Now we will talk about ADs, what they are, how and why they are produced and how to perform review and build the AD binders if required.
At the beginning it is important to understand what is an AD, regulatory basis and how it is publicated. An Airworthiness Directive means a document issued or adopted by the Agency (NAA such as FAA or EASA), which mandates actions to be taken or the conditions or limitations on an aircraft, engine, APU, component to restore an acceptable level of safety, when evidence shows that the safety level of this aircraft or aeronautical product may otherwise be compromised.
The main purpose the of the AD is to make aircraft owners, operators aware of the condition and how to manage or resolve potential risks associated with this condition.
The ADs contain mandatory requirements that should be carried out, however, you usually will not find direct accomplishment instructions in the AD document as it will refer to Service Bulletins, AOTs which will contain step-by-step work instructions. Access and visibility of these documents should be granted to you in order to accomplish review.
As ADs contain mandatory requirements they will have compliance timeline that owner or operator should use to address the condition or limitation. Compliance time limits are measured by either or combination of flight hours, flight cycles, aircraft flight hours, aircraft flight cycles, engine flight hours, engine flight cycles, calendar days, months.
Regulatory Basis
The process of introducing the safety publication is initiated by an unsafe condition, situation or fatalities. The data is collected during operation, maintenance, inspections, audits, testing of aircraft, main assemblies (engines, landing gears, APUs), components, etc…
The ADs are issues by the NAA where TC (Type Certificate) and STC (Supplemental Type Certificate) holder is registered (e.g. EASA issues ADs for Airbus and FAA for Boeing). Taking into account importance of the ADs the failure to comply with the threshold can affect aircraft airworthiness. Thus all issued ADs should be analysed by the operator for the specific aircraft and all necessary corrective actions must be accomplished. Any airworthiness issue makes aircraft not fit for flight and CoA will no longer be valid. In such cases operator or lessor can apply for fly permits to perform a ferry flight to the final location for maintenance, dismantle, etc…
Examples of corrective actions may consists of modifying, inspecting, verifying or replacing, components, parts, assemblies, updating manuals or maintenance programme withing the specified time frame, or imposing new operational limitations.
Below is the general process from unsafe condition to possible AD taken from IATA (Guidance Material and Best Practises for Aircraft Leases 4th edition, 05.2017)
Content of Airworthiness Directive
In this chapter we will discuss the main parts and contents of the AD. Airworthiness Directives issued by different Authorities will have different formats, however, the main content will be the same and typically it will contain the following:
- AD Number
- Date of issue
- State of Manufacture and/or Registration for EASA and FAA ADs
- Supersedure/Affected ADs – explains if this AD supersedes, cancels, replaces any prior issued AD
- Applicability – explains the product that AD covers, such as:
o Manufacturer
o Aircraft type, aircraft model, MSN
o Engine type, engine model, ESN
o Component, Part Number or Serial Number
o Specific Modification and/or STC
- Reason for Unsafe Condition – explanation of the problem
- Required Action/Compliance – actions required to restore an acceptable level of safety such as:
o Modifying, inspecting, verifying or replacing, components, parts, assemblies, updating manuals or maintenance programme withing the specified time frame, or imposing new operational limitations.
- Compliance time
- Reference Documentation – Service Bulletins, AOT’s, Vendor Service Bulletins
- Options for Alternative Means of Compliance – AMOC
- Contact information for queries, support, concerns
AMOC
AMOC – Acceptable Means of Compliance is an approved deviation from the AD. To address an unsafe condition on parts, products and appliances. An AMOC must provide a level of safety equivalent to the level of safety to be restored by compliance with the original AD. AMOCs may be issued in respect of, but are not necessarily limited to, the following:
· Alternative modifications
· Alternative inspection procedures
· Alternative maintenance intervals and/or procedures
· Specific operating procedures or limitations, etc.
· AD non applicability, due to configuration difference (Mods, STCs, etc..)
· Different tooling available during AD accomplishment
It is important to note that EASA cannot accept applications for AMOCs referring to aircraft that are not registered in an EASA Member State, as this is outside of EASA’s jurisdiction. However, if TC is issued by EASA than it automatically will approve FAA AMOCs. Also you should know that if AD has been superseded than AMOC will be automatically invalidated, if AD was revised than AMOC will be still valid because AD can not introduce more stringent requirements.
Source and more information on AMOCs available on EASA FAQ section: https://www.easa.europa.eu/en/the-agency/faqs/alternative-method-compliance-amoc-airworthiness-directive-ad
NOTE: when performing review make sure to check lease conditions as some operators and/or lessors will not accept AMOC compliance mainly due to transferability issues between jurisdictions.
AD Status
AD status or summary is an overview of all ADs issued for the aircraft type, engines, APU and installed components. Correct completion and check of AD summary is important for accessing applicability and completion status of ADs to monitor compliance. Airworthiness Directive summary ideally should identify the following information:
- AD Number
- AD effective date
- AD Description
- Latest bi-weekly number
- Engineering documentation and/or Manufacturer’s SB reference where appropriate
- Status (T-terminated, SS-superseded, O-open, N/A-not applicable, R-repetitive, PE-partially embodied) or other termination that clearly identifies the status of AD
- Date of embodiment, flight hours or cycles, as appropriate. For repetitive ADs only the last accomplishment should be recorded
- Date of embodiment, flight hours or cycles when the next maintenance is due, as appropriate
- Which part of a multi-part directive has been accomplished and applicable reference to accomplishment paperwork such as work order No, job card No, engineering order or reference to other paperwork with accomplishment instructions
- If AD is not applicable – the reference to the document or the reason why AD is not effective
- Details of any AMOC, including references, applicability and intervals, as appropriate, AMOC reference No
- Summary certification – AD summary must be certified with date of certification, stamp and/or signature
It is important to mention to always refer to the lease agreements as some of them will have information what data should be captured on the status. Nowadays is not mandatory to list superseded or cancelled ADs on the status, but many operators have them for tracking purposes.
As per redelivery standards and common practises it is recommended to have separate summaries for airframe, appliances, engines and APU ADs.
Review Process
Before jumping into records review process, it is important to check the lease conditions to know the requirements for aircraft return, sale or acceptance.
Typical terms as per lease (delivery conditions) are:
- Clearance period of 180 days (6 months) after aircraft sale, return.
- If reduced clearance period is introduced in the contract and that usually it will be 90 days, 500 cycles and 1000 flight hours.
- To which Manufacturers Type Certificate Aircraft should conform, for example EASA and/or FAA. Lease agreement will confirm the clearance period and which ADs must be complied with.
To better understand Type Certification and the jurisdiction you can check delivery documentation that came from manufacturer. Airbus will most likely be covered by EASA when Boeing by the FAA.
Also check if aircraft has a current legal and valid transport category certificate of airworthiness issued by the aviation authority with which the aircraft is registered prior to delivery, to confirm where the aircraft was operating.
After contractual obligations are understood you may start the process of the actual review by downloading the status of applicable ADs to your aircraft from FAA or EASA. Next slides will show you the step-by-step process of how to extract the data from their websites.
EASA AD Status Extract:
- Log into https://www.easa.europa.eu/
- Select “Domains” -> “Aircraft Products”
- Select “Airworthiness Directives”
- Click “EASA Safety Publications Tool”
Easiest way:
- Go to google and type “EASA AD”
- Select “EASA Safety Publications Tool”
On the new screen click “Advanced Search”
On the left side you will see the following Acronyms:
- AD - Airworthiness Directive, an AD which becomes effective 14 days after the date of issue
- EAD - Emergency Airworthiness Directive, an AD which becomes effective two days after the date of issue
- PAD - Proposed Airworthiness Directive
- SIB - Safety Information Bulletin
- SD - Safety Directive
- PSD - Proposed Safety Directive
Select AD and EAD – depending on the lease requirements, however, these are the main sections to look for.
Select applicable aircraft type and model by the manufacturer. Select letter in Taxonomy, B for Boeing, A-for airbus and so on.
Select – the applicable aircraft model – by double clicking on it – make sure it appeared on the right side of the table
Once selected – click search
Now you have a full list of ADs that you need to extract. Click “Export list as…”, select CSV and US – separator is the comma (,) – for better representation in excel.
The list will be downloaded to your computer.
FAA AD Status Extract
· Go to https://www.faa.gov/
· Select Regulations -> Airworthiness Directives
· Click “Dynamic Regulatory System (DRS)”
Easiest way
· Go to google and type “FAA AD”
· Click “Dynamic Regulatory System (DRS)”
In “Search Current Documents” you can type document number to find the document. If you are looking for individual ADs use search to quickly find required document.
To extract status, click on the dropdowns on LH side of the screen: Airworthiness Directives (ADs), Select AD Rules, and you will get Filter screen to use them to get the AD List. Let’s check ADs for Airbus A321-231.
Once selected click “Apply” and you will get the list of ADs related to selected Aircraft Model. Click “Save Result List” and the excel file will be downloaded to your computer.
After applicable AD status is extracted, make sure that all ADs are listed until the latest bi-weekly AD.
Note: sometimes operators or CAMO will not include ADs embodied by manufacturer at delivery as they are tracked on the delivery AD status. It can be acceptable if there is no provisions in the contract or end customer accepts it. However, industry standard is to cover delivery ADs on the final (current) AD status.
If final status is provided – it should be certified and stamped. CAMO or an authorised signatory must sign the AD status. If draft is provided – make sure that all amendments to the status are tracked until it is certified.
As previously mentioned, some operators will manage all ADs (airframe, components, engines, APU’s) on the one report – it is acceptable if contract or any additional conditions permit, however, it is a rear practise and as per industry standard you will have separate Airframe, Appliance, Engine and APU AD summaries and binders.
Example of an operators airframe AD status
Crosscheck for superceded/cancelled ADs
Compliance Binder
At this stage you should know what is AD, it structure, what should be on the AD status and how to extract applicable AD status from the FAA and EASA portals. Now let’s talk about what should be in the AD compliance binder (hard Copy or Soft copy format).
The binder should contain the full collection of Airworthiness Directives which were issued against aircraft type. Each AD file should contain:
- AD copy
- Applicable SB copy (if SB is to big you can save it as a separate document, if hard copy binders required – printout of SB summary can be added)
- Dirty Fingerprint (DFP), either one or combination of: Task Card (TC), Non Routine Card (NRC), Engineering Order (EO), Work Order (WO) or log book entry. All documentation should contain at least the following information:
o Aircraft details (MSN and/or Registration, type)
o Date of accomplishment
o Signature and authorization number of certifying staff
- Any additional referenced documents: AOTs, NDT reports or certification, Vendor Service Bulletins (VSB), etc…
- AMOC if applicable
- Certificate of release to service (CRS)
Note: For AD compliance SB revision should be the same or higher as mentioned in the AD. If accomplishment was done at lower SB revision than it is important to confirm if AD permits it in “Credit” and/or “Ref Publications” section, or if any additional actions need to be accomplished for compliance.
Note: Some ADs will refer to MPD tasks and some MPD tasks will perform the inspection requirements of the AD. It is important to check within the AD document if MPD task accomplishment will satisfy the requirements of the AD. Ref Example:
Review
When AD summaries are extracted and provided, and AD binders available for review, you can start by reviewing the following:
· Check that all ADs are listed in the AD status report and you have file for each AD
· Check the Status of ADs (T-terminated, SS-superseded, O-open, N/A-not applicable, R-repetitive, PE-partially embodied) or other termination that clearly identifies the status of AD
· Check the Date and Method of Compliance
· If AD is repetitive or terminating action was not performed – check when the next inspection or action is due. It is important to make sure that all repetitive and ADs that are due are properly controlled on the AD status. Such ADs also may be tracked in the operators AMP or other tracking document or system such as AMOS or SAP.
o For Repetitive ADs make sure that you have the latest compliance DFP.
· In regard to the superseded ADs – some operators track them on the status and some don’t. If the Contractual requirements does specify to include SS ADs or ALL ADs – than there is no regulatory requirement to track them
· For not applicable ADs – check the reason for AD being not applicable and compare with the AD effectivity/applicability section. A good example would be when you are involved in redelivery of Airbus A320 with V2500 engines but AD is effective for A320 with CFM engines installed. Or AD is applicable to aircraft with certain post mod configuration when your aircraft is in pre mod configuration.
o In such cases showing the current engine type installed on the AD status or adding extract that shows engines installed into AD file; or extracting the page that shows mod configuration of the aircraft from delivery report will be enough to show that AD is N/A.
o In rear cases when for example it is hard to establish applicability due to insufficient records or access to them, a signed statement issued by a member of the airline’s Quality Assurance team giving the reason for non-applicability can be requested.
To Summarise:
· Crosscheck contractual requirements for ADs and clearance period
· Request the AD status and crosscheck the status against downloaded summary from the FAA, EASA, etc.. to make sure that all ADs related to Aircraft, engine, APU, appliances are listed.
· Request AD binders or soft copies
· Check ADs for status (open, closed/terminated, not applicable, superseded, repetitive)
· Check that all information on the AD status is available and correct (AD No, effective date, description, engineering documentation references, AMOC if applicable, compliance references, embodiment date/FH/FC and next due information if applicable).
· Check that AD files have all information to confirm the status of AD with substantiating paperwork.
· Check that AD binder contains all necessary paperwork to show compliance ( AD copy, SB copy, DFP, any additional referenced documentation (e.g. AOTs, VSBs, NDTs, certs, etc…), AMOCs if applicable and CRS).
Regulatory Document
· EASA
o ED Decision 2003/19/RM
o ED Decision 02/2003 – Article 1
o EC 2042/2003 Annex I, Part-M
o EU 748/2012, Annex I, Part 21, Section A, Subpart A, 21.A.3B