On February 23, 2010, the Federal Aviation Administration (FAA) issued its final response to a Customer Service Initiative (CSI) request filed by ARSA on behalf of Erickson Air-Crane nearly six years ago (the program is now known as the Consistency and Standardization Initiative). The FAA’s CSI letter addresses the relationship between technical data (i.e., engineering information) on the one hand, and methods, techniques and practices for performing maintenance and alterations on the other.
Concurring with ARSA’s interpretation of the pertinent rules, the FAA concluded that the “how-to” instructions for performing maintenance and alterations contained in manufacturer’s manuals is already supported by approved technical data when such approval is required under sections 65.95(d)(1), 121.379(b), 135.437(b) and 145.201(c) (i.e., when performing major repairs and alterations). Because the technical data was approved under the design change procedures of part 21 there is no need to have the data re-approved via a field approval (block 3 of a Form 337), DER approval (Form 8110-3) or approval by another authorized designee. The FAA’s decision applies to thousands of existing manufacturers’ maintenance and overhaul manuals including Structural Repair Manuals, Aircraft Maintenance Manuals, Engine and Propeller Maintenance Manuals and Component Maintenance Manuals.
The FAA also acknowledged the fact that a Structural Repair Manual (SRM) that has been FAA-approved is of no particular significance for purposes of complying with sections 65.95(d)(1), 121.379(b), 135.437(b) and 145.201(c) since in the absence of special circumstances such as an Airworthiness Directive or Airworthiness Limitations, there is no requirement for a maintenance manual to be FAA-approved. In summary, these regulations require that the technical data be approved when performing a major repair or alteration and this requirement is fulfilled by following the methods, techniques and practices contained in the pertinent SRM or other manufacturer’s manual regardless whether the manual itself has been FAA-approved.
The FAA’s response may be found here.
