Sofema Aviation considers the key requirements related to the oversight and management of Non-Mandatory Service Bulletins (SB’s)
Introduction
The assumption that “no mandate equals no obligation” is a common trap in aviation management. While you are legally correct that a non-mandatory Service Bulletin (SB) does not carry the same “ground-the-airplane” weight as an Airworthiness Directive (AD), a CAMO’s obligation is not defined by the action of the SB, but by the process of evaluation.
The Regulatory Oversight Expectation
Regulators do not expect you to embody every SB, but they absolutely expect you to manage them. Under Part-CAMO requirements, your organization must have a robust system to monitor and assess all continuing airworthiness information.
- The Assessment Mandate: You cannot simply ignore a bulletin. You must be able to prove to an auditor that the SB was received, reviewed by a competent person, and a conscious decision was made to either implement it, defer it, or reject it.
- The “Instructions for Continued Airworthiness” (ICA): Many SBs eventually become part of the manufacturer’s Maintenance Planning Document (MPD). If a non-mandatory SB is absorbed into the ICA, its status changes from “optional” to a required part of the maintenance program unless an alternative is approved.
- The Safety Management System (SMS) Link: Modern oversight focuses on risk. If an SB addresses a known technical “nuisance” that could lead to an in-flight shutdown or a high-energy failure, ignoring it is seen as a failure of your Risk Management process, even if the SB isn’t “mandatory.”
Risk and Best Practice
Treating non-mandatory SBs as “optional” creates a blind spot in your safety and financial strategy. Best practice involves categorizing these bulletins to determine their true priority.
The Safety-Related “Pre-AD” SB Often, a manufacturer issues an SB to fix a safety issue while the regulator is still drafting an AD. (Note an ALERT Service Bulletin is the closest industry can get to an AD – Serious Organizations will always comply with Alert SB’s)
- If a CAMO ignores this SB and an incident occurs, “it wasn’t mandatory” is a legally indefensible position.
- Best practice is to identify SBs that address “Safety of Flight” and prioritize them as if they were mandatory.
Operational Reliability and Financial Risk Some SBs are designed to fix components that have high failure rates.
- While not a safety threat, a failure can cause an Aircraft on Ground (AOG) situation. The cost of performing the SB during a scheduled check is almost always lower than the cost of an unscheduled engine change or a cancelled flight at a remote outstation.
Asset Value and Lease Conditions If you manage leased aircraft, “non-mandatory” is a misnomer.
- Most Lease Agreements contain clauses requiring the operator to embody SBs of a certain “Recommended” status.
- Returning a “dirty” aircraft (one with low SB compliance) can result in massive financial penalties or “buy-back” costs during the redelivery phase.
Potential Exposure: The Hidden Liabilities
By choosing not to address a non-mandatory SB, the CAMO is essentially “accepting the risk.” This creates three specific types of exposure:
Legal and Liability Exposure In the event of a mishap, a plaintiff’s legal team will compare the manufacturer’s recommendations against your actions. If the manufacturer provided a “fix” and you chose not to apply it solely to save money, it can be characterized as negligence, regardless of the SB’s legal status.
Insurance and Underwriting Insurance companies increasingly look at SB incorporation rates as a KPI (Key Performance Indicator) for an operator’s safety culture.
- A low compliance rate for recommended safety enhancements can lead to higher premiums or more restrictive policy terms.
Warranty and Maintenance Credits Many manufacturers offer “goodwill” or “warranty” pricing for parts and labor if an SB is performed within a certain window.
- If you ignore the SB and the part fails later, you will likely be forced to pay full list price for the replacement, losing the financial protection the SB offered.
Summary of the CAMO’s “Right” Approach
The “right” answer is that while you have no statutory obligation to do the work, you have a procedural obligation to justify why you didn’t.
A high-performing CAMO should have a written “SB Assessment Form” for every non-mandatory bulletin. This form should document the technical benefit, the risk of non-compliance, the impact on fleet commonality, and the final management decision. This creates a “paper trail of safety” that protects the organization during audits and in the event of technical failures.
Next Steps
Join Sofema Aviation for a CAMO Compliance Challenges webinar on Tuesday, 24 March, from 10:30 – 13:00 Sofia time. Register for the webinar here – places are limited, so be sure to secure your spot early.
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Aircraft Maintenance, aviation safety, Safety Management System, Airworthiness, Part CAMO, sasblogs, Instructions for Continued Airworthiness (ICA), Sofema Online (SOL), Aviation Compliance, Aircraft Management, sofema aviations (SAS)
