Regardless of how the Service Bulletin (SB) is identified by the issuing company, Service Bulletins are not mandatory, unless they are supported by an Airworthiness Directive (AD). So from a regulatory point of view the SB may not be required. However this is only one part of the story. SB’s may also be driven by Lease Obligations or by Organisational decisions. Whilst the intention of the SB provider is to raise the standard of safety, the operator may view the cost of the bulletin as not effective for the particular aircraft, engine or component.
For the Operator to automatically comply with service bulletins will result in increased maintenance costs. For this reason it is normal for the Operator to implement a Service Bulletin Analysis process. Even Free of Charge (FOC) Service Bulletins may not be free.! Research has indicated that the actual cost of embodying a service bulletin. (This will typically translate into higher maintenance costs.) A survey of Service Bulletin true costs showed that the actual cost of embodiment was between 7 to 13 times the basic cost of the Service Bulletin.
Therefore it makes sound financial sense to review SB’s not just for Safety Benefits, but for economic benefits and to make a balanced decision to embody. A template may be used for this purpose which will consider all the relevant criteria which is applicable including the remaining length of the lease, the various obligations, as well as benefits to both safety & reliability a cost benefit analysis will allow the operator to compare the cost of embodying the aircraft maintenance service bulletin (compliance) in the light of the perceived benefits.
With this information the appropriate decision should become more obvious. The Operator through the Continuing Airworthiness Management Organisation (CAMO) is responsible to ensure the management of the status related to the serviceability of both operational and emergency equipment. This process shall ensure the accomplishment of modifications in accordance with an approved standard and, for non-mandatory modifications, the establishment of an embodiment policy. A typical policy will ensure that All mandatory modifications shall be carried out in accordance with the approved Airworthiness Directives (AD’s), Service Bulletin (SB’s) and/or Supplemental Type Certificate, taking due regard of applicable CDCCL requirements.
A Non-Mandatory Modification Embodiment Policy will examine all incoming technical data including Service Bulletin. Furthermore to consider the embodiment of all non-mandatory modifications, which can be shown to improve reliability and/or economical operation of the aeroplane and aeroplane components. The process normally involves the Technical Service or Engineering Department reviewing and make recommendations on embodiment of Service Bulletins (SB) together with any other associated non-mandatory material.
Based on the recommendation a final decision is normally taken by a modification committee including inputs from Engineering Finance as well as the accountable executive or other senior management. For Maintenance Planning purposes it is essential to ensure that full consideration is given to applying such modifications and or Service Bulletins at the same time as base maintenance occurs, in order not to interrupt the production.
Sofema Aviation Services offers training and consultancy for EASA compliant aviation as well as vocational training including Aviation English vocational training. For details please see www.sassofia.com or email: office@sassofia.com
