Manufacturer's Instructions: How the maintenance should be performed

When it comes to performing maintenance on an aircraft it is a little different than what we do when we need to repair our car.


How it should be performed

So, we covered briefly who can work on the aircraft and comparatively, who can approve the work for return to service. Next I want to talk about how the maintenance is to be performed, meaning the instructions to be used to perform the maintenance. In referring to "how the maintenance is performed" I am talking about what we call the three T's: talent, technical data, and tools.

Obviously, being in the compliance business in a regulated industry the three T's have a regulatory origin. Let me explain. The first T, talent, refers to the requirement that all persons who perform maintenance on a U.S. registered aircraft must possess the appropriate knowledge and experience to do that maintenance, or be supervised by a person who possesses as much.

14 CFR Part 65.81 - General privileges and limitations: (a) A certificated mechanic may perform or supervise the maintenance, preventive maintenance, or alteration of an aircraft or appliance, or a part thereof, for which he is rated (but excluding major repairs to, and major alterations of, propellers, and any repair to, or alteration of, instruments), and may perform additional duties in accordance with ??65.85, 65.87, and 65.95. However, he may not supervise the maintenance, preventive maintenance, or alteration of, or approve and return to service, any aircraft or appliance, or part thereof, for which he is rated unless he has satisfactorily performed the work concerned at an earlier date. If he has not so performed that work at an earlier date, he may show his ability to do it by performing it to the satisfaction of the Administrator or under the direct supervision of a certificated and appropriately rated mechanic, or a certificated repairman, who has had previous experience in the specific operation concerned.

The fact that a certain level of talent is required is pretty well-known and adhered to. When a technician runs across something that he/she doesn't understand they will more than likely find help before moving forward rather than risk safety. A problem area however lies in the second and third T's.

Current technical data

The second T, technical data, refers to the requirement that all maintenance must be performed in accordance with the technical data supplied by the manufacturer of that equipment.

14 CFR Part 43.13 - Performance rules (general): (a) Each person performing maintenance, alteration, or preventive maintenance on an aircraft, engine, propeller, or appliance shall use the methods, techniques, and practices prescribed in the current manufacturer's maintenance manual or Instructions for Continued Airworthiness prepared by its manufacturer, or other methods, techniques, and practices acceptable to the Administrator . . .

The current manufacturer's maintenance manual means just that. The only way to know that you have the current manufacturer's maintenance manual is to hold an acceptable subscription to that manual and use that manual. Using a third-party work card or an outdated photocopy of the maintenance manual instructions is simply illegal. It is an unsafe disservice to your customer (the aircraft owner) and an unnecessary liability to you.

Why is it a problem? The manufacturers' maintenance manuals and instructions for continued airworthiness are dynamic and always in flux. To be sure you are using the most recent instructions (as required by the regulation) it is critical to use the actual maintenance instructions directly from the manufacturer. And with advancements in technology, accessing the real "McCoy" quickly is easier than ever.

I remember when I learned how to change the Stab Actuator on a Lear 35. I made copies of the maintenance manual section covering the procedures so I would have them to refer to while I was being trained. When we were done I felt compelled to put those copies in my toolbox for future reference. I had made some notes on it and wanted to look it over again a few times when I had a spare moment. The problem was, that document was then in my toolbox and too easy to use on the next job. Not to mention that the FAA frowned seriously on any copies of maintenance instruction in my toolbox - as I found out.

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