The Evolution of Continuing Airworthiness
Whilst a significant development path (from the late 1960s onwards) was embraced by the FAA & JAA (later EASA) a different path was pursued by Russia and the “now” Commonwealth of Independent States (CIS) (Essentially continuing with a more Type Certificate Holder (TCH) centric process).
The Continuing Airworthiness System embraced by the Overseas Territories is something of a hybrid as it simplifies considerably the EASA approach whilst still ensuring full compliance with International Civil Aviation Organisation (ICAO) and at the same time drawing on the strengths of both the FAA and EASA systems.
ISC – MRB – MSG
The current Industry Steering Committee (ISC) – Maintenance Review Board (MRB) development of the continuing airworthiness management process traces its origins back to the introduction of Maintenance Steering Group (MSG) 2 in 1970 & MSG 3 in 1980.
The Maintenance Steering Group Logic (MSG) “process” was fundamental to the system which is used to manage the development of the Maintenance Planning Document (MPD) and Aircraft Maintenance Program (AMP)
CAW process within Russia
Related to Soviet Built Aircraft, Continuing Airworthiness in Russia historically provided for a different philosophy of design, operation and maintenance
As a result of these differences, the level of competence within the CAMO group (required to support western aircraft CAW) may require additional development to compensate for any knowledge/skill weakness found, predominantly due to the lack of experienced and suitably qualified people.
CAW Competence & Common Miss Understandings related to OTAR
Typical Problems – Maintenance Programme Common misunderstanding between a Maintenance Schedule (Derived from the MPD) and a Maintenance Programme
The Maintenance Programme is the responsibility of the Operator and should contain additional “specific” items including
a) Corrosion Control Programme
b) The Reliability Programme
c) Customer Furnished Equipment (Galley’s – Seats etc)
d) In-Flight Entertainment (IFE)
e) Emergency Equipment
f) Supplementary Type Certificate Requirements (STC)
g) Repair Repeat Inspection Requirements
Repair Classification (FAA)
Category A. A permanent repair for which the Baseline Zonal Inspection (BZI) is adequate to ensure continued airworthiness (inspectability) equal to the unrepaired surrounding structure.
The operator should demonstrate to the FAA that its maintenance or inspection program is at least as rigorous as the Baseline Zonal Inspection (BZI).
Category B. A permanent repair that requires supplemental inspections to ensure continued airworthiness.
Category C. A temporary repair that will need to be reworked or replaced before an established time limit. Supplemental inspections may be necessary to ensure continued airworthiness before this limit.
h) Engine off-wing maintenance programme
i) Airworthiness Limitations
j) CMRs etc
Typical Problems and Issues Reported
a) Maintenance Programme Hard time parts control, particularly safety equipment (manufacturer’s recommendations) not included
b) Management of Life Limited Parts (LLP)
c) Fuel and Oil Contamination Checks
d) Flight Data and Cockpit Voice Recorders annual readouts
e) Service Bulletins (SBs) – whilst not mandatory the Operator should have a policy to analyse (Older aircraft may not have had any SBs incorporated for many years.)
f) Equipment ADs frequently not assessed as the equipment fitted not known therefore unsure as to which NAA responsible
g) AD – Alternative Method of Compliance used by a previous operator
Note
1/ Not performing SBs affects the reliability of the aircraft
2/ The MPD assumes that the aircraft is new and latest SBs have been embodied at build
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