FAA Revises OpSpec/MSpec D104 Templates for Additional Maintenance on Emergency Equipment

The revision aims to clarify that emergency equipment does need to be listed in the D104, even if already present in a manufacturer’s maintenance document.

The Federal Aviation Administration (FAA) has published an update to the maintenance requirements for emergency equipment on aircraft, focusing on the operations specification (OpSpec)/management specification (MSpec) D104 templates.

Changes to OpSpec/MSpec D104 templates in the updated requirements include:

  • Adjusting wording to reduce ambiguity
  • Adding clarifications
  • Renaming to “MSpec D104, Emergency Equipment”
  • Removing “nine seats or less” from Title 14 CFR part 91 subpart K
  • Deleting additional maintenance wording that adds confusion

The items that fall under these rule changes are emergency equipment like:

  • Fire extinguishers
  • Oxygen bottles
  • Military-manufactured equipment
  • Foreign-manufactured equipment

The primary reason for these revisions is to reduce confusion stemming from the previous version that states:

Certificate holders/program managers are only required to list emergency equipment that is maintained to limitations and provisions other than what the manufacturer’s maintenance documents recommend.

According to the FAA, “This led to the misunderstanding that if an item of emergency equipment is in a manufacturer’s maintenance document, then the item of emergency equipment did not have to be listed in D104.”

Interested readers can review the entire revision in the FAA’s online document library.

About the Author

Emily Gorski

Editor | Aircraft Maintenance Technology

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