Are Mandatory Service Bulletins Required To Be Completed

Are they actually mandatory?

Past Joe Escobar

Is a manufacturer's mandatory service message mandatory or not? This topic pops upwardly in hangars regularly and tends to polarize A&P'due south and IA's akin. They either experience strongly that they are or they are not (with the majority assertive they are not). In that location does not seem to be a middle ground.

Looking to the by
Perhaps the best way to start out this discussion is get a perspective of past regulations and conformance practices. A Charles Taylor recipient from my area shared the following with me about his experiences as an A&E mechanic:

What checklist to use?

According to xiv CFR Part 43, a mechanic or IA needs to use a checklist when performing an annual or 100-hr inspection. If the aircraft manufacturer has a checklist available, must information technology be used or can a checklist based on Appendix D of part 43 be used? Technically, according to the regulation either ane can be used. But consider this: A Businesswoman had a gear upwards landing. The investigation revealed a failed gearbox. The maintenance records indicated that a checklist based on Appendix D of Part 43 was used to perform contempo annuals. The manufacturer's checklist shows the mechanic how to inspect and service the gearbox, while Appendix D of Part 43 does not. The gearbox had more than than 3,200 hours without any documented servicing. TBO on the gearbox is 2,000 hours.

"I would get to work almost ii hours before everyone else, so I stopped past the post office and picked up the mail service. The CAA sent out an Advertisement note to registered owners of the same type airplane whenever whatsoever serious defect was discovered. The schoolhouse I worked at had a subscription to the current aircraft specifications from the CAA, and service information from each of the aeroplane manufacturers, so we could keep our airplanes electric current. I would sort it all out and read everything with my morning coffee. By the fourth dimension I was gear up for my 2d cup of coffee, the boys had the airplanes out on the line and I would go out and check each and every one of them before they were flown every day.

I would immediately accept care of any write-upwardly a pilot made, and every 25 hours of flight time I would inspect the engine, clean and gap the spark plugs, change the oil and make clean the screen, bank check the tires for wear and proper pressure, and check and lubricate the flying controls. If we received an AD in the mail, I would immediately do whatever the AD said.

Once every 12 months I would bring each airplane into the hangar for a periodic inspection, a very detailed inspection and specification update. I thoroughly cleaned the airplane inside and out, complied with all the electric current service bulletins and verified that the plane conformed to its electric current aircraft specifications. When I was done, I would set a periodic inspection report for the CAA safety inspector and he would come up out and effect the airplane a new airworthiness certificate."

That Charles Taylor recipient was the source of all knowledge at the small airport where he worked. Anybody looked upwards to him and respected his judgment, especially the pilots. Only he could say when an airplane was ready to fly. He always says, "Base your decisions on regulations, not on someone else'south opinion."

Influences on perception
It is well known that our environment influences our perception. What nosotros are is based on where we were when we started learning. If you accept a look around your local FSDO, you may notice that many FAA inspectors have armed forces backgrounds. The military and major airlines are organizations. An organizational background produces organizational thinking and since the organization owns the shipping, the ownership responsibilities become functional responsibilities within the organization rather than the responsibility of ane individual.

Within the military, organizational thinking becomes authoritative thinking. There's a concatenation of control, and if y'all're non in the chain of command, y'all take no authority. Any question becomes a matter of who has the potency.

Within major airlines there are groups such as; operations, maintenance, dispatch, engineering, etc., with each group performing a specific function. Whatever question becomes a thing of who performs that function. Organizational thinking works great within organizations. It's only when organizational thinking is practical to individuals who are not part of an organization that problems arise. For a person with an organizational background, trying to recall outside the organization is like trying to drive on the left side of the route.

Some other interpretation-influencing cistron is that military machine shipping don't have airworthiness certificates. Annually conforming an aircraft to current aircraft specifications is a bizarre concept to a person with a military background. And inside the military, manufacturer'south representatives are just advisors. A recent FAA Order said manufacturer'southward service instructions are communication. Advice is optional and anything that'south both plush and optional is frequently not washed, particularly in today's environment.

The Federal Aviation Regulations are comprehensive, intentionally worded in debatable linguistic communication, and subject to interpretation. In contempo interpretations we see organizational thinking influences such every bit who has say-so and who performs that function.

Authoritative thinking vs. best maintenance practices
Administrative thinking statement - "Manufacturer's mandatory service bulletins are not mandatory unless they're referred to in an Advert."

Years ago, the FAA's position on this subject was on a case-by-instance basis. Recently the FAA has recognized a need for standardization and invented Instructions for continued airworthiness. When a manufacturer finds a problem with its product through service experience, information technology places a service bulletin in the instructions for continued airworthiness, which makes the service bulletin mandatory.

Lets read some regulations that may utilise to manufacturers' mandatory service bulletins. The Federal Aviation Act of 58, The Standard Airworthiness Certificate, and Part 21 say standard airworthiness is conformity to the blazon design and condition for safe operation (Ref. 21.183). But type design is discipline to change. Certification basis is grandfathered. Lets look at the regulation for type design changes.

§21.99 Required pattern changes (b) In a instance where there are no current unsafe atmospheric condition, but the Administrator or the holder of the blazon certificate finds through service experience that changes in type design will contribute to the prophylactic of the product, the holder of the type certificate may submit appropriate design changes for approval. Upon approval of the changes, the manufacturer shall make data on the design changes bachelor to all operators of the same type of production.

The manufacturer shall brand information on the design changes available to all operators of the aforementioned type of product. The manufacturer does so with a mandatory service message.

§43.11 Content, form, and disposition of records for inspections . . .
(b) Listing of discrepancies and placards. If the person performing any inspection required by Part 91 or 125 or §135.411(a)(1) of this chapter finds that the aircraft is unairworthy or does non see the applicable blazon certificate data, airworthiness directives, or other approved data upon which its airworthiness depends, that person must give the owner or lessee a signed and dated listing of those discrepancies.

If a mechanic inspects an shipping, and at the time of that inspection, discovers that the aircraft does not conform to the type pattern, or other canonical data upon which its airworthiness depends, he or she must list information technology equally a discrepancy. Inside the military, aircraft inspections are status inspections, and conformity to the type design is nonexistent. Within major airlines, their fleet management programs often make the manufacturer's mandatory service bulletins wait like yesterday's news, and are given to engineering for evaluation. But within full general aviation maintenance, the manufacturer is the merely source available for authoritative maintenance data, which must be understood (Ref. 65.81) and must be followed (Ref. 43.thirteen).

Best maintenance practices argument - Complying with mandatory service bulletins is common sense. Most mandatory service bulletins become AD notes in due fourth dimension.

Organizational thinking vs. best maintenance practices
An organizational thinking statement - "AD compliance is a maintenance function." From within an arrangement, Advertisement compliance is a maintenance function. Without an organization, Advertisement compliance is an owner or operator responsibleness. Lets look at the regulations.

§39.3 General. No person may operate a product to which an airworthiness directive applies except in accordance with the requirements of that airworthiness directive.

§91.403 General. (a) The owner or operator of an aircraft is primarily responsible for maintaining that shipping in an airworthy condition, including compliance with Part 39 of this chapter.

§43.11 Content, form, and disposition of records for inspections . . .
(b) Listing of discrepancies and placards. If the person performing whatsoever inspection required by Part 91 or 125 or §135.411(a)(1) of this chapter finds that the aircraft is unairworthy or does not meet the applicative blazon document data, airworthiness directives, or other approved data upon which its airworthiness depends, that person must requite the owner or lessee a signed and dated list of those discrepancies.

If a mechanic inspects an shipping, and discovers that an applicative Ad has non been complied with, he must list it as a discrepancy. And unless the Advertizement indicates compliance during that inspection, the owner or operator may take already violated Part 39.

A best maintenance practices statement - "The owner or operator is responsible for (Ref. 91.403) and tracks the current status of (Ref. 91.417) AD compliance." Even so, Ad compliance is a safe business organisation and safe is everybody's business. AD notes are freely available on the Internet and should be read by everyone agile in aviation.

In the end, the question of mandatory service bulletins depends on your perspective. Even if authoritative or organizational thinking influences your arroyo, all-time maintenance practices should exist considered when performing any inspection. Later all, it only makes common sense.