Appendix 8 to AMC 20-6B – Continuing airworthiness
considerations
ED Decision 2021/006/R
1. APPLICABILITY
The requirements of this Appendix apply to the continuing airworthiness management organisations (CAMO) managing the aircraft for which an ETOPS operational approval is sought, and they are to be complied with in addition to the applicable continuing airworthiness requirements of Part-M. They specifically affect:
a. Occurrence reporting;
b. Aircraft maintenance programme and reliability programme;
c. Continuing airworthiness management exposition;
d. Competence of continuing airworthiness and maintenance personnel.
2. OCURRENCE
REPORTING
In addition to the items generally required to be reported in accordance with AMC 20-8, the following items concerning ETOPS should be included:
a. in-flight shutdowns;
b. diversion or turn-back;
c. un-commanded power changes or surges;
d. inability to control the engine or obtain desired power; and
e. failures or malfunctions of ETOPS significant systems having a detrimental effect to ETOPS flight.
Note: Status messages, transient failures, intermittent indication of failure, messages tested satisfactorily on ground not duplicating the failure should only be reported after an assessment by the operator that an unacceptable trend has occurred on the system.
The report should identify as applicable the following:
a. aircraft identification;
b. engine, propeller or APU identification (make and serial number);
c. total time, cycles and time since last shop visit;
d. for systems, time since overhaul or last inspection of the defective unit;
e. phase of flight; and
f. corrective action.
The competent authority and the (S)TC holder should be notified within 72 hours of events that are reportable through this programme.
3. MAINTENANCE
PROGRAMME AND RELIABILITY PROGRAMME
The quality of maintenance and reliability programmes can have an appreciable effect on the reliability of the propulsion system and the ETOPS significant systems. The competent authority should assess the proposed maintenance and reliability programme’s ability to maintain an acceptable level of safety for the propulsion system and the ETOPS significant systems of the particular airframe/engine combination.
3.1 MAINTENANCE PROGRAMME
The maintenance programme of an aircraft for which ETOPS operational approval is sought, should contain the standards, guidance and instructions necessary to support the intended operation. The specific ETOPS maintenance tasks identified by the (S)TC holder in the configuration, maintenance and procedures document (CMP) or equivalent should be included in the maintenance programme and identified as ETOPS tasks.
An ETOPS maintenance task could be an ETOPS specific task or/and a maintenance task affecting an ETOPS significant system. An ETOPS specific task could be either an existing task with a different interval for ETOPS, a task unique to ETOPS operations, or a task mandated by the CMP further to the in-service experience review (note that in the case ETOPS is considered as the baseline in the development of a maintenance program, no ‘ETOPS specific’ task may be identified in the MRB).
The maintenance programme should include tasks to maintain the integrity of cargo compartment and pressurisation features, including baggage hold liners, door seals and drain valve condition. Processes should be implemented to monitor the effectiveness of the maintenance programme in this regard.
3.1.1 PRE-DEPARTURE SERVICE CHECK
An ETOPS service check should be developed to verify the status of the aeroplane and the ETOPS significant systems. This check should be accomplished by an authorised and trained person prior to an ETOPS flight. Such a person may be a member of the flight crew.
3.2 RELIABILITY PROGRAMME:
3.2.1 GENERAL
The reliability programme of an ETOPS operated aircraft should be designed with early identification and prevention of failures or malfunctions of ETOPS significant systems as the primary goal. Therefore the reliability programme should include assessment of ETOPS significant systems performance during scheduled inspection/testing, to detect system failure trends in order to implement appropriate corrective action such as scheduled task adjustment.
The reliability programme should be event-orientated and incorporate:
a. reporting procedures in accordance with Section 2: Occurrence reporting
b. operator’s assessment of propulsion systems reliability
c. APU in-flight start programme
d. Oil consumption programme
e. Engine condition monitoring programme
f. Verification programme
3.2.2 ASSESSMENT OF PROPULSION SYSTEMS RELIABILITY
a. The operator’s assessment of propulsion systems reliability for the ETOPS fleet should be made available to the competent authority (with the supporting data) on at least a monthly basis, to ensure that the approved maintenance programme continues to maintain a level of reliability necessary for ETOPS operations as established in Chapter II Section 6.3.
b. The assessment should include, as a minimum, engine hours flown in the period, in-flight shutdown rate for all causes and engine removal rate, both on a 12-month moving average basis. Where the combined ETOPS fleet is part of a larger fleet of the same aircraft/engine combination, data from the total fleet will be acceptable.
c. Any adverse sustained trend to propulsion systems would require an immediate evaluation to be accomplished by the operator in consultation with the competent authority. The evaluation may result in corrective action or operational restrictions being applied.
d. A high engine in-flight shutdown rate for a small fleet may be due to the limited number of engine operating hours and may not be indicative for an unacceptable trend. The underlying causes for such an increase in the rate will have to be reviewed on a case-by-case basis in order to identify the root cause of events so that the appropriate corrective action is implemented.
e. If an operator has an unacceptable engine in-flight shutdown rate caused by maintenance or operational practices, then the appropriated corrective actions should be taken.
3.2.3 APU IN-FLIGHT START PROGRAMME
a. Where an APU is required for ETOPS and the aircraft is not operated with this APU running prior to the ETOPS entry point, the operator should initially implement a cold soak in-flight starting programme to verify that start reliability at cruise altitude is above95 %.
Once the APU in-flight start reliability is proven, the APU in-flight start monitoring programme may be alleviated. The APU in-flight start monitoring programme should be acceptable to the competent authority.
b. The Maintenance procedures should include the verification of in-flight start reliability following maintenance of the APU and APU components, as defined by the OEM, where start reliability at altitude may have been affected.
3.2.4 OIL CONSUMPTION MONITORING PROGRAMME
The oil consumption monitoring programme should reflect the (S)TC holder’s recommendations and track oil consumption trends. The monitoring programme must be continuous and include all oil added at the departure station.
If oil analysis is recommended to the type of engine installed, it should be included in the programme.
If the APU is required for ETOPS dispatch, an APU oil consumption monitoring programme should be added to the oil consumption monitoring programme.
3.2.5 ENGINE CONDITION MONITORING PROGRAMME
The engine condition monitoring programme should ensure that a one-engine-inoperative diversion may be conducted without exceeding approved engine limits (e.g. rotor speeds, exhaust gas temperature) at all approved power levels and expected environmental conditions. Engine limits established in the monitoring programme should account for the effects of additional engine loading demands (e.g. anti-icing, electrical, etc.), which may be required during the one-engine-inoperative flight phase associated with the diversion.
The engine condition monitoring programme should describe the parameters to be monitored, method of data collection and corrective action process. The programme should reflect manufacturer’s instructions and industry practice. This monitoring will be used to detect deterioration at an early stage to allow for corrective action before safe operation of the aircraft is affected.
3.2.6 VERIFICATION PROGRAMME
The operator should develop a verification programme to ensure that the corrective action required to be accomplished following an engine shutdown, any ETOPS significant system failure or adverse trends or any event which require a verification flight or other verification action are established. A clear description of who must initiate verification actions and the section or group responsible for the determination of what action is necessary should be identified in this verification programme. ETOPS significant systems or conditions requiring verification actions should be described in the continuing airworthiness management exposition (CAME). The CAMO may request the support of the (S)TC holder to identify when these actions are necessary. Nevertheless, the CAMO may propose alternative operational procedures to ensure system integrity. This may be based on system monitoring in the period of flight prior to entering an ETOPS area.
4. CONTINUING
AIRWORTHINESS MANAGEMENT EXPOSITION
The CAMO should develop appropriate procedures to be used by all personnel involved in the continuing airworthiness and maintenance of the aircraft, including supportive training programmes, duties, and responsibilities.
The CAMO should specify the procedures necessary to ensure the continuing airworthiness of the aircraft particularly related to ETOPS operations. It should address the following subjects as applicable:
a. General description of ETOPS procedures
b. ETOPS maintenance programme development and amendment
c. ETOPS reliability programme procedures
(1) Engine/APU oil consumption monitoring
(2) Engine/APU Oil analysis
(3) Engine conditioning monitoring
(4) APU in-flight start programme
(5) Verification programme after maintenance
(6) Failures, malfunctions and defect reporting
(7) Propulsion system monitoring/reporting
(8) ETOPS significant systems reliability
d. Parts and configuration control programme
e. Maintenance procedures that include procedures to preclude identical errors being applied to multiple similar elements in any ETOPS significant system
f. Interface procedures with the ETOPS maintenance contractor, including the operator ETOPS procedures that involve the maintenance organisation and the specific requirements of the contract
g. Procedures to establish and control the competence of the personnel involved in the continuing airworthiness and maintenance of the ETOPS fleet
5. COMPETENCE
OF CONTINUING AIRWORTHINESS AND MAINTENANCE PERSONNEL
The CAMO should ensure that the personnel involved in the continuing airworthiness management of the aircraft have knowledge of the ETOPS procedures of the operator.
The CAMO should ensure that maintenance personnel that are involved in ETOPS maintenance tasks:
a. Have completed an ETOPS training programme reflecting the relevant ETOPS procedures of the operator, and,
b. Have satisfactorily performed ETOPS tasks under supervision, within the framework of the Part-145 approved procedures for Personnel Authorisation.
5.1. PROPOSED TRAINING PROGRAMME FOR PERSONNEL INVOLVED IN THE CONTINUING AIRWORTHINESS AND MAINTENANCE OF THE ETOPS FLEET
The operator’s ETOPS training programme should provide initial and recurrent training for as follows:
1. INTRODUCTION TO ETOPS REGULATIONS
a. Contents of AMC 20-6
b. ETOPS type design approval – a brief synopsis
2. ETOPS OPERATIONS APPROVAL
a. Maximum approved diversion times and time-limited systems capability
b. Operator’s approved diversion time
c. ETOPS area and routes
d. ETOPS MEL
3. ETOPS CONTINUING AIRWORTHINESS CONSIDERATIONS
a. ETOPS significant systems
b. CMP and ETOPS aircraft maintenance programme
c. ETOPS pre-departure service check
d. ETOPS reliability programme procedures
(1) Engine/ APU oil consumption monitoring
(2) Engine/APU oil analysis
(3) Engine conditioning monitoring
(4) APU in-flight start programme
(5) Verification programme after maintenance
(6) Failures, malfunctions and defect reporting
(7) Propulsion system monitoring/reporting
(8) ETOPS significant systems reliability
e. Parts and configuration control programme
f. CAMO additional procedures for ETOPS
g. Interface procedures between Part-145 organisation and CAMO
[Amdt 20/7]
[Amdt 20/21]
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