FAA Defines Elements of Maintenance and Common Areas of Confusion Continued from page 75 its inspectors useful information about common myths in aviation maintenance and FAA oversight. It is appropriately titled, since it mostly lists the areas rather than clearing up or clarifying them. At least, the agency put these areas that give industry grief in one place. As they say in the TV show MythBusters, myth number one is the confusion over using Type Certificate Data Sheet (TCDS) notes as part of maintenance instruction. A topic that has been the target of several legal interpretations, TCDS notes define the design of the aircraft and how that design meets its certifica- tion basis, not how it is maintained. The FAA highlights the common occurrence of manufacturers putting information into a TCDS that defines maintenance requirements for their aircraft; however, such information is not regulatory and is outside the purpose of the TCDS notes. The FAA is addressing this practice by revising its certification orders and training its engineers to understand the differ- ence and not allow the notes to be used as maintenance instructions. Next on the list is a topic of great importance to so many in the MRO world: the difference between inspec- tion programs and maintenance programs. I have written about this before in these pages and the FAA has also published an Advisory Circular (AC) and additional inspec- tor handbook guidance on this. Most of the discussion in this new document comes from both of those recently published documents. The main difference is that inspection programs capture a list of scheduled inspections that are completed at designated intervals. 76 A maintenance program should encompass all the elements of maintenance, to include inspec- tions, overhaul requirements, repair schemes and Corrosion Prevention and Control Programs (CPCPs). From my experience, especially after my FAA time and now from helping aircraft owners with their inspection programs, the inspection program content has been the most challenging. Not so much the sched- uled inspection items themselves, but the “other” inspections that are part of maintenance, such as inspec- tions performed during an overhaul. Where I have seen FAA inspectors get tripped up is with Part 91 operations when there is no requirement for an overhaul, yet the overhaul manual calls for an inspection. The inspec- tor will then try to make the overhaul mandatory because of the inspec- tion requirement in the overhaul manual. The FAA states in the new document, in recently published ACs, and in other areas of the handbook itself that inspections performed during an overhaul are classified as a maintenance action and are not a part of an inspection program. The last common area of confu- sion addresses the difference between operating rules and what type of inspection program is required based on those rules. For the most part, these requirements are understood, whether you are a Part 121 air car- rier or a Part 135 operating with 9 seats or less or 10 or more passenger configurations. However, increas- ingly, when it comes to a manufac- turer’s program or the Part 91.409 (f)(4) owner-developed programs, there continue to be questions. According to the FAA, if an operator is going to comply with the manufacturer’s program it does not need to research every appli- ance and equipment manual for potential inspection items. Proper compliance with a manufacturer’s inspection program includes the programs from the airframe, engine, and propeller manufacturers. Finally, the FAA defines the dif- ference between approved inspection programs (AIP) under Part 91.409 (f)(4) and inspection programs approved under §135.419, referred to as an Approved Aircraft Inspection Program (AAIP). Again, there is plenty of existing guidance for both the FAA and industry on AAIP, and in the last year, the FAA produced spe- cific guidance to assist it and industry develop, review, and approve AIPs. I hope the new guidance reaches both industry and the FAA inspector workforce. While the new material is not included in the 8900.1 Order’s more popular volumes of certifica- tion and oversight, they are in the Foundational Information chapter of the General Technical Administration Volume. Wherever and however you find it, this is very good information for review on a long winter’s night as well as to keep in your back pocket. Congratulations to the FAA for once again making an effort to improve consistency at the inspector level. Carol E. Giles is President of The Giles Group, global aviation consultants. Previously, Giles led the FAA’s aviation maintenance division. Aviation Business Journal | 1st Quarter 2018
