COMPLIANCE MATTERS
http://fsims.faa.gov 8900.1 CHG 239, dated 1/2/13 VOLUME 6 SURVEILLANCE CHAPTER 1 PART 91 INSPECTIONS Section 2 Monitor Part 91 and Approve/Monitor
a Part 91 Subpart K Program Manager’s Aircraft Inspection Program
C. Large Airplane (Over 12,500 Pounds (lbs)) and
Turbine-Powered (Turbojet and Turbopropeller) Multi-engine Airplane Inspection Programs. These aircraft must be inspected according to the requirements of an inspection program selected by the owner/operator/ program manager. Section 91.409(f) ... 2) Reference to a manufacturer-recommended program has led to several misconceptions about what precisely constitutes such a program.
a) Section 91.409(3) refers to “A current inspection program recommended by the manufacturer.” No reference is made to the aircraft manufacturer specifi cally; § 91.409, however, requires inspection of the airframe, engines, propellers, appliances, survival equipment, and emergency equipment.
b) Therefore, a complete manufacturer’s recommended program consists of the program supplied by the airframe manufacturer and supplemented by the inspection programs provided by the manufacturers of the engines, propellers, appliances, survival equipment, and emergency equipment installed on the aircraft.
NOTE: Because this program addresses inspections only, it does not include Service Bulletins (SB), Service Letters (SL), service instructions, and other maintenance documents, unless they require an inspection to be performed. In summary, there are only a few ways that a service
bulletin can be required in order to maintain a valid FAA airworthiness certifi cate — or mandatory. • As a means of calling out life-limited parts through reference in the TCDS
• By reference as an AD • Or when the service bulletin requires an inspection to be performed. (I don’t like this one, but that is the FAA’s position)
For certifi cated air carriers, service bulletins can also
be required through the operations specifi cations for the certifi cate, but for the purposes of a Part 91 operator, this sums it up.
All that being said, the safety of the aircraft is the fi rst and most important priority. It is my personal recommendation that whenever the manufacturer issues a service bulletin that is applicable to your aircraft, that you comply with it and incorporate those changes as soon as possible. Nobody knows the aircraft better than the manufacturer. These days, the FAA is not the only consideration for compliance. Some insurance policies and purchase agreements are getting much smarter and including language around service bulletins as well rather than just the blanket “airworthy” statement.
I hope this has been helpful. It can be a controversial topic, but that is only because of the many ways that service bulletins are used. Until next time ...
Joe Hertzler has more than 25 years of experience in business aviation. He has earned a reputation as an effi ciency expert when it comes to aircraft maintenance and is
well known for his in-depth understanding of maintenance regulations and how they aff ect aircraft compliance. He has helped many in dealing with critical and urgent FAA interactions and often speaks on the topic of aircraft maintenance and compliance at industry events, such as the NBAA Maintenance Managers Conference, PAMA meetings and IA renewal seminars. Hertzler also serves on the National Air Transportation Association’s (NATA) Maintenance and Systems Technology committee. Contact him at
JoeHertzler@gmail.com.
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11.12 2013
22 Authorized Service Centers: USA, United Kingdom, France, Germany, Italy, Oman & Thailand
DOMmagazine
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