Maintenance Program Requirements

            Ten elements of a maintenance program were mentioned during the discussion of the CASS, the other elements will now be discussed in part. One of the remaining elements is the air carrier’s airworthiness responsibility. The airworthiness responsibility simply outlines that the requirements to meet all ten elements of a maintenance program are the direct responsibility of the certificate holder and/or owner of the aircraft. Depending on how the aircraft is certificated will determine the specific Part, 121 or 135, that will direct the specific maintenance functions required for continued airworthiness for that aircraft. Regardless of operation under Part 121 or 135, Part 43 must also be followed for the maintenance, preventative maintenance, rebuilding, and alterations of aircraft along with their specifics outlines in either Part 121 or 135.

            The air carrier maintenance program has three overall objectives. The first objectives is to ensure that all aircraft released for service do in fact meet airworthiness requirements. Objective number two requires that all maintenance done on an aircraft are done in accordance with the maintenance manuals. The final objective is that the air carrier provide competent personnel and appropriate facilities and equipment to perform the maintenance correctly (FAA, 2012). To achieve these objectives on the maintenance side is where the other eight elements required for a maintenance program come in. The eight elements are the air carrier maintenance manual, air carrier maintenance organization, accomplishment and approval of maintenance and alterations, maintenance schedule, required inspection items, maintenance recordkeeping system, maintenance providers, and personnel training. Each will briefly be discussed below.

Ø  Air Carrier Maintenance Manual

o   Must be easily revisable and readily available to personnel for use

o   Needs to be standardized and usable by third parties in the event of contracted use

o   Contains OEM data, but written by the air carrier – cannot use OEM publications

Ø  Air Carrier Maintenance Organization

o   Part 121 and Part 135 require a Director of Maintenance and a Chief Inspector (or equivalent position)

o   Structure is required but is necessarily broad for the wide range of air carrier sizes

§  Recommends accountable manager – monitors and manages both maintenance and inspections functions

§  Clear authority, to include delegated responsibility, needs to be clear

o   Maintenance and Inspection need to be separated

Ø  Accomplishment and Approval of Maintenance and Alterations

o   Must meet the requirements of respective Parts

o   Major Repairs and Alterations must be done in accordance with FAA

o   Post maintenance actions require aircraft logbook entries and approval for RTS

o   Maintenance can be scheduled and unscheduled

Ø  Maintenance Schedule

o   Objective is to do the correct task at the correct interval

o   Schedule should contain the following:

§  What the task is – examples include service bulletins, special inspections, lubrication or servicing

§  How – how will the task be performed, does it require special tooling, specific facilities, special personnel

§  When – what is the time table for the inspection. This includes when to perform the task (time window), how long the task should take, and when to expect it to RTS

Ø  Required Inspection Items (RII)

o   Certain tasks are required to be considered RIIs. The expectation is to maintain a list of what is an RII.

o   Is a large part of maintenance schedule and maintenance manuals

§  Manual must include a list of persons for any required inspections

§  RII requirements must be clearly identified

§  Standards and limitations must be set

§  Manual must contain all procedures for the RII

Ø  Maintenance Recordkeeping System

o   The purpose of records is proof of work done to keep an aircraft airworthy

o   Part 43 contains the basic guidelines to be used for all recordkeeping

o   Must have copies of all records

o   Some records require reporting to the FAA, such as major maintenance and alterations, even when done in accordance with the OEM data

Ø  Maintenance Providers

o   Although done by a third party (leasing agent, outsourced, contracted), the final responsibility relies on the air carrier to ensure compliance with all requirements

§  This includes recordkeeping

Ø  Personnel Training

o   The certificate holder is responsible for ensuring the proper training of all maintainers that are to be used for the aircraft operating under them. Some of the training required are:

§  Initial training

§  Recurring training

§  Specialized training

§  Maintenance provider training

§  Competency-based training

Federal Aviation Administration. (November 15, 2012). Air carrier maintenance programs. Advisory Circular (120-16F).