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COMPLIANCE MATTERS For example, Pratt and Whitney TCDS E4EA, Revision


26, dated Dec. 21, 2012, includes the following: Note 14: Certain engine parts are life limited. These limits


are listed in P&WC Engine Service Bulletin Nos. 1002, 1302, 1402, 1602, 3002, 4002, 12002, 12102, 13002, and 13202 as revised. PT6A-140 refer to AWL section of the maintenance manual P/N 3075742. Another example is Honeywell TCDS E6WE, Revision


17, dated May 9, 2000, which states the following: Note 9: Certain engine parts are life-limited. These limits


are listed in the FAA approved Honeywell International Inc. Service Bulletins TFE731-72-3001 and TFE731-72-3501. These notes contained in the TCDS makes compliance with those bulletins mandatory due to the regulation that calls for them to be complied with. Take the time to look through the TCDS that are applicable to your aircraft and its attached Class I components (engines and props) and you might fi nd that there is a service bulletin that calls out the life-limited parts that must be replaced as defi ned in order to maintain the aircraft’s airworthiness.


FAA AIRWORTHINESS DIRECTIVE REFERENCE Another means by which a service bulletin can be mandatory is much more common to everyone. It is through an airworthiness directive, which the FAA (and other governing agencies worldwide) issue for the purpose of mandating specifi c actions be taken in order to ensure safe operation of aircraft. In most cases, those actions are the result of a previously-issued manufacturer’s service bulletin. The manufacturer issues the bulletin (usually with some level of urgency) and then submits it to the FAA for review. The FAA will then decide whether or not the need or condition addressed by the service bulletin warrants an airworthiness directive (AD). If it does, the FAA will then issue an AD and in the language of the AD specifi cally refer to the service bulletin and its contents for detailed actions to be taken. There are certainly problems with this process. The author of the AD will often call for a specifi c revision of a service bulletin to be accomplished. Then when the manufacturer revises the service bulletin, the FAA doesn’t revise the AD and the AD calls for compliance with an outdated service bulletin. We have run into this issue many times.


THE CURRENT INSPECTION PROGRAM RECOMMENDED BY THE MANUFACTURER


The third and most elusive way in which a manufacturer’s service bulletin can be mandatory (as defi ned within this article), is a “gotcha.” You see, 14 CFR Part 91.409 goes on to say in paragraph (f): (the key points in bold italics) 14 CFR Part 91.409 Inspections (f) Selection of inspection program under paragraph (e) of this section. The registered owner or operator of each airplane or turbine-powered rotorcraft described in paragraph (e) of this section must select, identify in the aircraft maintenance records, and use one of the following


11.12 2013


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programs for the inspection of the aircraft: (1) A continuous airworthiness inspection program that is part of a continuous airworthiness maintenance program currently in use by a person holding an air carrier operating certifi cate or an operating certifi cate issued under Part 121 or 135 of this chapter and operating that make and model aircraft under Part 121 of this chapter or operating that make and model under Part 135 of this chapter and maintaining it under §135.411(a)(2) of this chapter.


(2) An approved aircraft inspection program approved under §135.419 of this chapter and currently in use by a person holding an operating certifi cate issued under Part 135 of this chapter.


(3) A current inspection program recommended by the manufacturer.


(4) Any other inspection program established by the registered owner or operator of that airplane or turbine-powered rotorcraft and approved by the Administrator under paragraph (g) of this section. However, the Administrator may require revision of this inspection program in accordance with the provisions of §91.415.


The most common inspection program in use in


corporate aviation is the (f)(3) option, the current inspection program recommended by the manufacturer. Prior to 2005, it was interpreted and expressed through FAA internal guidance documents that the inspection program recommended by the manufacturer did not include service bulletins or service information until such time as that information was incorporated into the details of the inspection program itself. It was during a revision to the then FAA Order 8300.10 (later changed to 8900.1) that a change was made. The FAA now interprets this to mean that whenever a service bulletin is issued by the manufacturer that includes inspection, that service bulletin is incorporated into the manufacturer’s recommended inspection program and, if the operator has selected the current inspection program recommended by the manufacturer, the operator must accomplish it as written. Below is an excerpt from FAA order 8900.1. The wording seems backhanded because it implies that all service bulletins were at one time interpreted to be required. However, that is not the case. Before this language was introduced somewhere around 2005 or 2006, service bulletins were clearly excluded. The previous language was as follows: NOTE: Because this program addresses inspections only, it does not include Service Bulletins (SB), Service Letters (SL), service instructions and other maintenance documents. Below is the current FAA interpretation and enforcement guidance relative to service bulletins and inspections. I have included more than just the service bulletin reference for context. It can be found in its entirety at the following web location:


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