Service Bulletins SBs are not mandatory under any regulatory environment (Service Bulletins are subject to the Operator Review Policy) however we should not loose sight of the fact that not performing SBs may affect the reliability of the aircraft.
A Service Bulletin (S.B.) is a notice to an aircraft operator from a manufacturer – either type Certificate Holder TCH, Original Equipment Manufacturer (OEM) or Technical Standard Order (Holder) TSO identifying a product improvement.
Having realized that there were distinct levels of seriousness to a service bulletin, manufacturers started to categorize them as optional, recommended, alert, mandatory, informational, etc. It was left to the manufacturers to classify a service bulletin as they considered best for there was no standard for the terminology.
Differentiation between non-mandatory service bulletins is done and decided only by the FAA or EASA
An alert service bulletin is issued when an unsafe condition shows up that the manufacturer believes to be a safety related as opposed to a mere improvement of a product.
The official EASA position regarding ‘required’ application of SB instructions is as follows:
Through the DOA (Design Organisation Approval) oversight process, the Agency promotes that TC/STC holders designate a Service Bulletin (SB) as mandatory only if it is known to them that this SB will also be covered by an AD. In all other cases, the TC/STC holder should use a term like ’highly recommended‘(or equivalent). However, this is not yet common practice and there are still cases where an SB is termed ’mandatory ‘by the TC/STC holder, although no AD is to be issued.
The Agency has no legal tools to prohibit the use of the word ‘mandatory’ by TC/STC holders, but EASA Certification Memorandum CM-21.A-J-001 has been issued to provide advice and guidance on this subject.
Compliance with service bulletins basically translates into higher costs to the aircraft owner.
Whether it requires performance of a more detailed and elaborate inspection or replacement of a component, service bulletin’s recommendation means that the aircraft operator / owner will face the challenge of additional costs. As a result, there may be a temptation to reject or defer compliance with service bulletins. money.
If safety is not an issue, an aircraft owner may decide to perform a cost-benefit analysis so as to compare the benefits of complying with a service bulletin and the cost of compliance.
There is a way for the manufacturers to make a service bulletin mandatory and this is to include the requirement within the TCDS (Type Certificate Data Sheet) or within the airworthiness limitations part of the Aircraft Maintenance Manual AMM (Chap 5) / Maintenance Planning Document (MPD)
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