The Age Old Question

Are mandatory service bulletins really mandatory?

The second two bullets listed from AC 20-77A apply to aircraft operated as an air carrier. Let me explain, AAIP’s are called for under 135.419, and a continuous airworthiness maintenance program is what is used for larger air carrier aircraft, (10 seats or more). An Operation Specification (OpSpecs), referred to in the last bullet item is required in order to operate as an air carrier. So service bulletins can also be mandated by way of air carrier regulations.

Required by regulation
Another reference document geared more toward the FAA safety inspectors clearly states that service bulletins must be required by a regulation in order to be mandatory. The document is FAA Order 8620.2A issued Nov. 5, 2007.

FAA Order 8620.2A paragraph 6(b): . . . although § 43.13(a) does not specifically address SB’s or SL’s, an OEM may legitimately incorporate an SB or SL into one of its maintenance manuals by reference. If it does so, the data specified, and the method, technique, or practice contained therein, may be acceptable to the Administrator. However, unless any method, technique, or practice prescribed by an OEM in any of its documents is specifically mandated by a regulatory document, such as airworthiness directive (AD), or specific regulatory language such as that in § 43.15(b), those methods, techniques, or practices are not mandatory.

Service bulletin references added to the manufacturer recommended inspection program for the aircraft are not mandatory unless they are tied specifically to a regulation. If the manufacturer wants to add a new requirement to its inspection program it can use its manual revision system to implement changes to its inspection program within the maintenance manual itself.

So, basically mandatory bulletins are just not mandatory on their own account. They must be supported further by some sort of airworthiness measure established or approved by the FAA. For any action to be mandatory in nature it must have a legal purpose. The regulations are written by the FAA to ensure that the aviation community stays within the boundaries of the actual law. For a service bulletin, or any requirement issued by the manufacturer for that matter, to be required for airworthiness compliance we must be able to trace it back to a regulation.

Joe Hertzler is the CEO and co-founder of Avtrak Inc., provider of the industry’s first Internet-based and compliance-focused maintenance tracking service — Avtrak GlobalNet. Avtrak has earned a solid reputation for having the most comprehensive and easy-to-use compliance management system and service in the industry. Avtrak’s GlobalNet technology is the engine behind Gulfstream and Sikorsky HelotracII. GlobalNet is the system of choice for many operators of more than 140 models including Bombardier, Hawker/Beechcraft, and Dassault Falcon aircraft.

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