May be first time you hear about “aircraft technical record” it might seem obvious, but in this article we tried to uncover a set of rules and regulations which describes what we mean by “Aircraft technical Records” or “aircraft continuing airworthiness records”

Please at any circumstances don’t underestimate the importance of the technical records, without documentary evidence supporting the airworthiness status of the aircraft simply it would not be allowed to fly (in fact if the aircraft continuing airworthiness technical records were not available then the certificate of Airworthiness would be also be declared invalid!)- and ofcourse the aircraft not airworthy.

Regulatory definitions:

            EASA definitions:

“Detailed maintenance records” are required to be kept by an AMO (respectively Part-M/F organization or Part-145 organization). Maintenance organizations are required to retain all detailed records in order to be able to demonstrate that they maintained aircraft and components in compliance with applicable requirements. as defined in M.A.614 or 145.A.55(c)

“Detailed maintenance records”: are those records, coming from the AMO having performed maintenance, required to be kept by the owner/operator (or the CAMO when required by M.A.201) allowing to determine the aircraft configuration, the airworthiness status of the aircraft and all components installed, as well as to plan future maintenance as required by the AMP, based on the last accomplishment. as defined in M.A.305(h)

What the tasks required from “Technical record department”?

1. a) Maintain and manage any records associated with the maintenance management or operation (track hour /cycle /calendar to aircraft /engine/units/ components).
2. b) Liaise with the Stores inspector regarding the management of components and the control of Form 1’s for fitted components.
3. c) Raise, Issue and Distribute end of month status and engineering reports.
4. d) Liaison with Maintenance Planning and Engineering Departments in particular in respect of component configuration and status.
5. e) Support the performance of Airworthiness Reviews (ARC) process to ensure correct availability of back to birth records for Continuing Airworthiness.
6. d) Importation and Exportation of Aircraft Technical Records as required.
7. e) Perform QC Data checks of the various information’s which managed by the Technical records office and resolve any ambiguities, technical or other problems from Engineering, Operations and Crew.
8. f) General and administrative support to Engineering for additional support tasks for example management of Calibration and or servicing records of Ground Support Equipment (GSE)
9. g) Support for the Quality Department to track and manage Licensed Aircraft Maintenance Engineers Licenses (LAME) and Organization Company Approval as appropriate.
10. h) Perform Training and Mentoring to Technical Records support staff and junior administration staff regarding the correct functioning of the organization’s procedures.

Record keeping / Retention:

It is considered a best practice as part of the AMO record-keeping system, (and it is also required by certain competent authorities) to record information (e.g. batch number or other tracking reference) relevant to the identification of all standard parts and material used during any maintenance. This practice may limit safety and industrial risks in the case where a batch is recalled by the manufacturer. Such record does not need to be transmitted to the owner/operator/CAMO. See below figure

Finally, we in digital world, so it’s preferable to use digital software for all record. the software record system has many benefits than old fashion record (paper record), it gives you more control, ease the tracking process, searchable, can make better decision by making data analysis easily and ton of other benefits than paper record.

References:

           1- EASA.

           2-SOFEMA

Finally , if you want add extra information ,question or query we like to hear in the below comment

Definition

A Service Bulletin SB is document released by manufacturers of product like aircraft, engines, APU, landing gear, appliance or any other components.

What is the purpose behind releasing SB?

The purpose of SB is to communicate with operators for details of modifications, new product release which can be embodied in aircraft.

Service Bulletin SB may issue by the manufacturer to:

• Fix safety issue (Mandatory & Alert SB)
• Avoid potential maintenance errors.
• Increase product reliability.
• Ease product maintenance ability.
• Add a new feature.
• Introduce a wholly new product exchange old one.
• Enhance aircraft, engine or any other product design.
• Enhance aircraft, engine or any other product performance.
• A modification which extend product life.

Service Bulletin SB document structure:

SB document structure may vary from manufacturer to another, but all SB should contain the main titles as it’s important to understand and comply with SB.

The main SB document structure:

• Effectivity:

In this section the manufacturer discus which aircraft, component, serial numbers or part numbers which will apply this SB on.

• Concurrent requirements
• Reason:

Discuss the reason of issuance, and the importance level of the SB also what the operator gain from complying with this SB

• Description:

General description of what to do to execute the service bulletin

• Compliance:

This section gives if required to execute the SB in a certain time frame, and if there are SB’s or AD’s in compliance with this SB

• Approval

This section discusses the approval level of the SB

• Manpower:

Manpower required to complete and execute the SB task in details

• Weight and balance changes:

Tell the operator if the aircraft weight will be affected by executing this SB.

• Material Information:

Discusses the material required availability, support information, parts necessary for each aircraft and prices.

• Tool and Kit Information

The tools, special tools and kits required to carry out the SB task

• Accomplishment Instructions:

Instruction needed to complete and carry out SB tasks including subtasks and job setup and preparation and may refer to Aircraft Maintenance Manual AMM or any other standard manual.

What are the categories/classifications /types of SB?

SB Category differs from manufacturer to another, but sometimes to standardize the engineering work and ease the decision-making process, the CAMO engineering put their category and classification with consistence with different manufacturer classifications.

If a service bulletin is not an alert service bulletin, mandatory or a bulletin referenced in an AD, it becomes optional and may or may not be incorporated by the operator.

Here will browse some of famous manufacturers service bulletin categories /classification/types:

· Boeing SB types:

Boeing classifies Service bulletin to two main types then under these two other types as you will see in below classification,

   a- Change Type:

           1)      Master Change.

           2)      Miscellaneous Retrofit.

           3)      Other.

          4)      Production Revision Record.

   b- Product Safety Type:

          1)      Alert.

          2)      Standard.

         3)      Unusually Significant.

Of course, the importance of safety type higher than change type as you can guess, but here I want to draw your attention in some points

• Safety alert SB, in this type of service bulletin SB, you will find the “ALERT “phrase at the top of each page, and of course, this type is incorporated with AD issued by FAA or possibly will release an AD to make task compliance and time frame mandatory.
• Significant safety issue SB, in this type of service bulletin SB, you will find “SPECIAL ATTENTION “phrase in the top, also this type of SB usually Boeing recommend each aircraft operator to examine this SB immediately, also may recommend time frame to complete and the FAA possibly will release an AD for this SB type

· Pratt & Whitney:

Thank you “Pratt & Whitney” for making it organized and simple to understand, as you can see in their Canada website.

The following P&WC compliance guidelines apply to service bulletins issued or revised after August 8, 1998.

Also, they make a group for compliance of the service bulletin as you can see in below table:

· GE SB category classification

GE Service Bulletins are issued with different compliance categories and recommendation statements to assist an operation/shop in assessments of the Service Bulletin priority.

Category 1
 
Usual Statement: Do before a subsequent flight or before XX hours, YY cycles, or specific end date or specific interval. 
 
Explanation: Compliance is mandatory and is the result of FAA action - AD, NPRM, or pending AD. This category does require action within a specified time frame and must be complied with on all engines presently in the shop. 
 
Category 2
 
Usual Statement: Do as soon as possible without effect on revenue service or before XX hours, YY cycles, or specific end date or specific interval. 
 
Explanation: Compliance is recommended based on GE technical evaluation and when an aircraft can stay at a line station or maintenance base with the capability to do the procedure. Justification for an hour, cycle, and end date requirements will be based on technical considerations only(safety, risk analysis, etc). This category may cause non-routine operator action and must be complied with on all engines presently in the shop.
 

Category 3
 
Usual Statement: Do at the next shop visit of the engine or module. 
 
Explanation: Compliance is necessary regardless of shop visit reason. Disassembly of engine or module may be required to incorporate bulletin. Incorporation of this SB will enhance engine reliability and reduce the potential for operation disruptions. May cause further disassembly than planned.

Category 4
 
Usual Statement: Do when the area is exposed. 
 
Explanation: Technical evaluation indicates that incorporation of this SB may enhance engine operational reliability or improve time on-wing. Disassembly of a module to piece part may be required to incorporate this bulletin. 
 
Category 5
 
Usual Statement: Do as soon as the affected part is removed from the engine 
 
Explanation: Technical evaluation indicates that the incorporation of this SB is expected to improve (reduce) maintenance costs. This SB should be incorporated when the part is removed from the engine for other reasons. 
 
Category 6
 
Usual Statement: Do when the part is routed for repair 
 
Explanation: Do when the affected part is being routed for repair. Incorporation of this SB should improve maintenance costs in the future.  

Category 7
 
Usual Statement: Do at customer convenience/option 
 
Explanation: An alternate configuration/part is being introduced into production that may have a different appearance or may require unique assembly or maintenance practices. 
 
Category 8
 
Usual Statement: Spare parts information 
 
Explanation: Use for release/introduction of spare parts that are fully interchangeable and are not anticipated reliability or maintenance costs improvements. 
 
Category 9
 
Usual Statement: Information only 
 
Explanation: Issued to announce specific name brand information (approved oils, etc.) or for administrative purposes. 

Frequently asked questions FAQ about SB:

• What is "Alert SB"? Is the operator have to comply with?

Alert service bulletins are issued by the manufacturer when a certain condition exists that may be a safety-related item as a proposal to just a product improvement. Until here the operator has the right to not comply with, but these SB's usually result in the FAA/EASA issuing an AD. The AD will reference the alert service bulletin as a method of compliance with the AD airworthiness directive.

• Do I have to comply with a "mandatory SB" Service Bulletin?

As per EASA site” Through the DOA (Design Organization Approval) oversight process, the Agency promotes that TC/STC holders designate a Service Bulletin (SB) as mandatory only if it is known to them that this SB will also be covered by an AD. In all other cases, the TC/STC holder should use a term like ’highly recommended ‘(or equivalent). However, this is not yet common practice and there are still cases where an SB is termed ’mandatory ‘by the TC/STC holder, although no AD is to be issued. The Agency has no legal tools to prohibit the use of the word ‘mandatory’ by TC/STC holders, but EASA Certification Memorandum CM-21.A-J-001 has been issued to provide advice and guidance on this subject.

The case of an SB for which an AD has been issued, irrespective of whether it is designated by the TC/STC holder as ‘mandatory’, ‘alert’ or ‘highly recommended’, is clear: these are part of the Mandatory Continuing Airworthiness Instructions and must be applied in all cases.

The case of SBs designated as ‘mandatory’, ‘alert’ or ‘highly recommended’ by the TC/STC holder for which no AD has been issued is more complex and the following cases should be considered:

• The TC/STC holder subsequently includes such SB (e.g. repetitive inspection instructions) in the manufacturer maintenance program (Maintenance Review Board Report (MRBR) or Manufacturer Recommended Program) for the aircraft concerned. In this case, the SB under consideration will need to be included in the aircraft maintenance program as defined in Commission Regulation (EU) No 1321/2014, M.A.302(d) and (g) (see also AMC M.A.302(d)) to ensure compliance with instructions for continuing airworthiness issued by the TC/STC holder.
• The TC/STC holder does not include such SB in the manufacturer maintenance program (MRBR or Manufacturer Recommended Program) for the aircraft concerned. In this case, the final decision to apply such SB lies with the owner/operator or contracted CAMO, as M.A.302(g) does not apply.
• The TC/STC holder issues an SB defining a modification, the related embodiment instruction and the relevant scheduled maintenance requirements, where these may or may not be subsequently included in the manufacturer maintenance program (MRBR or Manufacturer Recommended Program) for the aircraft concerned. In case the SB will not be included in the manufacturer maintenance program, the final decision to apply it or not lies with the owner/ operator or contracted CAMO. If the final decision is to apply the SB, then the aircraft maintenance program needs to be updated to include the scheduled maintenance requirements.

Finally, in relation to points 2. and 3. above, for all non-mandatory modifications and/or inspections, including SBs classified by the TC/STC holder as ‘mandatory’, ‘alert’ or ‘highly recommended’ and not covered by a corresponding AD, for all large aircraft, or aircraft used in commercial air transport, an embodiment policy is to be established, as required by M.A.301(7.). That policy should then result in a substantiated (and recorded) operator’s decision for each SB to apply it, or not.”

Finally , if you want add extra information ,question or query we like to hear in the below comment

Continuing Airworthiness are the processes keep the aircraft in a condition where it remains airworthy throughout its life (technically fit for safe flight)

“All of the processes ensuring that, at any time in its life, an aeroplane complies with the technical conditions fixed to the issue of the Certificate of Airworthiness and is in a condition for safe operation"

Source: ICAO Airworthiness Manual [ICAO, 2014]

Airworthiness Responsibility:

It is useful to compare Continued and Continuing Airworthiness and know the responsible for as they are sometimes make some confusion.

Continued Airworthiness

Sometimes called also Type Airworthiness or Initial Airworthiness

Definition: “All the actions associated with the upkeep of a type design and the associated approved data through life.” - Source MAA02 glossary [MAA, 2016]

Responsibility: The ultimate responsibility for continued airworthiness is the State of Design - ICAO Annex 8

Continuing Airworthiness

Definition : “All of the processes ensuring that, at any time in its operating life, the aircraft complies with the airworthiness requirements in force and is in a condition for safe operation”

Responsibility: The program to achieve continuing airworthiness is a matter for the State of Registry. (Responsibility of the aircraft operator -owner / lessee – under supervision and maintenance program approval from the state of registry)

Continuing Airworthiness Management Organization (CAMO)

For operators based in EU nations, and others who choose to follow EASA regulations, a Continuing Airworthiness Management Organization (CAMO) must be in place. This is an approved organization responsible for implementation of continuing airworthiness management tasks. EASA Part M subpart G

CAMO Responsible:

According to EC 216/2008 Annex IV Section 6 [EC, 2008], the owner or – if designated by contract - the lessee is responsible for the continuing airworthiness of an aircraft and shall ensure that no flight takes place unless:

• The aircraft is maintained in an airworthy condition, and;
• Any operational and emergency equipment fitted is correctly installed and serviceable or clearly identified as unserviceable, and;
• The airworthiness certificate remains valid, and;
• The maintenance of the aircraft is performed in accordance with the Approved Maintenance Program as specified in Part M.A.302.

Reference should also be made to M.A 201 in EASA Part M [EC, 2014], which gives more detail concerning the responsibilities for continuing airworthiness. For operators based outside the EU, for whom EASA regulations do not apply, continuing airworthiness is still managed in a controlled manner but the regulations are within the rules for the operator. Although the owner bears the legal responsibility for continuing airworthiness, there is very much a shared responsibility between:

• The aircraft Type Certificate Holder (TCH) - Designer / Manufacturer
• Commercial Air Transport (CAT) Operators
• Aircraft Owner
• Maintenance Organization
• Authorized Persons e.g. Licensed Aircraft Engineers
• Regulators i.e. Airworthiness Authorities

CAMO Responsibility:

For each of its aircraft, the approved CAMO is required to carry out the following functions. Although these are drawn from EASA Part M, Sub Part G M.A.708 [EC, 2014], the activities would be similar to those required of any operator:

1. Develop and control Approved Maintenance Program for the aircraft managed including any applicable reliability program
2. Present the aircraft Maintenance Program and its amendments to the competent authority for approval.
3. Manage the approval of modification and repairs,
4. Ensure that all maintenance is carried out in accordance with the Approved Maintenance Program and released in accordance with M.A. Subpart H [Certificate of Release to Service (CRS)]
5. Ensure that all applicable ADs and operational directives with a continuing airworthiness impact, are applied
6. Ensure that all defects discovered during scheduled maintenance or reported are corrected by an appropriately approved maintenance organization,
7. Ensure that the aircraft is taken to an appropriately approved maintenance organization whenever necessary,
8. Coordinate scheduled maintenance, the application of ADs, the replacement of service LLP, and component inspection to ensure the work is carried out properly
9. Manage and archive all continuing airworthiness records and/or operator's technical log.
10. Ensure that the mass and balance statement reflects the current status of the aircraft.

Continuing Airworthiness is therefore not just the maintenance of aircraft and equipment, but also involves monitoring performance of products in service. This will include recording service difficulties to assess significance with respect to safety and airworthiness for the specific aircraft/product involved and for similar aircraft/products. Timely response is required where airworthiness is affected, which means devising and provisioning rectification action, and promulgating the necessary information to restore safety levels.

Inspection methods and intervals, repair actions, modifications and timescales are all part of Continuing Airworthiness, as are feedback to design/production and formal airworthiness review (or Airworthiness Review Certificate, ARC).

References:

• EASA.