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All aircraft operators and maintenance engineers.
The purpose of this Continuing Airworthiness Notice (CAN) is to provide guidance for aircraft operators and maintenance engineers regarding the assessment of and their decision as to whether they need to comply with manufacturer’s service information.
The term “service information” is used here to encompass the various forms of notification that a manufacturer may use to communicate airworthiness information to aircraft owners/operators. “Service bulletin” is the common term and is often used in a generic sense; but there are also Service Letters, Service Information Letters, Service Notices and so on. Manufacturers may also attribute a different weight or focus to each type of publication in addition to applying different priorities.
Service information published by vendor suppliers to aircraft manufacturer’s or product OEM’s is sometimes re-published by the aircraft manufacturer or product OEM. The service information for the vendor supplied items, regardless of whether published through the vendor or the aircraft manufacturer or product OEM, must be assessed and actioned the same as the service information published by the aircraft manufacturer or product OEM.
Within our rule structure we know that Rule 91.603(a)(1) requires that an operator must ensure an aircraft is maintained in an airworthy condition. To achieve an airworthy condition we can pick up the linkages made by the applicable definitions in Part 1, which leads to:
· Instructions for continued airworthiness (ICA’s) means current airworthiness data provided by the manufacturer of an aeronautical product, a product, or a component, and include any related airworthiness limitations mandated by the airworthiness authority of the State of Design.
· Airworthiness data means any information necessary to ensure an aeronautical product, or a product, or a component can be maintained in an airworthy condition.
· Airworthy condition means the condition of an aircraft, including its components, fuel and other materials and substances essential to the manufacture and operation of the aircraft that complies with all the requirements prescribed by the Civil Aviation Rules relating to design, manufacture, maintenance, modification, repair and safety.
Therefore, for an operator to maintain an aircraft in an airworthy condition, they must have access to all available publications (ICA’s), including service information, assess the information for applicability, action accordingly and record that action in the maintenance logbook. Leaving aside publications made mandatory by airworthiness directives, manufacturers’ publications may be considered under three general headings:
1. Recommended methods, techniques and practices for the performance of maintenance,
2. Recommended modifications, or inspections,
3. Mandatory actions established as part of the type certification process.
Although a single publication may in practice deal with more than one topic, in this CAN each group will be dealt with separately:
1. Publications specifying methods, techniques, and practices for the performance of work.
Publications under this heading may be considered as amendments or additions to the instructions for continued airworthiness (ICA’s). As such, pursuant to Rule 43.53(3), they constitute one of the acceptable sources for such data. (The other is equivalent methods, techniques and practices acceptable to the Director).
An example is Cessna SEB99-18R1 Fuel Quantity Indicating System Inspection: To verify Gauge Reads Empty When the Tanks are Empty.
2. Publications recommending the incorporation of modifications or the performance of inspections.
Except for all the compliance requirements of Rule 91 Subpart G, compliance with service information dealing with the incorporation of modifications or the performance of inspections is optional. However, aircraft operators have a duty to be aware of the contents of these publications and to evaluate the need for compliance in light of their own circumstances.
Those operators on air operations (Part 119) and operators with a maintenance programme approved under Rule 91.607 should have a documented process for conducting and recording the evaluation of service information, as part of their approved maintenance programme.
For all operations where the manufacturers’ maintenance schedule Rule 91.605(a)(3) refers to a service bulletin or equivalent service information as part of the inspection, then compliance is required. Where the manufacturer’s maintenance schedule refers to service information that is superseded by a later revision, then the later revision must be complied with.
An example is Cessna SEB03-4 Nose Landing Gear Wheel Fairing Modification: To provide a modification to enhance the strength of the nose landing gear wheel fairing upper attachment area.
3. Publications providing information regarding airworthiness limitations established as part of the type certification process.
On occasions the communication of airworthiness limitations, such as component life limits, or maintenance requirements, is accomplished by manufacturers issuing service bulletins, or equivalent service information. When used in this manner the content of the bulletin is a condition of the type certificate and compliance is mandatory.
An example is: Pratt & Whitney SB1302R5 Turboprop Engine Rotor Components Service Life: which lists the service lives of certain components and requires compliance to remain in conformance with the type design.
“Do manufacturers’ service bulletins or service information need to be complied with?”
Operators need to review all service information published by the manufacturer and action according to their type of operation, maintenance options, whether the instructions for continued airworthiness are affected or the type certificate is affected, or whether it forms part of the maintenance schedule.
This review must be carried out by a competent person and the outcome of the review must be recorded and signed for by the aircraft operator in the appropriate maintenance logbook.
“How far back do we have to go?”
It is reasonable to expect that the latest revision of service (maintenance) manuals published by the manufacturer will incorporate any applicable service information (e.g. service bulletins) prior to the date of the revision. Any service information published since the revision should be reviewed and action according to the type of operation, maintenance options, whether the instructions for continued airworthiness are affected or the type certificate is affected, or whether it forms part of the inspection/maintenance schedule.
All enquiries regarding this CAN should be made to the CAA at Airworthiness@caa.govt.nz