AC 120-xX Aging Airplane Records Review and Inspections

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Manager, Flight Standards Service Continuous Airworthiness Maintenance Division AFS

300 Flight Standards Service Federal Aviation Administration 800 Independence Avenue SW Washington, DC 20591
.
Subject Comments to AC 120-xX
Aging Airplane Records Review and Inspections
Reference  GEM-RED-0799-2334 Comments to AC 120-xX
dated 19 July 1999 ( 7 pages

attached )

The Reference attachment contains comments relative to the content of the Subject Advisory Circular.
Please advise if any additional information or explanation is required.

Sincerely

Member UACC
(Used Aircraft Certification Conformity Committee)

3

of 3
COPY

E-Mail : gembob@ibm.net
2601 Marber Avenue . Long Beach, CA 90815 . U.S.A. . Phone (562) 4255213 . Fax (562) 425-5243
Submitted by : R. E. Durbin, Gemini Aviation GEM-RED-0799-2334 19 July 1999
COMMENTS TO AC 120 -XX
AGlNG
AIRCRAFT RECORDS REVIEWAND INSPECTIONS

I.
GENERAL
a)
Direction
Comments :
The procedures as contained in the subject AC do not reflect the intent of the inspections as stated in the Federal Register /
Vol. 64, No. 63 ;
i.e.,
.
.
.
“prescribe regulations that
ensure the
continuing airworthiness of aging aircraft. ‘I..
. . .
.
.
.
“demonstrate to
the
Adminisfrafor, as part
of the
inspection, that
maintenance of the
aircraff’s age-
sensitive parts and components has been adequate and timely enough to
ensure the
highesf degree of safety. “.
. .
. . .49
U.S. C. 44717, which requires the
Administrator fo ‘I
prescribe regulations that
ensure the
continuing airworthiness of aging aircraft * * *
(and) to
make inspections and review the
maintenance and other records of each aircraft
an air carrier uses fo provide air transportation that
the
Adminisfrafor decides may be necessary fo enable the
Administrator fo decide whether the
aircraft is in safe condifion
and maintained properly for operation in air transportation. “.
. . , .
b)
Procedure
Comments :
Without a specific and written procedure to govern the audits and inspections most operators and DAR’s will typically direct their efforts to the minimum acceptable under the AC.
Under today’s guidelines, the various FAA Regions all have different standards covering the preparation and retention of records and documentation, most DAR’s recognize only the basic categories, some operators consider destruction of ”
hard ”
records to be beneficial, some FAA Regions and the vast majority of DAR’s do not recognize the regulatory requirements for Part 43 inspections of imported airplanes, etc.
4

Format
Comments :
Operators who systematically destroy their ”
hard ”
records reducing all past maintenance functions to automated ”
one liners ”
could satisfy the AC requirements with a one or two page printout.
d)
Definitions
Comments :
The AC contains requirements heavily dependent upon terms which are not defined by 14 CFR p
1 .I
or elsewhere ;
e.g., ”
status ‘I,
etc.
e)
Configuration
Comments : Airplane configuration, or compliance with the Type Data Sheets, is not given consideration.
r)
Traceability
Comments :
Traceability, or verification and authentication of Life Limited Part (LLP) records and history, is not given consideration.
9)
Lack of record requirements in 14 CFR
Comments 14 CFR does not require records and documentation which are considered critical during airplane transfer and under the Aging Aircraft Program; e.g., records to support details of major repairs. p
121.707 requires only a list of such repairs.
h)
Maintenance Programs
Comments : No consideration is given to the radical differences between the various operators Maintenance Programs; e.g., Continuing Analysis and Surveillance vs. Reliability. The manufacturer’s data also varies greatly between MPD’s
reflecting original, or basic, maintenance and later MSG-3.
Recommended scheduled maintenance of Controlled Parts not only vary between the various programs
but disappear altogether in later versions. Some Maintenance Programs have Time Controlled Component (TCC) requirements over and above the MPD, etc.
Recent MPD’s,
and many operator Maintenance Programs, have incorporated the Aging Aircraft Program requirements into the basic schedule. It is doubtful that a review of these programs would reveal which specific items have their origins in the Aging Aircraft Program.
i)
Transfer of Records
Commenfs :
The AC does not address the transfer of records with the airplane to verify the last inspection and audit under p
121.368. For some unknown reason FAA correspondence addresses only the Sale of airplanes ignoring the most common reason for leaving an operator’s fleet; i.e., return to lessor. As records and documentation must be considered an integral system of an airplane, all such data should be required by regulation to accompany an airplane when leaving a particular fleet for any reason.
Penalties
0
Comments :
The method of restricting continued operation of airplanes failing this inspection, or the penalties to be assessed to either the operator or DAR under p
21.2 or #
43.12 for lack of records or incorrect acceptance of the required inspection is not defined.
II. SPECIFIC
1. PURPOSE.
Commenfs :
No Comment.

2. EFFECTIVE DATE.
Comments :
No Comment.

3. FORMS AND REPORTS.
Comments : p
121.368, etc., do not meet the stated statutory requirements as repeated in the Federal Register, Vol. 64, No. 63.

4. DEFINITIONS.
Comments :
Inadequate. At a minimum, the terms ”
status “,
”
major repair ‘I,
”
overhaul ‘I
as it applies to structural assemblies, etc., must be defined in regulations.
Under normal circumstances the definition provided for Years in-service should suffice. Unfortunately, airplanes that received their first Airworthiness Certificate from foreign agencies, and have subsequently been transferred into the U.S., may or may not still possess documentation attesting to the original date of issuance. U.S. operators are in the habit of destroying all old, or dated, documentation. Consideration should be given to using the Date of Manufacture or Original Delivery for, at least, all imported airplanes.

5. RELATED READING MATERIAL.
Comments :
Referenced documents do not cover many areas.

6. BACKGROUND
a. Public Law.
Comments :
The inspection as presently constituted seems to be based on a misconception of the intent of the referenced Public Law. Assurance that ”
Aging Aircraft ”
remain airworthy is not limited to just those items which fall under the Aging Aircraft Program. All areas covered by this AC could be in perfect order while the lack of documentation attesting to configuration, repairs, adherence to
Maintenance Manual standards, etc., could be typically absent. 14 CFR, for example, does not require accurate Service Bulletin accomplishment data even though certain of these non-regulatory documents
have replaced the Type Data Sheets; e.g., engine Life Limited Parts (LLP).
b. Operator requirements.
Commenfs :
Other than the Flap Hinges on many older Douglas airplanes, there is not a significant number of structural LLP’s
even though some may become age-sensitive due to untreated, or uncorrected, corrosion,
c. Mandatory 15 year aging aircraft inspections.
Comments : Airplane structural inspections that cover only those items which fall under the Aging Aircraft Program could not confirm whether the airplane was airworthy. 14 CFR does not require the retention of all drawings, calculations, etc., required to complete a major repair. p
121.707 requires only an undefined report.
Representatives of the Administrator, that is DAR’s as indiscriminately empowered under Part 183, are not qualified to perform physical inspections on any and all models of airplanes under the rules and restrictions of their AP Licenses.
7. GENERAL PROVISIONS OF THE ‘I
AGING AIRPLANE SAFETY “
RULE REGARDING AGING AIRCRAFT RECORDS REVIEW AND INSPECTIONS.
a. Rule Requirements.
Commenfs :
No Comment.
b. Airplanes and Operations Affected.
Comments : No Comment.
c. Records Review and Inspections.
Comments : By what means are the operators to be prevented from operating an airplane that has not undergone or failed the required inspections ? Will the airplane’s Standard Airworthiness Certificate be revoked ? Will the FAA formalize the terms now in use to cover many such areas, ”
Valid ”
and ”
invalid ”
?
What if the operator decides to return the airplane to its lessor while under such restrictions ? What will enable the owner or lessor to determine that the airplane has not been properly maintained ?
Is it possible that an airplane which has failed the inspection in one FAA Region could be transferred to another where it may have a better chance of passing ? Can a different DAR be called in to overrule the one who declared the airplane to have failed the inspection ? Can a DAR overrule a PMI decision ?
d. Extensions.
Comments :
No Comment.

8. CONDUCT OF AGING AIRCRAFT RECORDS REVIEW AND INSPECTIONS.
a. Acceptable procedure.
Comments :
Although this may be the proper way to identify procedures within an Advisory Circular, it will not suffice in practice. There must be a firm, official, minimum listing of how to perform the required inspections, what is expected, and the minimum records which must be retained and transferred with the airplane.
b. Procedure for notifying the FAA of a due review and inspection.
Comments :
A simple request to have records ”
. . *available
at the aircraft’s location.. .I’
is not adequate. Owners, lessors and others who are routinely engaged in the return and transfer of airplanes will attest to the fact that these instructions are inadequate. Several requirements which have been obtained and paraphrased from Volume 304B 0
of the 300 Handbook are included below :
. . , . . . . all Records and Documentation (will be provided) in specified form, format and
condition. . . . . including lnven tory List. . . . .
. . . .A11
records and Documentation shall be provided at one central point.. . . not less than (ten (70)).
.
business days prior to (inspection). . . . .
. . . . (Operator) shall provide assistance as required and /or
requested by (inspector). to catalog
Records and Documentation and ensure adequacy and completeness.. . . .
. . . . . Each page of all acceptable Automated Records shall be Verified and Authenticated with a
signature or stamp representing (Operator) Quality Assurance.. . and dated. The Records shall be
accompanied by a letter identifying (Opera tors)signa
tory agent. . . . .
. . . In
event of missing, incomplete, mutilated, or otherwise unacceptable Records, (Operator) shall
produce alternative documentation acceptable to (Inspector) or, at its sole cost and expense,
re-accomplish tasks necessary to produce such records in accordance with its approved.. . . . . Program, or
other con trolling document. . . . . .

c. Aircraft Inspections.
Comments .’
It is not likely that all necessary major repair records and supporting documentation will exist for airplanes over fourteen years of age. It is unfortunate that the predominance of record librarians of U.S. operators direct their efforts to minimizing the quantity of records rather than optimizing quality and safety.
The U.S. FAA has never settled the question of what constitutes a Major Repair. 14 CFR presents two diametrically opposed definitions in p
1 .I
General definitions. and Part 43, Appendix A. It is not impossible that a number of U.S. operators which have been in operation for many years have ever, by their internal standards, performed a Major Repair.
#
121.707 requires that a ”
report ”
on each major repair be retained, however, the term ”
report ”
is not defined. In practice, if anything at all is kept, it is a non-definitive listing. The statement, “.
. . . inspections also will be based on the review of all the records required by the rule.. . . .‘I,
should be expanded and defined.
The statements, “.
. . . primarily on those parts of the aircraft that are accessible...“, and, “....may
require additional access.. .“,
are license to ignore physical inspections. No operator leaves an airplane wide-open for inspection in all areas regardless of the maintenance function. Even if it is open, manpower to assist in the inspection may or may not be available. For example, Q
21.183(d)(2) specifies that a Part 43, Appendix D, IOO-hour inspection must be performed per p
43.15 of obtain a Standard Airworthiness Certificate. This requirement is universally ignored by operators, DAR’s and the FAA as it requires that all areas of the airplane necessary to facilitate the inspection must be open. Generally any C-Check, or minor phase portion thereof, is found to be an acceptable substitute although it is never inventoried. Under the specified guide-lines, this inspection will fall into the same mis-use as, for no other reason, the same personnel are involved.
d. Required Records.
(1) Records required for review and inspection.
Comments :
Listing is not adequate.
(i) Total years in service.
Comments :
Suggest substituting manufacturer’s date of delivery to establish zero time. Such data is a matter of common record whereas the date of issuance of an airplane’s first foreign airworthiness certificate may not be.
(ii) Total flight hours of the airframe.
Comments :
No Comment.
(iii) Total flight cycles of the airframe.
Comments :
No Comment.
(iv) Date of last aging aircraft records review and inspection.
Comments :
Date alone should not be considered adequate. The Form XX-X, Discrepancy Lists and other reports resulting from the last review and physical inspection fall into the category’of Unsuperseded Records and should be made readily available.
(v) Current status of life-limited parts of the airframe.
Comments : The term ”
status ”
is not defined in 14 CFR and can become an argumentative term during the transfer of records. Those operators who feel, ”
. . . the fewer records, the better.. .‘I,
interpret ”
status ”
to mean only Date, Part Number, Serial Number, and pertinent time either as TT
or TC. In short, they limit the LLP records to those maintenance items contained in p
121.380 with ”
free interpretation ”
of the term ”
status ‘I.

Those operators who maintain and believe in complete record systems also include, and require at transfer, data established by Parts 21 and 25, etc. These operators recognize that the origin of the LLP are the Type Data Sheets, not the MPD as Time Controlled Components (EC).

Few airframe structural components fall into the category of Life Limited Parts (LLP). An example are the Flap Hinges on older Douglas airplanes. Landing Gear, on the other hand, have a relatively large number of LLP’s.

As the term ”
airframe ”
is defined by p
1 .I
it includes Landing Gear : Airfi-ame
means the fuselage, booms, nacelles, cowlings, fairings, airfoil surfaces...... and landing gear of an aircraft and their accessories and controls.
It should be understood that Landing Gear Records may be the most deficient area of any given airplane.
(vi) Time since last overhaul of time controlled structural components.
Comments :
The term, ”
Overhaul “,
has for all practical purposes disappeared from U.S. operators maintenance procedures. What is to be the governing specification ? The operator’s Maintenance Program or the MPD ?
(vii) Current inspection status of the airplane.
Comments : Are the Records produced by the last un-superseded inspection also subject to review ? If so, they must be specified on the procedure.
(viii) Current status of the following, including method of compliance.
Comments : The term ”
status ”
is not defined in 14 CFR; it can mean something different to everyone involved. Method of Compliance means simply the SB number to some operator’s automated records.
(A) Airworthiness Directives
Comments :
Due to the variance in U.S. record keeping, the instructions in such an important area must be spelled out in detail. The following comments are extracted from basic instructions in -302A
Domestic 0
and other standard industry procedures established by persons specializing in the transfer of airplanes and records : a.) Of primary importance is the documented assurancethat the part upon which the AD was accomplished is still installed in the airplane and has not been replaced with a part not in compliance.
b.) The AD list must contain all AD’s issued against the particular airplane, its engines, appliances and accessories. Those AD which are not applicable to the particular airplane must be explained; e.g., AD accomplished in production, FSN not listed for action, etc. The simple, Not Applicable is not acceptable. It should be understood that the manufacturer’s and industry AD lists are seldom complete as the issuers of such lists have no way of knowing of AD’s active against interior items, etc., installed by the operator.
c.) Automated lists which contain only the AD number, SB, date, and limited supporting information such as, ”
. . . part changed per AD.. .‘I,
are not sufficiently definitive. At a minimum, the AD and SB revision numbers must be supplied in addition to an expanded Method of Compliance. If an SB reference is used for the compliance, there must be some assurance that the operator followed the letter of the SB and made no unapproved revisions. As the SB is not a regulatory document it is common practice to alter, redesign, or selectively comply with SB contents.

d.) When airplanes are imported into the U.S. little attention is paid to the fact that some AD’s which are noted as Complete, or closed, from foreign countries may still be Open in the U.S. due to additional regulatory requirements.
e.) Dedicated AD files containing specified Method of Compliance in the form of Engineering Orders, and Verification of Accomplishment on completed Shop Cards have disappeared from operators dedicated to automated one-liner records.
(B) Corrosion Prevention and Control Programs.
Comments :
Has been incorporated into the basic Maintenance Program on many airplanes. No separate or dedicated files kept.
(C) Aging aircraft supplemental inspection.
Comments :
No Comment.
(ix) List of major structural alterations.
Comments :
Request for a simple, ‘I..
. . list of major structural alterations.. . .“,
is not sufficiently definitive. An STC is self explanatory, but past that point ”
major ”
is subject to debate. Is it based on complexity ? . . . . cost ? . . . Principal Structural Element ? . magnitude ? The geographical approach supplied by 14 CFR Part 43, Appendix A is also non-definitive and is seldom utilized by U.S. operators.
(x) Report of major structural repairs.
Comments : Request for a simple, ‘7.
report of major structural repairs and the current inspection status for those repairs.. . .“,
is not adequate. Some U.S. operators do not recognize the term, ‘I..
. major repair.. .“,
and 14 CFR does not, including p
121.707 or Part 43, Appendix B provide definition of the data which must be retained. The ”
report ”
of p
121.707 is not defined in f
1 .I.
It could consist of a simple listing with such inputs as, “.
. . . repaired leading edge of RH wing.. .“.
Complete contractual requirements for the purchase, return or transfer of an airplane include data, such as :
If..
. . All technical and engineering data, calculations, drawings and documentation identified within the various parts of 74 CFR
and which may result from these Repairs and /or Alterations shall become a permanent part of the airplane maintenance records and delivered, without exception, at delivery of airplane.. . . . ‘:

Although various sections of 14 CFR may assume that such instructions will be followed due to implication, such is not the case especially as ‘I
4 CFR requires retention of such important data but one year and does not address transfer of airplanes.
(2) Aging aircraft supplemental inspections.
Comments : How will an airplane be prohibited from operating ? What is to prevent a lessee from returning an airplane to a lessor without a report on this inspection ? 14 CFR does not require retention of these reports nor their transfer with the airplane.
(3) Additional information.
Comments : Although the intent of this item is good, it is not sufficiently definitive. Again, the term, ”
status ‘I8
is not defined. Without going into detail, there are major U.S. operators who claim not to be capable of locating such records. As a particular operator’s maintenance may be accomplished in a number of different locations or cities, it is doubtful that they will adhere to bringing all supporting documentation to a single point. If a DAR is willing to buy off the airplane based on a simple type-written, automated, one-liner record then the inspection must be considered a Rubber Stamp operation.
9. DESIGNATED AIRWORTHINESS REPRESENTATIVES.
Comments :
The way that this particular paragraph is worded it sounds as if the ”
inspection ”
is limited to records. With very few exceptions, DAR’s have not been required nor trained to possess the necessary level of expertise to conduct the required record reviews and audits.
Few leasing companies or owners would hire someone off of the street to perform airframe inspections on any and all models. The best inspectors know their limitations and normally take steps to augment their experience levels or transfer the task to someone who possesses the necessary expertise. Inclusion in Part 183 notwithstanding, the power to conduct inspections in no way alters the fact that the majority of DAR’s are not capable of such responsibilities.
The restrictions of a DAR’s A &
P license state that only those tasks which have been demonstrated under proper supervision can be accomplished. If a DAR has never been trained in a particular model, as must any mechanic working on the airplane, how may they exercise authority to accept or reject physical installations ?
Anyone, DAR or other, who is to be granted authority to perform these inspection tasks should be trained and certified. Blanket Part 183 acceptance is not realistic.
10. COMMENTS INVITED.
Comments :
Comments supplied
11. APPENDIX. FAA Form XX-X, Result of Aging Aircraft Inspection.
Comments :
It should be specified that the Form and all Discrepancy Lists, actions to restrict operation, etc., become a permanent part of the airplane records and are not to be destroyed nor reduced to automated one-liners. In addition, such documentation must be transferred with the airplane when it leaves an operator’s fleet for any reason.
If a DAR signs Form XX-X due to finding all records acceptable during Inspection One, what action is to be taken if Inspection Two reveals that such records were never imported or haven’t existed for an extended period of time ? What action will be taken against an operator under the same conditions ?

Submitted by : Robert E. Durbin Gemini Aviation 2601 Marber Ave., Long Beach, CA 90815 Tel. : 562-425-5213 Fax : 562-425-5243