8900.1 CHG 562



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Section 2  Inspect a Part 91 Inspection Program


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A.    Maintenance: 3681, 3425, 3426.

B.    Avionics: 5691, 5425, 5426.

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6-41    OBJECTIVE. This section discusses procedures to monitor aircraft and Aircraft Inspection Programs under Title 14 of the Code of Federal Regulations (14 CFR) part 91, § 91.409.

6-42    INSPECTION PROGRAMS. Several inspection programs are available to part 91 owner/operators.

A.    Small Airplanes, Turbine-Powered Single-Engine Airplanes, and Turbine-Powered Rotorcraft. With a few exceptions, these aircraft must be inspected using either an annual under § 91.409(a) or using a progressive inspection program under § 91.409(d). Only turbine-powered rotorcraft owner/operators can choose one of these options or an option under § 91.409(f).

1)    Annual and 100-Hour Inspections. The annual and 100-hour inspections are standardized, basic inspection programs, have no Federal Aviation Administration (FAA) approval requirements, and are identical in scope and detail. The difference is in the performance and approval of the annual inspection, which must be accomplished by a person authorized under 14 CFR part 43, §§ 43.3 and 43.7. The scope and detail of the annual and 100-hour inspections is defined in part 43 appendix D, and the contents of appendix D must be included in a checklist, which must be used while performing the inspections. While its use is required, the checklist is not a document that must be retained as a maintenance record. Additional rotorcraft systems to be inspected are contained in § 43.15(b), and if applicable, must also be included in the checklist.
a)    Annual Inspections. Except as detailed in § 91.409(c) and § 91.409(a)(2), § 91.409(a) indicates that persons may operate an aircraft only if, within the preceding 12 calendar-months, the aircraft has had an annual inspection.
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1.    Annual inspections provide a complete and comprehensive inspection of an aircraft. They are performed at least each 12 calendar-months by persons authorized under § 43.7. The inspection determines the condition of the aircraft and the maintenance required to return the aircraft to an Airworthy condition.

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2.    An aircraft inspected and approved on any day of a calendar month will become due for inspection on the last day of the same month, 12 calendar-months later. However, the owner/operator/program manager of an aircraft may have annual inspections performed at any interval that does not exceed the maximum of 12 calendar-months between inspections, as specified by § 91.409(a)(1).

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3.    Section 43.15 and part 43 appendix D indicate that all systems, components, and appliances must be checked to ensure proper installation and satisfactory operation.

a.    Before conducting surveillance of annual inspections performed by maintenance personnel, inspectors should become familiar with the manufacturer’s recommended inspection procedures, special instructions, etc., in as much as possible.

b.    Inspectors should know the acceptable degree of deterioration or defect permitted by the manufacturer, as detailed in the manufacturer’s manuals or other data.

4.    In all cases, persons authorized to perform inspections under §§ 43.3 and 43.7 must determine from records and physical inspection that the aircraft conforms to the contents of:


    Properly altered condition (refer to FAA Form 337); or

    STCs, if applicable, and Airworthiness Directives (AD).

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5.    The above documents must be available to maintenance personnel conducting an inspection. Applicability of an STC may be determined by reference to the aircraft maintenance records.

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6.    Ensure the required recording procedures of § 43.11 and § 91.417 are met.

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a.    Under the provisions of § 43.11, the agency or person approving or disapproving the aircraft for return to service is responsible for recording the inspection in the maintenance records. The owner/operator must ensure that the maintenance records contain proper entries according to § 43.11 and § 91.417.

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b.    If the person conducting the inspection finds the aircraft to be unairworthy, appropriate entries must be made in the aircraft maintenance records. The owner/operator/program manager must be provided a list of discrepancies or unairworthy items. The owner/operator/program manager must have any discrepancies repaired, as described in part 43, before the aircraft is returned to service.

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7.    When conducting surveillance, airworthiness inspectors will review aircraft maintenance records to determine if the requirements of an annual inspection have been accomplished.

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b)    The 100-Hour Inspection. The 100-hour limitation may be exceeded by not more than 10 hours while enroute to reach a place where the inspection can be done. The excess time used to reach a place where the inspection can be done must be included in computing the next 100 hours of time in service. The 100‑hour inspection is required, in addition to the annual inspection, under the following situations:

    Aircraft are operated for carrying persons for compensation or hire, and

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    Aircraft are used for flight instruction for hire, and the aircraft is provided by the flight instructor.

NOTE:  When a flight instructor is not included in the rental agreement, a 100-hour inspection is not required on an aircraft when it is rented out.

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c)    Surveillance Considerations. When performing surveillance of aircraft after having received an annual or 100-hour inspection, the following steps should be followed:

1.    Verify that the maintenance personnel/facility has the necessary technical data to include a manufacturer’s maintenance manual, aircraft specifications or Type Certificate Data Sheets (TCDS), and aircraft maintenance records that include FAA Form 337, Major Repair and Alteration (Airframe, Powerplant, Propeller, or Appliance) for major alterations or repairs and any associated Supplemental Type Certificates (STCs) for major alterations/modifications. See paragraph 6-43 for greater detail of surveillance criteria.

2.    After confirming the aircraft’s airworthiness and registration certificates are current and accurate the aviation safety inspector (ASI) should conduct a general visual inspection of the aircraft. This inspection should be performed on the inside and outside of the aircraft but does not require removal of any inspection panels or equipment.

3.    Examine the aircraft maintenance records to ensure the required recording procedures of 14 CFR part 43, § 43.11 and § 91.417 are met. The maintenance logbook entries for the annual or 100-hour inspection must include the aircraft total time in service, date, and description of the inspection and any associated maintenance are documented. If any ADs are performed, the AD number and method of compliance is to be documented. If it is a repetitive AD, the date or time when it is due again should also be noted. Finally, the record must include the signature of the person approving the aircraft for return to service and their certificate type and number.

2)    Progressive Inspections. The progressive inspection is a complete inspection of the aircraft, conducted in stages, with all stages to be completed in a period of 12 calendar-months.
a)    Must Be Requested. An owner/operator using a progressive inspection program must submit a written request to the responsible Flight Standards office having jurisdiction within the applicant’s location. In response to the owner/operator’s request, the FAA will review the submitted program and either concur with the request, or issue a letter of denial. There is no requirement for the FAA to approve a progressive inspection.
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1.    Since progressive inspection programs developed by the manufacturer may not automatically fit the needs of individual owner/operator, an owner/operator may have tailored its progressive inspection program to fit its operation.

2.    The owner/operator’s progressive inspection program may be more restrictive than the manufacturer’s program, but it may not be less restrictive unless sufficient justification is presented to and accepted by the FAA.

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b)    Starting a Progressive Inspection. Progressive inspections must start out with a complete aircraft inspection, either an annual or 100-hour inspection. Inspections after this initial inspection follow the schedule defined in the program. The owner/operator must provide an Inspection Procedures Manual (IPM) that explains the progressive inspections with the inspection schedule and examples of the forms and records with instruction for their use. They must also provide, with the written request, the name of a mechanic with Inspection Authorization (IA), a certificated and appropriately rated repair station, or the aircraft manufacturer who will conduct or supervise the inspections.
c)    Inspection Intervals. Intervals for the inspection of aircraft are based on the manufacturer’s recommendations, field service experience, malfunction and defect history, and the type of operation in which the aircraft is engaged.
d)    Discontinuance. If the progressive inspection is discontinued, the owner or operator must notify the FAA responsible Flight Standards office in writing immediately. After the discontinuance, the first annual inspection is due within 12 calendar-months after the complete inspection has been accomplished according to the progressive inspection program.
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B.    Large Airplanes, Turbine Powered Multi-Engine Airplanes, and (Optionally) Turbine‑Powered Rotorcraft. In addition to compliance with the replacement times of life-limited parts as specified in § 91.409(e), these airplanes and turbine-powered rotorcraft must be inspected according to the requirements of an inspection program selected by the owner/operator/program manager under § 91.409(f)(1)‑(f)(4), hereafter called the F1, F2, F3, or F4 programs respectively. The options specified for F1, F2, and F3 programs refer to existing inspection programs from a 14 CFR part 121 or 135 operator, or manufacturer-recommended programs. These programs do not require that the field inspector issue a specific approval, as they refer to manufacturer-developed programs or programs already separately approved. However, the ASI should recognize that at the time the selection was made, these programs must be either currently in use by a part 121 or 135 operator providing its program to the operator, or the program was the one most recently published and recommended by the manufacturer, which includes any temporary revisions to the program. The following sections outline the options available to the operators of applicable aircraft:

NOTE:  An exception is provided in § 91.409(e) that allows turbine-powered rotorcraft operators to use the inspection provisions of § 91.409(a), (b), or (d) in lieu of an inspection option under § 91.409(f).

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1)    A Continuous Airworthiness Inspection Program – F1. Owner/operators can choose an inspection program that is part of a Continuous Airworthiness Maintenance Program (CAMP) currently in use by a person holding an air carrier Operating Certificate or an Operating Certificate issued under part 121 or 135. This is most common with air carriers that own aircraft that are not being operated under their certificate, such as for corporate use or for newly purchased aircraft before being added to the carrier’s certificate. But a non-certificate holding owner/operator could also select and use one of these programs, but it must have access to the most recent information about the current program being used by the air carrier. Also, the program would have to be directly applicable to the aircraft; same make/model and similarly configured. Note that this is just the portion of the CAMP that encompasses the inspection program and not the entire CAMP. Inspection programs do not encompass overhaul limits, Corrosion Prevention and Control Programs (CPCP), repair processes, or scheduled replacement of parts, which are items of maintenance and outside the scope of an inspection program.

NOTE:  The rule does not provide for the use of a CAMP that may have been approved for other types of operators such as those under 14 CFR part 125 or part 91 subpart K (part 91K).

2)    Approved Aircraft Inspection Programs (AAIP) – F2. This is nearly identical to an F1 program except that the program in question is an AAIP from a part 135 nine seats or less operation instead of a CAMP program. All the same qualifiers applicable to an F1 are applicable here too (same make/model, similar configuration, access to the program, etc.). However, since this should just be an “inspection” program, it should be much easier to determine applicability, assuming that the original program was developed correctly. However, like an F1 program, the owner/operator cannot change or modify the program, and must comply with the entire program as written. If the program doesn’t exactly fit the aircraft or type of operation, another option would have to be chosen, such as an F3 or F4 program.
3)    Manufacturer’s Recommended Inspection Programs – F3. These programs may be published in the Aircraft Maintenance Manual (AMM) or offered by the manufacturer separately. Typically, they provide the owner/operator with a degree of scheduling flexibility and a minimum of downtime.
a)    Inspectors should be aware that what the airframe manufacturer provides may not be all inclusive. They may not cover items such as aftermarket avionics installations, emergency equipment, or other equipment installed by a person other than the manufacturer. However, modifying the aircraft, such as through an STC or FAA Form 337 does not make selection of an F3 program inappropriate. In such cases, the owner/operator must be careful to comply with all inspections required by manufacturers of all aftermarket equipment and/or modifications. This is where commercially available tracking programs can make tracking the various required inspections easier, but their use is not required.
b)    The use of WINDOWS—allotted periods of time—within the inspection programs accepted under § 91.409(f)(3) is allowed only if contained as part of the manufacturer’s recommended program (see Volume 6, Chapter 2, Section 28).
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c)    Figuring out a manufacturer’s inspection program can be difficult at times because manufacturers often mix items of an inspection program and maintenance program together. Remember that inspection programs are one part of a maintenance program and will likely be included in the same chapter with other maintenance requirements (frequently found in chapter 5 of the AMM.

1.    Again, it is good to have a sound understanding of the difference between an inspection requirement and a maintenance requirement.

2.    For example, because we are talking about inspection requirements, it would not include items of scheduled maintenance such as overhaul limits, CPCPs, repair processes, scheduled replacement of parts or other maintenance actions called out in Service Bulletins (SB), Service Letters (SL), or service instructions. Those items are outside the scope of an inspection program.

d)    As discussed in an FAA legal interpretation, changes made to the manufacturer’s recommended inspection program after an owner/operator has already selected and identified that program in the maintenance records are not mandatory in a regulatory sense. Owner/operators are required to comply with the inspection program the way it was at the time the selection was made. If owner/operators were required to comply with every change made by the manufacturer, it would essentially enable the manufacturer to impose regulatory‑like requirements without the review and comment process required by the Administrative Procedures Act (APA). However, if the owner/operator changes to a different inspection program and then wants to switch back to an F3 program, they would be required to comply with the most current version of the inspection program as published at that time.

1.    The same is true for any new aircraft the owner/operator obtains; F3 programs are aircraft specific, and not owner/operator specific. This means the owner/operator must comply with the most current version of the manufacturer inspection program at the time it is selected for each individual aircraft. Of course, owner/operators can voluntarily comply with the changed requirements, and the FAA encourages owner/operators to keep their programs current in the interest of safety.

2.    It may also be easier for owner/operators of multiple like-model aircraft to simply comply with the latest version of a manufacturer’s inspection program, rather than have multiple aircraft on different revision levels. The owner/operator also cannot pick-and-choose parts of an inspection program to comply with, such as keeping some older elements while adopting parts of the latest inspection program; it is an all-or-nothing selection. However, this can be a gray area as owner/operators can always elect to perform more inspections that their selected program requires. Basically ensure that owner/operators are at least meeting the requirements of their selected program, or are being more restrictive.

NOTE:  Not all manufacturers provide, or recommend, specific detailed inspection programs for their aircraft. This is especially true for some older and ex-military aircraft. In these cases, selection of an F3 program would not be appropriate.

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4)    Approved Inspection Program – F4. These programs are completely custom programs designed specifically for an aircraft. These programs are typically a customized version of one of the above programs, most often the F3. This program is used when one of the above programs is not directly applicable to the aircraft in question, or the owner/operator desires more flexibility due to the type of operation (low utilization, unique environments, etc.). This type of program can also be used if the manufacturer didn’t provide an adequate F3 program. For more information on what this type of program should contain, refer to AC 91-90, Part 91 Approved Inspection Programs, and guidance on the review and approval of these programs can be found in Volume 4, Chapter 14, Section 3.

NOTE:  We generally refer to an inspection program approved under part 135 as an Approved Aircraft Inspection Program, or AAIP, and an F4 inspection program more generically as just an Approved Inspection Program, or AIP. They are all forms of “Approved Inspection Programs,” but the term AAIP has long been associated with part 135. So the term “AAIP” should be used when referring to an inspection program approved under part 135 and the term “AIP” should be used when referring to a program approved under any other part to reduce confusion.

C.    Special Considerations for Experimental Aircraft. Experimental aircraft are generally exempt from the requirements of annual/100-hour inspections; however, their operating limitations will prescribe some minimum level of inspection they must perform. Additionally, large and multiengine turbine-powered experimental aircraft are not exempt from the inspection requirements in § 91.409(e). Those aircraft should follow the same procedures for developing and identifying an inspection program as described above. In addition, the following items should also be considered.

1)    F4 Programs. For experimental aircraft, the program may be based off a current manufacturer’s recommended program, a current military program (preferably the Technical Order, North Atlantic Treaty Organization (NATO) recognized version, or developed by the service organization), or based on a program previously approved for the same make/model. However, prior FAA approval of an inspection program does not guarantee an automatic approval for a similar make/model because inspection programs are aircraft specific. If no current program exists on which to base the program, review the owner/operator’s proposal for adequacy. If possible, consult with other FAA offices that might have experience on the specific make/model, and/or contact the Aircraft Evaluation Group (AEG) for any assistance they can provide. The decision is ultimately up to the professional discretion of the FAA inspector approving the program.
2)    Operable Ejection Seats. For experimental aircraft with operable ejection seats or other military‑related systems, the inspection program must contain inspection tasks recommended by the current manufacturer or military program. However, inspection tasks for aircraft systems that have been removed or deactivated may be excluded.
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3)    Manufacturer/Military Manuals. If the manuals were not originally published in English, the owner/operator should submit an English translation of the original manuals. It is to the owner/operator’s benefit to ensure the translation is performed by a technically competent individual familiar with aviation terms and practices.


A.    References (current editions):

    Title 14 CFR Parts 39, 43, and 91.

    AC 39-7, Airworthiness Directives.

    AC 43-9, Maintenance Records.

    AC 91-90, Part 91 Approved Inspection Programs.

    AC 120-78, Electronic Signatures, Electronic Recordkeeping, and Electronic Manuals.

    Volume 6, Chapter 1, Section 3, Inspect Part 91 Maintenance Records.

    Volume 6, Chapter 1, Section 7, Evaluating and Inspecting Part 91 Aircraft.

B.    Forms. None.

C.    Job Aids. None.


A.    Review and Accept a Progressive Inspection Program.

1)    Advise the owner/operator desiring a progressive inspection program to submit a written request and a copy of the program, as required by § 91.409. A progressive inspection is authorized on a case-by-case basis per aircraft, not by the operator, so each aircraft needs to be specifically authorized. If the owner is creating a progressive program, the program can list multiple aircraft as long as each aircraft is clearly identified in the program. Also, ensure that there are enough similarities between the aircraft so that one program will work. There can be small variances between the aircraft (such as installed equipment, modifications, SBs, etc.), but if the differences cause a change in the inspections required, ensure those differences are clearly identified, such as effectivity identified for a given task (e.g., “N12345 Only”).
2)    Upon receipt of the request and the program, ensure:
a)    The program includes the entire aircraft and its components.
b)    The program will provide a complete inspection of the aircraft within 12 calendar-months. The owner/operator should base inspection intervals on the manufacturer’s recommendations, field service experience, service difficulty history, and the type of operation in which the aircraft is engaged.
c)    The scope of the inspection is at least equal to that of an annual inspection.
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d)    The inspection schedule ensures that the aircraft will be Airworthy at all times and will conform to all applicable life limits, ADs, and other approved data.
e)    The program includes procedures for immediate written notification of the responsible Flight Standards office upon the discontinuance of the progressive program and the assumption of an annual inspection program.
3)    Notify the operator of any deficiencies found in the program and request that the operator inform the FAA of plans for resolving deficient items. Once the operator has corrected the deficiencies, notify the operator the FAA has accepted the program and authorized its use on the specific aircraft in question. Acceptance can also be indicated by applying the signature of the FAA inspector in the inspection program, such as on the list of effective pages, if desired.
4)    Establish and maintain an operator file according to agency orders.

B.    Periodic Review of Maintenance Records and Other Applicable Records. If the aircraft records are available, review them in accordance with Volume 6, Chapter 1, Section 3. This should include life-limited items.

1)    Ensure that persons approving and disapproving equipment for return to service after any required inspection have recorded the inspection in the record of that equipment. If the owner/operator maintains separate records for the airframe, engines, powerplants, propellers, appliances, and components, ensure the entry for required inspections is made in each record.
2)    Title 14 CFR part 43 contains maintenance recording requirements, and includes requirements for persons approving or disapproving equipment for return to service after any required inspection.
3)    The maintenance record entry required by § 43.11(a) should provide enough detail to ensure all requirements of the program have been met. The entry should identify the inspection program by name or document and include revision information. For example: “I certify that this aircraft has been inspected in accordance with a [insp type] [insp name] Inspection per [OEM manual or other instruction reference] [revision #] and was determined to be in Airworthy condition [date accomplished]. Aircraft total time in service: [enter hours] [signature] [certificate number] [certification held]”.
4)    Specific inspection program requirements.
a)    For an annual and 100-hour inspection:

    Review maintenance record entries to ensure compliance with all applicable requirements of § 43.11 and § 91.417.

    Determine that the entries made meet the regulatory requirements.

    If possible, verify that a checklist was (or is being) used while performing the inspection, and if the checklist contains all required inspection items as specified in § 43.15(c).

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b)    For a progressive inspection, ensure that records indicate all of the following:

    The aircraft has had a complete inspection prior to the start of a progressive inspection program.

    Compliance with the inspection intervals prescribed in the progressive program.

    Completion of the inspection cycle within 12 calendar-months.

    Appropriate use of forms and instructions as explained in the inspection manual.

5)    For aircraft on F1, F2, F3 or F4 programs, ensure the maintenance records indicate that the owner/operator has selected and identified a program according to § 91.409(f). Check that the inspection program instructions and procedures have been followed specific to the type of inspection program.
a)    For a part 91 operator’s use of a CAMP inspection program from part 121 or part 135, § 135.411(a)(2) operator (F1), ensure that the inspection program is currently in use by the part 121 or 135 operator and that the make and model is applicable. Although the part 91 operator does not have to be affiliated with the part 121 or 135 operator, they almost always are, because the part 91 operator must have some legitimate way to gain access to the inspection program.
b)    For a part 91 operator’s use of a part 135 operator’s AAIP, approved under § 135.419 (F2), ensure the AAIP is currently in use by the part 135 operator. As with the option above, the operator does not need to be affiliated with the part 135 operator, but they usually are in some way due to the information sharing needed for this type of program to be feasible.
c)    For a part 91 operator’s use of the inspection program recommended by the manufacturer (F3), ensure all items required to be inspected have been inspected per the manufacturer’s recommendations. This includes temporary revisions issued by the Original Equipment Manufacturer (OEM).
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d)    For a part 91 operator’s use of an approved inspection program under § 91.409(f)(4) (F4), ensure the program is approved and that the specific procedures and intervals defined in the program are being followed. If there are safety concerns with the program, refer to § 91.415 for additional information.

C.    Conduct Surveillance of the Aircraft. Examine the aircraft to determine to the extent possible that it is in condition for safe operation. The ASI must ensure surveillance is accomplished either in the presence of, or with specific approval from, the owner/operator.

1)    Airworthiness Certificate. Inspect the airworthiness certificate. Ensure that it is current, correct, and in the aircraft.
2)    Registration Certificate. Inspect the registration certificate. Ensure that it is current and correct. If it is a temporary certificate, ensure that it has not expired.
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3)    Inspect the Aircraft. Inspect the aircraft to ensure:

    The general condition of the aircraft is Airworthy.

    The Aircraft Flight Manual (AFM), or pilot’s operating handbook (POH), is complete and current.

    The aircraft complies with applicable maintenance, operating, and equipment rules.

    The aircraft complies with applicable ADs.

    The aircraft records indicate compliance with life-limited parts requirements.

    Properly certificated persons have been performing maintenance and inspections, and maintenance recording entries comply with requirements.

4)    Additional Items to Check. Although by no means a complete list, the following are examples of items to be checked:

    Proper internal and external placarding.

    Obvious signs of excessive wear and deterioration, including corrosion, worn places on tires, nicks in the leading edge of propeller blades, broken windshields, etc.

    Condition of fabric on fabric-covered control surfaces, wings, or fuselages.

    The interior of the aircraft for obvious deterioration.

    Tires and brakes for serviceability.

    Any other indication that would render the aircraft unsafe for flight.


A.    Complete the PTRS Record.

B.    Complete the Task. Successful completion of the task will result in assurance that the aircraft is Airworthy and is maintained and inspected per applicable regulations.

6-46    FUTURE ACTIVITIES. Carefully monitor inspection systems for compliance with appropriate 14 CFR parts and for continued airworthiness of subject aircraft. Revisions and amendments to approved programs are to be reviewed only for new or revised material provided. The FAA person performing the approval for the revision is only responsible for reviewing the changed or revised material. It is not required or expected that the entire program be reviewed for approval again, nor should it be required for an operator to rejustify any existing approved intervals or processes. If there are safety concerns about the currently approved program, those issues should be addressed separately per § 91.415 and not as part of the revision process.

RESERVED. Paragraphs 6-47 through 6-63.