OTAR Maintenance Data General Comments
111.1 General
An approved maintenance organisation should hold and use the following minimum maintenance data relevant to the organisation’s approval rating. All maintenance related OTARs associated OTACs, a copy of the Air Navigation (Overseas Territories) Order and all applicable Airworthiness Directives.
OTAR Use of Manufacturers Maintenance Data
111.2 Manufacturers’ Maintenance Data
An approved maintenance organisation should hold and use the following maintenance data where published that is relevant to the organisation’s approval rating. The aircraft maintenance manual, repair manual, supplementary structural inspection document, corrosion control document, appropriate sections of component vendor maintenance and repair manuals, service letters, service instructions, modification leaflets, NDI manual, parts catalogue, type certificate data sheet and any other specific document issued by the type certificate or supplementary type certificate holder as maintenance data.
OTAR Use of Customer Supplied Maintenance Data
111.3 Customer Supplied Maintenance Data
Where an operator or customer provides maintenance data, this data should be verified for applicability and revision status. These arrangements should be identified in the works order contract. It is not necessary to continue to hold such provided data when the work order is completed; however records of its use should be retained.
OTAR Maintenance Data Availability
111.4 Maintenance Data Resources
The approved maintenance organisation should retain relevant copies of maintenance data applicable to the scope of approval at approved locations where the maintenance is conducted. This will inevitably mean that certain documents will need to be duplicated whereas others need only be made available at particular approved locations.
OTAR Maintenance Data Validity
111.5 Control and Availability
(a) To keep maintenance data up to date, a procedure should be in place to verify the amendment status of all data and maintain a check that all amendments are being received by having a subscription to a document amendment scheme. Where several copies of a document are held the procedures should ensure that these are all maintained to the correct revision status.
(b) It is important that maintenance data is made available to personnel maintaining aircraft and that the data should be available in close proximity to the aircraft being maintained for supervisors, mechanics and certifying staff to study. Additionally, consideration should be given to situations where maintenance, repair and or defect rectification is being undertaken away from the approved sites. In these circumstances, it may be advisable to ensure that those involved in such maintenance activities have appropriate access to any required data through a person responsible for maintenance data within the organisation. These arrangements should be formalised and be available during the hours of the maintenance activities.
(c) Where computer systems are used, the number of computer terminals should be sufficient in relation to the size of the work programme to enable easy access, unless the computer system can produce paper copies. Where microfilm or microfiche readers/printers are used, a similar requirement is applicable.
OTAR Concerning Complex Maintenance Tasks
111.6 Complex Maintenance Tasks
Where complex maintenance tasks are undertaken using a work card system to record the maintenance activity, it is advisable that the maintenance data should be transcribed onto the work cards or worksheets. This should be subdivided into clear stages to ensure a record of the accomplishment of the maintenance task. Of particular importance is the need to differentiate and specify, when relevant, disassembly, accomplishment of the task, reassembly and testing. In the case of a lengthy maintenance task involving a succession of personnel to complete such task, it may be necessary to use supplementary work cards or worksheets to indicate what was actually accomplished by each individual person.
OTAR Management of Inaccurate Data
111.7 Inaccurate Data
(a) A procedure should ensure that when maintenance personnel discover inaccurate, incomplete or ambiguous information in the maintenance data they should record the details. The procedure should then ensure that the approved maintenance organisation notifies the problem to the author of the maintenance data in a timely manner.
A record of such communications to the author of the maintenance data should be retained by the approved organisation until such time as the type certificate holder has clarified the issue by e.g. amending the maintenance data.
(b) The procedure in (a) should be specified in the Maintenance Organisation Exposition.
(c) The procedure should also address the need for a practical demonstration by the engineer to the quality personnel for a proposed modification to the maintenance instruction. The quality personnel should approve (or not approve) the modified maintenance instruction and ensure that the type certificate or supplementary type certificate holder is informed of the modified maintenance instruction. There should be traceability of the complete process from start to finish, ensuring that the relevant maintenance instruction clearly identifies the modification. Modified maintenance instructions should only be used in the following circumstances:
(1) Where the type certificate / supplementary type certificate holder’s original intent can be carried out in a more practical or more efficient manner;
(2) Where the type certificate / supplementary type certificate holder’s original intent cannot be achieved by following the maintenance instructions. For example, where a component cannot be replaced following the original maintenance instructions;
(3) For the use of alternative tools/equipment.
Next Steps
Sofema Aviation Services www.sassofia.com and Sofema Online www.sassofia.com provide regulatory training compliant with EASA, FAA & OTAR requirements. For details please email office@sassofia.com or online@sassofia.com
