minimum eQuiPmenT LisT (meL)
VII. Special Emphasis Items: Flightcrew Training A Knowledge and understanding of ATC phraseology
4. mAinTenAnce oPeRATions
4.15. Discrepancy Management
The sophistication and complexity of aircraft used in the corporate environment matches that of any other part of the aviation spectrum. Because of this, the expertise and strong teamwork skills of both maintenance department and flight operations personnel are essential for effective resolution of aircraft /system difficulties. Without a struc- tured process of discrepancy management, several con- cerns become apparent:
• Communication between pilots and technicians regard- ing problems with an aircraft are passed verbally or not documented at all.
• When discrepancies are documented, the content and presentation of data varies greatly from flightcrew to flightcrew.
• Unclear squawks can lead to replacement parts that are incorrectly ordered.
• Write-ups are unnecessarily repeated.
• Application and interpretation of the MEL varies among pilots, technicians and the FAA.
• Intermittent discrepancies and ensuing troubleshooting lack documentation and follow-up.
4.15.1. BRieFinGs And deBRieFinGs
Briefings and debriefings are used in an effort to meet the aviation and maintenance departments’ mission statements regarding safety, cost effectiveness, professionalism, qual- ity and pride in work and a high level of internal and external customer satisfaction.
A formal briefing and debriefing process is recommended. Working groups as well as individuals benefit from discuss- ing ideas, developing action plans, identifying ownership and acquiring backup. The maintenance/flightcrew brief and debrief process is the mechanism used to bridge communi- cation gaps regarding discrepancies or issues that concern either maintenance or flight working groups.
In a briefing session, individuals who were actively involved in performing maintenance on the aircraft or any of its sub- systems should meet with the flightcrew to inform them of the maintenance action performed. This can be either corrective action for a discrepancy or routine maintenance inspections.
In a debriefing session, maintenance technicians and flightcrew members meet to acquire relevant information regarding discrepancies. Once the information is gathered, the individual leaves the debrief meeting with a complete description and understanding of the discrepancy. The underlying objective is to provide the highest level of maintenance service, thereby providing customers with safety and customer satisfaction. The use of a formalized process creates an environment for professionalism, cost effectiveness and quality improvement.
4.15.2. inoPeRATive insTRumenTs And
eQuiPmenT
In certain circumstances, relief for aircraft discrepancies may be found through FAR 91.213, which states: (a) Except as provided in paragraph (d) of this section, no
person may take off an aircraft with inoperative instru- ments or equipment installed unless the following condi- tions are met:
(1) An approved Minimum Equipment List exists for that aircraft.
(2) The aircraft has within it a letter of authorization, issued by the FAA Flight Standards district office having jurisdiction over the area in which the opera- tor is located, authorizing operation of the aircraft under the Minimum Equipment List. The letter of authorization may be obtained by written request of the airworthiness certificate holder. The Minimum Equipment List and the letter of authorization consti- tute a supplemental type certificate for the aircraft. (3) The approved Minimum Equipment List must –
(i) Be prepared in accordance with the limitations specified in paragraph (b) of this section; and (ii) Provide for the operation of the aircraft with the
instruments and equipment in an inoperable condition.
(4) The aircraft records available to the pilot must include an entry describing the inoperable instruments and equipment.
(5) The aircraft is operated under all applicable conditions and limitations contained in the Minimum Equipment List and the letter authorizing the use of the list. (b) The following instruments and equipment may not be
included in a Minimum Equipment List:
(1) Instruments and equipment that are either specifical- ly or otherwise required by the airworthiness require- ments under which the aircraft is type certificated and which are essential for safe operations under all operating conditions.
(2) Instruments and equipment required by an airworthi- ness directive to be in operable condition unless the airworthiness directive provides otherwise.
(3) Instruments and equipment required for specific operations by this part.
(c) A person authorized to use an approved Minimum Equipment List issued for a specific aircraft under part 121, 125, or 135 of this chapter shall use that Minimum Equipment List in connection with operations conducted with that aircraft under this part without additional ap- proval requirements.
(d) Except for operations conducted in accordance with paragraph (a) or (c) of this section, a person may takeoff an aircraft in operations conducted under this part with inoperative instruments and equipment without an ap- proved Minimum Equipment List provided -
(1) The flight operation is conducted in a -
(i) Rotorcraft, nonturbine-powered airplane, glider, or lighter-than-air aircraft for which a master Minimum Equipment List has not been devel- oped; or
(ii) Small rotorcraft, nonturbine-powered small air- plane, glider, or lighter-than-air aircraft for which a Master Minimum Equipment List has been developed; and
(2) The inoperative instruments and equipment are not - (i) Part of the VFR-day type certification instru-
ments and equipment prescribed in the appli- cable airworthiness regulations under which the aircraft was type certificated;
(ii) Indicated as required on the aircraft’s equipment list, or on the Kinds of Operations Equipment List for the kind of flight operation being con- ducted:
(iii) Required by 91.205 or any other rule of this part for the specific kind of flight operation being conducted; or
(iv) Required to be operational by an airworthiness directive; and
(3) The inoperative instruments and equipment are - (i) Removed from the aircraft, the cockpit control
placarded, and the maintenance recorded in ac- cordance with 43.9 of this chapter; or
(ii) Deactivated and placarded “Inoperative.” If deactivation of the inoperative instrument or equipment involves maintenance, it must be accomplished and recorded in accordance with part 43 of this chapter; and
(4) A determination is made by a pilot, who is certifi- cated and appropriately rated under Part 61 of this chapter, or by a person, who is certificated and appropriately rated to perform maintenance on the aircraft, that the inoperative instrument or equipment does not constitute a hazard to the aircraft.
An aircraft with inoperative instruments or equip- ment as provided in paragraph (d) of this section is considered to be in a properly altered condition ac- ceptable to the Administrator.
(e) Notwithstanding any other provision of this section, an aircraft with inoperable instruments or equipment may be operated under a special flight permit issued in ac- cordance with 21.197 and 21.199 of this chapter. Even with FAR rules as a tool to help the operator, problems may become apparent that will decrease the effectivity of the overall discrepancy correction process. For example: • There may exist no common definition/understanding among the FAA, pilots and technicians that explains ge- neric terms such as “return to service” and what kind of “corrective action” clears a discrepancy write-up. • Discrepancies that are not safety- or flight-related and not
covered by a MEL may ground an aircraft needlessly. • Problem correction is best addressed through creation of
action plans designed to provide a specific set of solu- tions to those concerns that may be raised.
• It may prove helpful to hold meetings with the FAA, pilots and technicians regarding current MEL use and ap- plication, discrepancy deferral processes and regulations. • Time should be taken to define for all users “corrective
action” and “return to service” (see next section). Begin to document all discrepancies and corrective ac- tion in order to improve troubleshooting, speed of repair and the generation of a clean audit trail. Once all issues are addressed, the documentation of progress to date is
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Figure 4.5: Discrepancy Flow Process for Technicians and Flightcrew Members
Aircraft In Service
Discrepancy Noted in Flight/Discrepancy Log
*Decision Junction*
Aircraft Returned to Service Aircraft Grounded “AOG”
(Corrective Action Required)
Logbook Inspection
Discrepancy Present
Aircraft Flight/Postflight Inspection
Aircraft Status/Preflight Check
Discrepancy Present Corrective Action (Discrepancy Repaired) MEL Management (Discrepancy Deferred) Yes No No Yes No No Yes Yes
Figure 4.6: Discrepancy Log
q All prior pages completed Page #__________
Discrepancy Log/N __________
Flight Log # Discrepancy Deferral MEL Item # q TFR to Deferred Discrepancy Log
Date Corrective Action q Removed from DDL if Necessary
Aircraft Hours
Flightcrew Signature, Cert. #, Date
Figure 4.7: Deferred Discrepancy Log
q All prior pages completed Page #__________
Deferred Discrepancy Log
Flight Log # Discrepancy Deferral MEL Item # Signature, Cert. #, Date
Date Corrective Action
Aircraft Hours
Flightcrew Signature, Cert. #, Date
important. Documentation includes both definitions and graphics that clearly illustrate the desired discrepancy cor- rection process. Such a reference also is the blueprint for an implementation plan.
Develop an aircraft maintenance binder with sections for a discrepancy log, postflight sign-offs, maintenance/inspec- tion work cards or due date lists, oil consumption, and so on. 4.15.2.1. Carry Over List
In addition to an MEL, it is helpful to develop a Carry Over List for cosmetic or non-airworthy type items, as well as for the documentation of dents and scratches that have been measured and found to be within limits. This can save any questions during an FAA ramp check or audit, and also keeps these things from getting forgotten at the next inspection or interval at which they can be addressed.
4.15.3. discRePAncy mAnAGemenT deFiniTions
4.15.3.1. Corrective Action
Correction action is defined as reasonable, prudent and progressive steps taken to resolve a discrepancy or problem with a component or system. Corrective action is accomplished either by (1) verification of system or component integrity as required by the manufacturer’s maintenance manual or instruction for continued airworthi- ness prepared by the manufacturer or (2) other methods,
techniques and practices acceptable to the administrator. Corrective action can include progressive troubleshooting to resolve the fault, component changes or other action taken that demonstrates positive steps in resolving the problem.
4.15.3.2. Return to Service
Approval to return an aircraft to service is authorized by the holder of an appropriate mechanic’s certificate. Once an aircraft’s discrepancy, fault, deviation, or error has been addressed in a reasonable and prudent manner (corrective action taken) and the appropriate entries have been made to the aircraft discrepancy log, the aircraft may be returned to service.
See Figure 4.5, “Discrepancy Flow Process for Techni- cians and Flightcrew Members,” illustrating the movement and disposition of a discrepancy.
Once the discrepancy management procedures are in place, follow-up is required to ensure that it meets both current and future needs of all participants.
Elements to consider are:
• Monitoring of discrepancy write-ups and corrective ac- tions to ensure that process is made routine
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Figure 4.8: Request for Proposal (RFP) Template
Company Name ________________________________________ Date _______________________________
Address _______________________________________________ Aircraft Type________________________
________________________________________________________ Registration # ______________________
Telephone ( ) _________________________________________ S/N ________________________________
Fax ( ) ________________________________________________ Desired
E-mail _________________________________________________ Start Date __________________________
Note: Please bid each line item separately. Airframe:
A. Inspections
1. 150, 300, and 600-hour ____________________________________
B. Service Bulletins
1. 32-118 Landing Gear Mod ____________________________________
2. 35-464 Oxygen Valve Upgrade ____________________________________
C. Avionics
1. C/W FAR 91.411 & 413 ____________________________________
2. RVSM 2-year renewal ____________________________________
D. Interior
1. Air stair carpet replacement ____________________________________
E. Paint 1. None required ____________________________________ Engines: (m/n: AAAAAA) A. #1 Engine (s/n: 123456) 1. 150-hour Inspection ____________________________________ 2. SOAP sample ____________________________________ 3. S/B 77-222 FCU mod ____________________________________ B. #2 Engine (s/n: 123457)
1. 150 & 300-hour Inspection ____________________________________
2. SOAP sample ____________________________________
APU: (m/n: BBBBBB)(s/n: 987642)
A. 300-hour inspection ____________________________________
Declarations: (Please declare the following separately)
A. Estimated downtime (normal weekdays or can the weekends be utilized) B. Shop rates (both regular and overtime)
C. Hazmat fee structure and is there a cap? D. Consumable fee structure and is there a cap? E. Local and state fee structure
F. Coordination of warranty programs for aircraft directly with manufacturer? G. Records research included in the inspection flat rate? (if required?) H. Freight charge structure
1. Flat fees
2. Component rate fee I. Are any fees applied to incoming parts? J. Payment methods, terms and conditions?
1. Down payments 2. Progress payments
• Validating that communication paths between pilots and technicians stay open
• Measuring the time between a noted discrepancy and the final correction
It is important that operators read and understand the FARs. Using an approved MEL along with an organized method of handling the day-to-day maintenance difficulties as outlined above can provide the high degree of operation- al flexibility necessary for a successful aviation department.
4.15.4. discRePAncy mAnAGemenT
RecommendATions
The MEL binder contains a copy of the Letter of Authoriza- tion with guidelines/procedures for deferrals. Records of discrepancies, deferrals and corrective action are kept in an aircraft maintenance binder under the title “Discrepancies” (see Figure 4.6).
A deferred discrepancy log is carried in the aircraft (see Figure 4.7).