AIRCRAFT MAINTENANCE DATA
Maintenance data
are maintenance information and instructions required to maintain an aircraft
or product in an airworthy condition. The maintenance data are used to ensure the continuing airworthiness of aircraft throughout its life and are required to be
kept up to date and accessible to maintenance personnel performing maintenance
and inspection on aircraft. Maintenance data are sometimes referred to as
technical data or airworthiness data either approved or accepted. This paper examined
the regulatory requirement for maintenance data and types of maintenance data.
The paper looked at the various categories of maintenance data and their
sources with emphases on the organization issuing or publishing such
maintenance data and importance. The availability of maintenance data to
persons or organization performing maintenance, the need for the currency of
maintenance data, the permissibility of making changes to maintenance data, and the
use of work cards and/or worksheets were examined including the requirements.
EASA
Part M.A.401(a) requires the person or organization maintaining an aircraft to
have access to and use only applicable current maintenance data in the
performance of maintenance including modifications and repairs. The maintenance
data could be any of the following:
- Instruction
for Continued Airworthiness (ICA) issued by the aircraft manufacturer or
Original Equipment Manufacturer (OEM) who owns the type certificate for
the aircraft type/product or the holder of a supplemental type
certificate for the aircraft type;
- Airworthiness
Directives (ADs) or other mandatory airworthiness requirements like
Certification Maintenance Requirements (CMRs) or Airworthiness Limitation issued
by the regulatory authority of the State of Design or ADs issued by the regulatory authority of the State of Registry;
- Airworthiness
data issued by the Part 21 organizations or other similar approved
organization; and
- Maintenance
data issued by the engineering department of an air operator or modified
by a Part 145 organization in accordance with a procedure approved the regulatory authority with safety oversight responsibility on that aircraft.
The
maintenance data could be once only issued data or subject to revision by the
issuer or publisher. At any point in time, only the current issue/revision of
the maintenance data is permitted to be used in performing maintenance on
aircraft and products by various regulations. Let us now examine the various
maintenance data held by operators or organizations performing maintenance on
aircraft or products.
Categories of Maintenance Data
Airworthiness
Directives (ADs) are issued by regulatory authorities of the State of Design
and/or the State of Registry. According to 14 CFR Part 39, an AD is issued when an
unsafe condition exists in the aircraft or product and the condition is likely
to exist in aircraft or products of similar design. ADs are an example of
Mandatory Continuing Airworthiness Information (MCAI) is required to be
provided by the State of Design and must be complied with by the aircraft owner or
operator. Most regulations forbid any person from operating an aircraft for
which an AD has been issued except in accordance with the terms and conditions
of the AD.
Instruction
for Continued Airworthiness (ICAs) are published by the type certificate
holders (aircraft manufacturers/OEMs) or the supplemental type certificate
holders for the aircraft or product. The aircraft owner, operator and
maintenance organizations must have access to these ICAs and use them in
performing maintenance on the aircraft or products. Some examples of ICAs are:
Maintenance Planning Document or Guide (MPD or MPG) that contains Maintenance
Review Board Report (MRBR), CMRs, and AWL; Aircraft Maintenance Manuals (AMM);
Troubleshooting Manual; Structural Repairs Manual (SRM), Component Maintenance
Manual (CMM), among others. These ICAs contains maintenance information or
instructions for maintaining the aircraft in airworthy condition by the person performing maintenance.
Airworthiness
data are issued by Part 21 organisations for modifications or repairs in
accordance with procedures approved by the regulatory authority having safety
oversight over the aircraft. Sometimes this type of airworthiness data is
required to be approved by the regulatory authority to determine that the
airworthiness data comply with the applicable airworthiness requirements. Such
airworthiness data includes major repair scheme.
Maintenance
data published by the engineering department of an air carrier in the form of
engineering order or maintenance data published or modified by an approved
maintenance organisation in the form of engineering drawing.
Availability
of Maintenance Data
Apart
from the fact that persons and maintenance organisations performing maintenance
should have access and use current maintenance data, both EASA Part M and Part
145 require maintenance data to be made available to mechanics and certifying
staff maintaining aircraft in close proximity to the aircraft or component being
maintained. Where maintenance data is accessed through computer systems,
sufficient computer terminals should be situated in the hangar for easy access.
Currency
of Maintenance Data
The
organisations performing maintenance on aircraft are required by regulations to
establish procedure to ensure the amendment status of the maintenance data
being used is monitored and kept up to date and where the maintenance data is
supplied by the owner or operator, the maintenance organisation should obtain a
written confirmation that the maintenance data is the latest amendment. Another
suitable means should be established to verify the amendment status of any
maintenance data. Most organisations have technical library under the Quality
Manager that monitors amendment status of maintenance data and produce an
amendment status list for circulation among workshops and offices. If a
maintenance data is out of date, that is enough ground for nullifying the
maintenance carried out on the aircraft.
Changes
to Maintenance Data
Maintenance
organisations performing maintenance on aircraft are permitted by regulations
to modify maintenance instruction where it is found to be inadequate or
ambiguous. This must be done in accordance with the procedure approved by their
regulatory authority in their maintenance procedures manual. However, the organisation modifying must
demonstrate that the changes will result in equivalent or improved maintenance
standards and shall inform the publisher of such changes.
Work
Cards or Worksheets
EASA
Part 145 permits the maintenance organisation transcribe accurately the
maintenance data onto such work cards or worksheets, or make precise reference
to the particular maintenance task(s) contained in such maintenance data. This
means the maintenance organisation should use a common work card or worksheet
systems throughout the organisation that would differentiate and specify, when
relevant, disassembly, accomplishment of task, reassembly and testing. The work
cards or worksheet may be computer generated to safe guard unauthorised
alteration and the maintenance organisation may also use the work cards or
worksheets of the operator where it so desire but a procedure must be
established to ensure correct completion of the work cards or worksheets.
Conclusion
O’Brien (2014) opined that maintenance
data are also referred to as approved data or accepted data based on the
regulatory jurisdiction, FAA or EASA. Maintenance data when used for performing
maintenance or repair on an aircraft are required to be up to date and be made
part of the certification of the maintenance and permanent maintenance records
of the aircraft. The maintenance data are required to be kept with the
worksheet or work cards used as the maintenance records of the aircraft.
Maintenance data is also called technical data, and airworthiness data by the
industry. The maintenance data must contain self-explicit instructions,
procedures and information in performing applicable maintenance or inspection
task. Most of them contains warning, and caution for persons performing
maintenance and standards to which the maintenance must be performed to.
I am thankful to you because your article is very helpful for me to carry on with my research in the same area. Your quoted examples are relevant to my research as well.
ReplyDeleteaerospace component
What is the difference of approved data and accepted data?
ReplyDeleteIs component drawing from OEM considered as approved or accepted data?