ED Decision 2023/013/R
When evaluating an alternative to a maintenance task issued or recommended by the DAH or the declarant of a declaration of design compliance, such as the extension of TBO intervals, or when considering not to include a maintenance task issued or recommended by the DAH or the declarant of a declaration of design compliance, a risk-based approach should be taken, considering aspects such as the operation of aircraft, type of aircraft, hours and years in service, maintenance of the aircraft, compensating measures, redundancy of components, etc.
The following table provides more details of aspects that should be considered:
|
Examples |
OPS approval |
HIGHER RISK: commercial operation, commercial flight training MEDIUM RISK: flight training by an association, non-commercial specialised operations (SPO) LOWER RISK: private |
Flight rules |
HIGHER RISK: instrument flight rules (IFR) MEDIUM RISK: visual flight rules (VFR) at night LOWER RISK: VFR by day |
Aircraft weight |
HIGHER RISK: Other than ELA1 MEDIUM RISK: ELA1 aircraft other than light sport aeroplanes (LSA), very light aircraft (VLA), sailplanes and powered sailplanes LOWER RISK: LSA, VLA, sailplanes and powered sailplanes |
Who manages the airworthiness of the aircraft? |
HIGHER RISK: owner LOWER RISK: CAMO/CAO |
Who maintains the aircraft? |
HIGHER RISK: pilot-owner MEDIUM RISK: independent certifying staff LOWER RISK: maintenance organisation |
Time in service (flight hours, years) |
HIGHER RISK: very high number of hours or years MEDIUM RISK: medium number of hours or years LOWER RISK: low number of hours or years |
Aircraft utilisation |
HIGHER RISK: less than 50 h per year MEDIUM RISK: around 200 h per year LOWER RISK: more than 400 h per year |
ACAM findings |
HIGHER RISK: numerous findings in ACAM or ramp inspections MEDIUM RISK: few findings in ACAM inspections LOWER RISK: rare findings in ACAM inspections |
System
redundancy |
HIGHER RISK: single-engined aircraft LOWER RISK: multi-engined aircraft |
Supplementary maintenance measures |
HIGHER RISK: no supplementary measures LOWER RISK: supplementary measures (such as oil analysis, engine data monitoring, boroscope inspections, corrosion inspections, etc.) |
Risk factor of the component failure |
HIGHER RISK: engine failure on a helicopter MEDIUM RISK: engine failure on an aeroplane LOWER RISK: sailplane, or powered sailplane |
The above information may be useful for CAMOs and CAOs when developing and approving maintenance programmes, and for the AR staff performing ARs and reviewing the effectiveness of the declared maintenance programme. It may also be useful for the owner in order to take an informed decision before introducing deviations from the recommendations issued by the DAH or the declarant of a declaration of design compliance. Nevertheless, as allowed by ML.A.302(c)(7) and explained in GM ML.A.302, when the owner issues a declaration for the maintenance programme, it does not need to justify such deviations.
Risk-based evaluation of maintenance task alternatives per AMC1 ML.A.302(c), considering operational, design, and maintenance factors to guide CAMOs, CAOs, and owners.
* Summary by Aviation.Bot - Always consult the original document for the most accurate information.
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