It is not unusual to find a number of abnormal configurations or situations during embodiment or “attempted embodiment” of a modification, SB or repair action.
The following are considerations regarding resolution, these are the authors recommendations and ultimately it is necessary to validate any process or procedure with the Competent Authority.
a) The aircraft is at a different modification standard than the SB indicated applicability
b) Other work or activity has been previously employed which impacts the performance of the maintenance.
c) The work has been previously carried out – however we are issued with another set of accomplishment instructions
In the case of a) It happens from time to time that the manufacture’s understanding regarding configuration status is at variance to the actual aircraft
In this case it is necessary to understand the current situation
Typically this will involve engineering action to determine
i/ What has occurred
ii/ What actions should be taken to ensure conformity and to deliver the required outcome
iii/ This may require an input from the manufacturer and should be managed by the CAMO / Engineering – Planning Group
iv/ It may be necessary to seek an alleviation and in this case CAMO Quality Assurance may be involved to discuss negotiate with the regulatory authority.
As the circumstance which led to the issue typically sit with the manufacturer rather than the operator, there is little further action to take. It is typically such circumstances apply to more than a single aircraft.
In the case of b) additional or other works as been performed in the vicinity of the proposed Modification or Repair
Typically this will involve engineering action to determine
i/ Exactly the nature of the current situation and what are the impediments to accomplishment
ii/ What actions should be taken to ensure conformity and to deliver the required outcome
iii/ This may require an input from the manufacturer and should be managed by the CAMO / Engineering – Planning Group
iv/ It may be necessary to seek an alleviation and in this case CAMO Quality Assurance may be involved to discuss negotiate with the regulatory authority.
As the circumstance which led to the issue may be as a result of other or additional works. It may be necessary to initiate a fleet campaign to establish the “overall” position and to determine if any additional engineering driven action should be mandated.
c) The work has been previously carried out
When a modification or repair is called for embodiment on the aircraft, however on attempting to perform the task it is found it in post mod or post repair condition already.
The following steps need to be taken
i/ Attempt to determine the cause of the repeat task being raised (for example it was caused by tech records not updating the system regarding the accomplished task )
ii) If such certified reference document is available then it is possible to close out the issued work card by reference to the original task
“Task xxxx has on inspection been found to be already embodied – see the following reference for accomplishment xxxxx-xxxxx no further action required this task is for reference purposes only ” this is NOT a certification it is for reference”
iii/ In the event that it is not possible to find the original task where accomplishment was carried out
Further action may be required regarding the certification of the material used for the modification / repair and it may be necessary to consult with Engineering / Quality Assurance / CAA / GCAA to determine. In the worst case it may be required to repeat the task using “known” material.
Where the use of material is not considered a “critical” component of the activity the task may be cleared as follows (with agreement from Engineering / QA).
“Task xxxx has on inspection been found to be already embodied – Inspection carried out to verify task has been performed in accordance with current applicable data and is considered fully serviceable and acceptable with no further action required.
This is a certification of the Mod Configuration – attesting to conformity
Where the use of material IS considered a “critical” component of the activity the task may be cleared as follows ( Attestation regarding criticality to be made Engineering / QA)
“Task xxxx has on inspection been found to be already embodied – Inspection carried out to verify task has been performed in accordance with current applicable data and is considered fully serviceable and acceptable however in accordance with concession reference xxxxx.
Task has a “90” day termination action for demonstration of full compliance.
This is a certification of the Mod Configuration – attesting to conformity (however an agreed extension is provided to either find the documentation to support the original material or to repeat the task with “approved” material).
