Sofema Aviation Services www.sassofia.com considers issues related to the need to ensure compliance with Airworthiness Directives in the context of OTAR.
Service bulletins often result to issuance of Airworthiness Directives by FAA. An airworthiness directive references the alert service bulletin as a way of complying with the AD.
Although a service bulletin may be categorized as mandatory by the manufacturer, it is crucial to know that compliance with service bulletins isn’t necessarily required under the FARs (Federal Aviation Regulations) unless the service bulletin includes or is accompanied by an airworthiness directive.
As opposed to service bulletins, airworthiness directives affect the safety conditions of a flight. It’s for this reason compliance becomes mandatory.
It is ultimately the Operators responsibility to ensure that all Airworthiness Directives issued by the Regulatory Authority of the Type Certificate Holder, The Engine Manufacturer or the Regulatory Authority of any equipment manufacturer.
Typical Problems occur when the operator is not sure of exactly what constitutes an AD. That is not uncommon
Equipment ADs frequently not assessed as the equipment fitted not known therefore unsure as to the NAA responsible
It is also possible that an Airworthiness Directive Alternative Method of Compliance has been employed by a Previous Operator and which will require a conformity inspection to ensure full acceptance.
Back to birth traceability is required for airworthiness records including Major Repairs, Major Modifications.
It is essential that all the information supporting an STC should be in the records (STC, ICAW, Drwgs, Flight Manual (FM) Supplement, Airworthiness Limitations, Certification Maintenance Requirement (CMRs) etc)
Details of Work Shop Visits for LDG and engines are essential especially during lease returns.
For all Hard Time Components either EASA Form 1 or FAA 8130-3 dual release
FAA Parts Manufacturing Approval (PMA)
Whilst Parts manufactured under the FAA Parts Manufacturing Approval (PMA) are acceptable to FAA / EASA / OTAR when accompanied by an 8130-3 form, However, they must be eligible for fitment on the aircraft type. Also to consider that many leasing contracts prevent the fitment of PMA parts
Notes
1/ Without full availability of all essential information it is challenging to effectively manage the continuing airworthiness and any required rectifications could come with a significant cost burden.
2/ The aircraft lease agreement will usually place the full burden on the lessee (Operator) and the importance of ensuring the full viability and integrity of the it cannot be overstated.
3/ Mistakes or omissions when accepting the aircraft are always going to be the Iessee’s responsibility!
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