Operational Control

How maintenance fits in

When an aircraft flies, it accumulates time in hours and minutes, and when it lands, it adds additional landings or cycles; as the days go by, we move closer and closer to items scheduled on a calendar basis. The maintenance status of the aircraft is dynamic. In order to have a clear understanding of the maintenance status of the aircraft (required by 91.417 and 135.439, respectively), the pilot must know when all of the required maintenance items were last accomplished and more importantly, when they are next due. It’s as simple as knowing without a doubt that you will be able to complete the planned trip without overflying any required scheduled maintenance item.

The term scheduled maintenance also includes airworthiness directives. Whether they are recurring or not, airworthiness directives must be accomplished as outlined in the airworthiness directive itself, if it’s applicable to the aircraft or any of the aircraft components. While a pilot or entity is planning for the operation of an aircraft, whether it is for hire or just for fun, the aircraft must be airworthy. In order to be airworthy, the aircraft, as configured, must be in compliance with all federal regulations, have all scheduled maintenance items accomplished, and be properly configured for the intended flight.

Airworthiness directives
The FAA recently announced that it intends to come down on the operational control of aircraft operated under Part 91. This made me laugh. Part 135 operators are specifically bound to “operational control” by regulation, which under Part 135, includes several Part 135 specific requirements that will not be required under Part 91.

§ 135.77 Responsibility for operational control.

Each certificate holder is responsible for operational control and shall list, in the manual required by §135.21, the name and title of each person authorized by it to exercise operational control.

Under Part 91 “operational control” has always been delegated to the owner/operator.

§ 91.3 Responsibility and authority of the pilot in command.

(a) The pilot in command of an aircraft is directly responsible for, and is the final authority as to, the operation of that aircraft.

In addition to being the final authority as to the Part 91 operation of that aircraft, the owner or operator is also responsible for maintaining the airworthiness of an aircraft.

§ 91.403 General

(a) The owner or operator of an aircraft is primarily responsible for maintaining that aircraft in an airworthy condition, including compliance with Part 39 of this chapter.
FAA Order 8900.4 includes the following guidance related to the maintenance requirements for an aircraft and operational control.
8900.4 Appendix A, Section 1269, Paragraph C.

(2) Maintaining operational control requires the Part 135 operator to, among other things:

(h) Ensure that an aircraft is airworthy and is in compliance with the conditions and limitations specified by the FAA-approved inspection/maintenance program for the certificate holder before it is allowed to depart on a Part 135 flight.

(3) … Thus, each Part 135 operator must have an organization and system in place — including all the necessary tools such as recordkeeping and management surveillance/oversight — that is sufficient to ensure that all functions have been accomplished before a flight or a series of flights is authorized to depart …

Maintenance tracking
In order to have a handle on the scheduled maintenance requirements for an aircraft, the aircraft owner or operator under Part 91 or Part 135 should take advantage of a service for maintenance compliance tracking.

There are a few maintenance tracking services available but, as you might guess, I am a bit biased to the Avtrak GlobalNet system. Regardless of your choice, an adequate system will, in real time, keep the owner or operator up to speed as maintenance requirements change for their aircraft, regardless of the inspection and maintenance program. It will be simple to use and will provide a good set of tools for the planning of scheduled maintenance. If you are not currently using a maintenance tracking service provider, consider the following:

  1. Do you know if all of your aircraft’s maintenance requirements have been met?
  2. Are you certain that only the necessary maintenance is being accomplished?
  3. Do you know what the next inspection requirement due on your aircraft is and about when it will be due?
  4. Have you accomplished all mandatory service information recommended by the aircraft manufacturer?
  5. Are all applicable Airworthiness Directives properly recorded in the maintenance records?
  6. Are you including all of the “instructions for continued airworthiness” that are required by the modifications and alterations on your aircraft?
  7. Are the life-limited parts in your engines going to make it to the next major engine event?

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