins (SB).

H.    Evaluate Procedures for Reporting and Correcting Mechanical Irregularities. The program must include detailed instructions, procedures, and the necessary forms and documents for the recording and repair of mechanical irregularities. These instructions, procedures, and forms may appear elsewhere in the company manual, but their location(s) must be referenced in the maintenance manual and AIP.

1)    Within its manual, the operator/applicant should establish procedures to address continued operation of an aircraft with interim repairs and Structural Repair Manual (SRM) allowable damage. These procedures should also include provisions for a continuous feedback loop of timely information between the operator/applicant, the FAA’s Principal Maintenance Inspector (PMI), Principal Avionics Inspector (PAI), ACO, Designated Engineering Representative (DER), and the manufacturer.
2)    Manufacturers’ service documents (i.e., maintenance manuals, SBs, and Service Letters (SL)) communicate useful information on alterations, repair inspections, etc. Also, the manufacturer may provide service documents to the operator/applicant, upon request, that include statements that the data is “DER approvable” or that the manufacturer has “no technical objection” with the operator/applicant’s request. It is the air carrier’s responsibility to ensure that technical data is acceptable for minor repairs/alterations or approved for major repairs/alterations before implementing the information in these service documents. “No technical objection” and “DER approvable” letters, in most cases, are issued by the manufacturer’s technical representative and have no formal approval process within a manufacturer’s system. The FAA does not accept statements such as “DER approvable” or “no technical objection” without additional supporting data.
3)    It is recommended that PMIs and PAIs with certificate management responsibilities ensure that this information is brought to their operator/applicant’s attention. Any conflict should be resolved regarding what constitutes FAA-approved data and when that data is required, regardless of what a manufacturer’s service document may say.

I.    Evaluate Instructions for Using AIP. Make sure the AIP includes instructions on its use.

J.    Analyze Findings. Evaluate findings to determine if program changes are required. Coordinate with other specialties before debriefing the operator/applicant.

K.    Conduct Debriefings.

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1)    Before meeting with the operator/applicant, discuss initial findings with the appropriate FAA personnel to determine the content of the briefing. Depending on the findings, it may be necessary to coordinate with the certification team, principal ASIs, Air Carrier Maintenance Division, or other FAA personnel.
2)    Brief the operator/applicant on the results of evaluation. Discuss any deficiencies.


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A.    PTRS. Complete the PTRS record.

B.    AIP/Revision. Approve or reject the AIP/revision.

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1)    Approval. For approval if the program or revision meets all regulatory requirements, proceed as follows:
a)    Ensure that the AIP or revision has been fully coordinated between maintenance and avionics and any other appropriate personnel.
b)    Indicate “Approved” by the amended OpSpecs. See Volume 3, Chapter 2, Exemptions, Deviations, Waivers, and Authorizations.

NOTE:  The date the AIP and engine maintenance program are approved must be the same as the date the OpSpecs are approved.

c)    For a new or revised program, approval is granted by a “stamp of approval” and the PMI/PAI signature on the List of Effective Pages (LEP), or by some other official means of conveying approval.
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d)    Send the approved AIP/revision, the original AIP, and one copy of the OpSpecs to the operator/applicant, as appropriate. Request that the operator/applicant retain the original AIP and acknowledge receipt of the OpSpecs by signing and dating the copy and returning the copy to the Flight Standards District Office (FSDO).
e)    Update the FSDO file with copies of the acceptance letter, the signed and dated AIP/revision, and the receipted OpSpecs.
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2)    Rejection. For rejection if the AIP/revision is not acceptable, advise the operator/applicant by letter that the program is rejected. Return it to the operator/applicant along with the reasons for the rejection. Ensure that the letter accomplishes the following:

    Confirms all agreements made during the debriefing;

    Identifies the date the AIP/revision was submitted;

    Shows the revision number and date;

    Identifies and describes all deficiencies by chapter, section, page, etc.;

    Refers each deficiency to the appropriate regulation;

    Returns the original AIP; and

    Reminds the operator not to implement the revision until it is approved.

NOTE:  If this review is performed as part of a certification, inform the applicant in the letter that issuance of the certificate will be withheld until deficiencies are corrected. If necessary, advise the applicant to revise the SOE.


A.    SOE. In the case of original certification, review the SOE to determine if a revised schedule is necessary.

B.    PPM. Ensure that the PPM includes the approved AIP/revision.

RESERVED. Paragraphs 2-853 through 2-870.